Is Cyprus on the EU Grey or Black List? The Facts

Cyprus on the Global Listing Map: What Grey and Black Lists Actually Mean for a Foreign OwnerCopy link to section

The short answer on the grey/black list in Cyprus is that the country sits on none of the major ones. As an EU Member State, it is structurally excluded from the EU list of non-cooperative jurisdictions, and it carries no FATF grey or black list designation. For a foreign owner, that status is the baseline that lets a Cyprus company open accounts and trade without the blanket Enhanced Due Diligence that follows a listed jurisdiction.

This article explains how each listing body treats Cyprus, why the country once drew scrutiny, and what the residual reputational picture means for your banking and compliance. It is most relevant to non-resident investors weighing a Cyprus holding or trading structure, and to advisers who must reassure banks and counterparties about the entity's standing. The authoritative reference point for the EU dimension is the EU Council list.

The Listing Bodies That Matter: EU, FATF, OECD and National Watchlists ExplainedCopy link to section

Several institutions maintain their own lists, and they measure different things. Understanding which body assesses what keeps you from confusing a tax-transparency rating with an anti-money-laundering finding.

The EU first adopted both annexes on 5 December 2017, with revisions issued no more than twice a year, usually in February and October. The FATF updates its two public documents three times a year after each Plenary; its blacklist names Iran, North Korea, and Myanmar, while its grey list covers 22 jurisdictions.

The OECD Global Forum runs peer reviews under a multilateral framework of more than 170 participating jurisdictions, assigning one of four ratings. National watchlists, such as US FATCA arrangements or individual EU-member domestic lists, run alongside these and are treated separately below.

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Cyprus and the EU Lists: Status on Annex I (Blacklist) and Annex II (Greylist)Copy link to section

Cyprus appears on neither Annex I nor Annex II. The EU list applies only to non-EU third countries, so membership of the Union removes the question entirely.

For context, Annex I held eleven jurisdictions as of October 2025: American Samoa, Anguilla, Fiji, Guam, Palau, Panama, the Russian Federation, Samoa, Trinidad and Tobago, the US Virgin Islands, and Vanuatu. Annex II held nine as of February 2026, including Belize, the British Virgin Islands, Brunei Darussalam, Eswatini, Greenland, Jordan, Montenegro, Morocco, and Türkiye.

The country does, however, apply the blacklist outward. Effective 31 December 2022, withholding tax falls on certain payments where the recipient company sits in an EU-blacklisted jurisdiction, subject to double-tax-treaty reductions or exemptions.

Heightened DAC6 reporting also attaches to certain related-party transactions between EU taxpayers and counterparts in blacklisted states. Note that Türkiye, listed on Annex II, does not exchange CRS data with Cyprus, a point recorded in the February 2026 Council conclusions. The next EU list update is expected in October 2026.

Cyprus and the FATF: Mutual Evaluation History and Grey/Black List StandingCopy link to section

Cyprus is not on the FATF grey list or blacklist. Its AML/CFT system is assessed through MONEYVAL, the Council of Europe body that conducted the evaluation on FATF's behalf following an on-site visit in May 2019.

The resulting Fifth-Round Mutual Evaluation Report set the technical baseline. On 18 June 2025, MONEYVAL published its 4th Enhanced Follow-up Report, acknowledging significant progress on technical compliance.

By that report, the country is rated Compliant or Largely Compliant on 38 of the 40 FATF Recommendations, with none assessed as Non-Compliant. The one remaining weakness is Recommendation 8 on Non-Profit Organisations, rated Partially Compliant for gaps in risk assessment and regulatory measures.

The 6th-Round Mutual Evaluation is scheduled for October 2028, and the 5th-round follow-up process no longer applies. A 2008 FATF statement on AML improvements concerned the northern part of the island, not the Republic of Cyprus.

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Cyprus and the OECD: Harmful Tax Practices and Transparency Peer ReviewsCopy link to section

The OECD Global Forum rates Cyprus "Largely Compliant" on exchange of information on request, a result confirmed in a second-round peer review and unchanged from the first rating announced in 2015. The Cypriot Finance Ministry described the country as widely compliant with the international standard.

Implementation rests on EU Directives transposed into national law, the bilateral double-tax-treaty network, and other international instruments. In May 2026, the country signed the Multilateral Competent Authority Agreement on the Exchange of GloBE Information, extending its commitments under the Pillar Two framework.

On harmful tax practices, no active adverse finding from the Forum on Harmful Tax Practices has been identified against the jurisdiction; the IP Box regime is FHTP-compliant under the modified nexus approach. The country participates in the OECD/G20 Inclusive Framework on BEPS.

Third-Country Listings: How the US, Russia and Other States Treat CyprusCopy link to section

The United States operates a Model 1 FATCA intergovernmental agreement with the country, under which Cypriot financial institutions report to the Cyprus Tax Department, which then exchanges data with the IRS. The country sits on no US Treasury list of non-cooperative jurisdictions.

• Russia: Russia itself is on EU Annex I. The Russia-Cyprus double-tax treaty was terminated in 2023 after Russia suspended it in response to sanctions; this affects Russian-owned structures but reflects no listing of Cyprus by Russia.
• EU member-state domestic lists: Individual states may run their own lists alongside the EU one. No retrieved domestic list names the country.
• Türkiye: The absence of CRS exchange is a bilateral political matter, not a formal listing.

No public data confirms the country's appearance on any other named national watchlist, such as those of the UK, UAE, India, or China.

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Why Cyprus Has Drawn Scrutiny: The Specific Reasons Cited by Each BodyCopy link to section

Scrutiny clustered around the now-abolished citizenship-by-investment scheme rather than the core tax or AML framework. The 2019 MONEYVAL report found that vulnerabilities tied to the Cyprus Investment Programme had increased sharply, particularly through real estate, and had not been comprehensively assessed.

On technical compliance, that same report rated the country Largely Compliant on customer due diligence by banks and by designated non-financial businesses, and on beneficial ownership transparency for legal entities and arrangements. The concerns were about effectiveness in one programme, not systemic failure.

The 2020 "Cyprus Papers" investigation reported that investment above €2 million had secured EU citizenship for roughly 1,400 individuals and their families between 2017 and 2019, with at least 30 primary applicants said to face criminal charges or convictions and 40 identified as politically exposed persons. Transparency International judged the passport scheme vulnerable to corruption and money laundering.

The European Commission advanced infringement proceedings, stating that citizenship was being sold without any residence requirement in breach of Union law. The OECD's 2020 peer review added recommendations on beneficial ownership availability and enforcement while keeping the Largely Compliant rating.

Commitments and Action Plans: How Cyprus Responded and Achieved DelistingCopy link to section

No formal delisting event exists, because the country was never placed on the FATF grey list or the EU annexes. The scrutiny that did arise was addressed through concrete steps.

1. Programme closure: The citizenship-by-investment scheme was scrapped in late 2020, following the Al Jazeera investigation.
2. Criminal accountability: Four people, including the former head of the Cyprus Parliament, were charged with corruption over the scheme.
3. AML reform: The June 2025 MONEYVAL follow-up upgraded Recommendation 13 on correspondent banking to Largely Compliant after amendments applied uniform due diligence to all cross-border correspondent relationships.
4. OECD commitments: Authorities committed to further transparency recommendations and, in May 2026, signed the GloBE information-sharing agreement.

As of June 2025, the country exited the MONEYVAL enhanced follow-up process, with the next full evaluation not due until October 2028.

Practical Consequences for You: Enhanced Due Diligence, Banking Friction and Investor PerceptionCopy link to section

Because the country carries no FATF listing, banks and payment processors have no FATF-mandated obligation to apply blanket Enhanced Due Diligence to your Cyprus counterparties. That blanket trigger attaches to grey-listed jurisdictions, and the threshold is not met here.

Residual reputational friction persists, however. The 2020 passport scandal, the Pandora Papers exposure of registered vehicles, and the 2019 MONEYVAL findings have raised the perceived risk profile of certain structures in the eyes of some correspondent banks and compliance teams.

Expect requests for source-of-funds documentation, business-rationale explanations, and full beneficial owner disclosure where a bank internally rates a transaction as elevated risk. The golden-passport investigation remained in its final stage as of autumn 2025, which keeps some reputational pressure on the wider corporate ecosystem.

Tracking Current Status and the Outlook for CyprusCopy link to section

The EU list updates each February and October, with the next revision expected in October 2026; membership of the Union keeps the country off Annex I and II regardless. Watch the Council page for changes to the defensive measures the country applies to third parties.

On the AML side, the next full MONEYVAL evaluation is set for October 2028, with no interim enhanced follow-up reports due. The single open weakness on Non-Profit Organisations is unlikely to prompt grey-listing on its own.

The OECD rating holds steady at Largely Compliant, with monitoring continuing between full reviews and the May 2026 GloBE signature reinforcing a cooperative posture. The principal variable is the golden-passport case, in its final stage as of autumn 2025, where adverse findings could re-attract attention; the lapsed Russia treaty, meanwhile, depends on geopolitical direction.

ConclusionCopy link to section

A Cyprus company starts from a clean position: no EU annex, no FATF list, and a steady Largely Compliant transparency rating. The work that remains for a foreign owner is at the counterparty level, where source-of-funds and beneficial owner evidence matters more than the jurisdiction's own standing. Treat the residual reputational legacy as a documentation task rather than a barrier, and keep an eye on the October 2028 evaluation and the closing golden-passport proceedings.

How Expanship Can Help Your Business in CyprusCopy link to section

Expanship helps you document and present a Cyprus company's clean listing status to banks and counterparties, and prepares the source-of-funds and beneficial owner files that ease account opening where compliance teams ask for them. That sits within a wider service set for foreign-owned entities operating in the jurisdiction.

• Company formation and structuring for non-resident owners
• Registered agent and registered office services
• Tax registration and ongoing filing obligations
• Compliance management aligned with AML and reporting rules
• Accounting and bookkeeping
• Introductions to banking and payment providers

To discuss your structure, contact Expanship Cyprus.

Frequently Asked QuestionsCopy link to section