Key Takeaways
- Grey and black list designations differ across the EU, FATF and OECD, so Dominica's standing depends on which body and criteria you check.
- Specific concerns cited against Dominica come with commitments and action plans that set the path toward delisting.
- Foreign owners feel listings most through banking access, heightened due diligence and reputational perception rather than direct legal bans.
- Dominica's citizenship-by-investment programme is a notable factor that influences how watchlist bodies assess its listing risk.
Dominica on the World's Watchlists: What "Grey" and "Black" Really Mean Here
The grey and black list question in Dominica matters because three separate international bodies maintain lists that shape how banks and counterparties treat a jurisdiction: the EU Council, the Financial Action Task Force (FATF), and the OECD Global Forum. For a foreign owner, the practical concern is simple: does a Dominican company or passport carry a formal listing that triggers defensive measures, withholding surcharges, or enhanced due diligence abroad?
The short answer is no. Dominica appears on neither the EU list of non-cooperative jurisdictions nor either FATF watchlist, having been cleared of both EU annexes by February 2024. This article explains how each list works, why the country was once listed, how it exited, and what residual scrutiny remains for entities and individuals connected to it.
The material is most relevant to non-resident investors weighing incorporation, advisers running counterparty checks, and anyone holding or considering Dominican citizenship by investment.
The EU Perspective: Dominica on Annex I and Annex II
The EU maintains two registers. Annex I is the blacklist of jurisdictions deemed non-cooperative on tax; Annex II is a "state of play" grey list for countries that fall short of standards but have committed to reform, with their progress tracked until they comply or are removed.
The relevant authority is the Council's Code of Conduct Group (Business Taxation), mandated in November 2016, with the first list published on 5 December 2017. Listing decisions are adopted as conclusions of the Ecofin Council and revised at scheduled review dates.
Dominica was added to Annex I in the February 2021 review, replacing Barbados, for failing the tax transparency criterion of an "at least Largely Compliant" OECD rating on exchange of information. By October 2021 it moved to Annex II after committing to reform, then exited both lists entirely in February 2024 on receiving a positive rating.
The country was absent from both annexes at the February 2025 and October 2025 reviews. The lists below show the entities a foreign owner would actually need to treat with caution under the current EU framework.
| List | Jurisdictions | Dominica |
|---|---|---|
| Annex I (blacklist), 11 | American Samoa, Anguilla, Fiji, Guam, Palau, Panama, Russia, Samoa, Trinidad & Tobago, US Virgin Islands, Vanuatu | Not listed |
| Annex II (grey list), 8 | Antigua and Barbuda, Belize, British Virgin Islands, Brunei Darussalam, Eswatini, Seychelles, Türkiye, Viet Nam | Not listed |
Company Incorporation in Dominica
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FATF Status: Where Dominica Stands on the Grey and Black Lists
FATF publishes two registers three times a year for anti-money-laundering and counter-terrorist-financing weaknesses: the black list ("High-Risk Jurisdictions subject to a Call for Action") and the grey list ("Jurisdictions under Increased Monitoring"). Dominica's compliance is assessed by the Caribbean Financial Action Task Force (CFATF), the regional body operating under FATF methodology.
The country sits on neither list. Its absence is confirmed on the FATF country page, which records no current grey- or black-list designation.
As of February 2026 the FATF black list named only three states: North Korea, Iran, and Myanmar. The June 2025 grey list ran to 24 jurisdictions, including British Virgin Islands, Monaco, and South Africa, with Dominica not among them.
The most recent assessment followed a CFATF onsite visit between 15 and 26 August 2022, measuring the system against the 40 FATF Recommendations. FATF reviewed and endorsed the findings, and at least one follow-up report has tracked progress on technical compliance since.
An earlier CFATF public statement around May 2013 once flagged deficiencies, but sufficient progress led to removal from that process.
OECD and Global Forum Assessments of Dominica
The OECD Global Forum rates jurisdictions on exchange of information on request (EOIR), and this rating is the hinge on which EU listing turns. A score below "Largely Compliant" is what put Dominica on the blacklist in the first place.
The 2020 Second Round Peer Review rated the country Partially Compliant. During the review period of 1 April 2016 to 31 March 2019 it received only two information requests, answered each within 90 days, and sent none of its own, leaving thin practical experience.
A Second Round Supplementary Report, published in November 2023, reassessed practice. Two elements stayed Partially Compliant: A.1, availability of ownership information, and A.2, availability of accounting records. The report did acknowledge fixes to access powers, taxpayer safeguards, and confidentiality in court-compelled document production.
The supplementary review produced a positive overall rating, which directly triggered the EU's removal of Dominica in February 2024. An Enhanced Monitoring Report followed in 2025, the standard post-review track that keeps implementation under observation.
One structural point is worth recording for tax purposes: the offshore-bank tax exemption was repealed, with grandfathering ending in December 2021, so the jurisdiction now levies corporate and individual income tax under its Income Tax Act.
Ongoing Compliance in Dominica
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Timeline of Listings and Delistings: A Year-by-Year Record
The path runs across two decades and three bodies. Reading it chronologically shows how AML progress and tax transparency interlocked to put the country on, and then off, the EU lists.
- 2013 (CFATF): Public statement identifies AML/CFT deficiencies; later removed after progress.
- November 2014 (CFATF): All 13 core and key recommendations rated PC or NC addressed; removed from enhanced follow-up.
- December 2017 (EU): First EU list adopted; Dominica not listed.
- December 2020 (OECD): Second Round Peer Review rates the country Partially Compliant on EOIR.
- February 2021 (EU): Added to Annex I, replacing Barbados.
- October 2021 (EU): Moved from Annex I to Annex II alongside Anguilla and Seychelles.
- August 2022 (CFATF): Onsite mutual evaluation visit, 15 to 26 August.
- November 2023 (OECD): Supplementary EOIR report published.
- February 2024 (EU): Positive rating earns full removal from both annexes.
- 2025 (OECD): Enhanced Monitoring Report published; observation continues.
- February and October 2025 (EU): Absent from both annexes at each review.
- June 2025 (FATF): Absent from both the grey and black lists.
The Specific Reasons Cited Against Dominica
The EU listing had a single, traceable cause. The 2020 EOIR rating of Partially Compliant fell short of the "at least Largely Compliant" threshold, and that gap alone was enough for Annex I in February 2021.
On the OECD side, the live deficiencies concerned the availability of beneficial ownership information and of accounting records, compounded by minimal practical experience in handling requests.
The 2022 CFATF mutual evaluation found a different set of gaps. Despite amendments to the Money Laundering Prevention Act in 2020 and August 2022, technical shortcomings remained in several areas.
- Targeted financial sanctions for terrorist financing and proliferation financing
- Oversight of non-profit organisations
- Treatment of new technologies
- Regulation and supervision of designated non-financial businesses and professions (DNFBPs)
- Transparency and beneficial ownership of legal persons
Effectiveness was also weighed down by limited investigative resources and the non-prioritisation of money-laundering cases in the courts, with no ML convictions recorded as of the review. The Financial Services Unit (FSU) ran 226 inspections, covering all offshore banks on beneficial ownership obligations, and issued written reprimands and monetary penalties where it found failings.
Dominica Incorporation Pricing
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Commitments and Action Plans for Exit
Exit from the EU grey list rested on one deliverable: satisfying the EOIR standard to the Global Forum's satisfaction. Dominica gave the political commitment to good tax governance in October 2021, met it through the 2023 supplementary review, and was removed in February 2024.
The AML track ran in parallel and earlier. Between 2009 and 2014 the country passed amendments to the Money Laundering Prevention Act, the Proceeds of Crime Act, and the Suppression of Financing of Terrorism Act, clearing all 13 core and key recommendations and exiting enhanced follow-up in November 2014.
Following the 2022 evaluation, the jurisdiction reports to CFATF plenary meetings to demonstrate continued technical progress. The 2025 OECD Enhanced Monitoring Report confirms that residual obligations survive a positive rating, which is the normal post-review condition for every assessed jurisdiction rather than a sign of fresh trouble.
Practical Consequences for Foreign Owners: Banking, Due Diligence and Perception
While the country sat on Annex I between February and October 2021, the consequences were concrete. EU-blacklisted entities generally cannot transact freely within the bloc or with EU companies and face serious obstacles with euro transfers.
EU member states apply defensive measures against Annex I jurisdictions; 18 states applied at least two of the four agreed legislative measures. The DAC6 disclosure regime for tax intermediaries, in force from 1 July 2020, also imposed heightened reporting on schemes involving listed countries.
Those triggers no longer apply. With Dominica off both annexes since February 2024, the formal basis for defensive measures, enhanced DAC6 obligations, and withholding surcharges that certain states such as Cyprus levied on listed entities has fallen away.
The FATF position is similarly clean. Enhanced due diligence is mandatory for grey-listed counterparties, but since the country is not grey-listed, that FATF-based obligation does not attach to Dominican-connected parties.
A clean listing status reduces friction; it does not erase it. The 2021 blacklisting and grey-list period through 2024 persist in bank AML risk models, so onboarding of Dominican-incorporated entities or passport holders may still draw elevated review.
Counterparties running enhanced checks will also find the FSU's documented inspection findings and penalties in the public record. That is a factor to anticipate rather than a barrier, and clean corporate documentation answers most of it.
How Dominica's Citizenship-by-Investment Programme Shapes Its Listing Risk
The Citizenship by Investment (CBI) programme has run since 1993 under the Citizenship by Investment Act, Cap. 1.2. It is the single largest reputational variable bearing on future listing risk, because passports sold to foreign nationals can, without sound vetting, enable identity obfuscation and cross-border crime, a category FATF addresses in dedicated guidance.
Successive legislative refinements have aligned the programme with FATF Recommendations 10 and 22 and with CFATF evaluation findings. The IMF, in Country Report No. 26/117, flagged CBI-related reforms as a priority area and pointed to tightened governance, stronger revocation powers, stricter agent eligibility and applicant due diligence, and regional oversight through the Eastern Caribbean Citizenship by Investment Regulatory Authority (ECCIRA).
The IMF Board encouraged further progress and welcomed the reforms while noting room for better data reporting and governance. As of 2026 the regime reflects a measurable shift toward heightened source-of-funds documentation and enhanced due diligence, with a four-tier vetting structure maintained by the CBI unit.
The interplay is direct and worth understanding before relying on the programme. Any future weakening of CBI due diligence, or a cluster of CBI-linked crime typologies, could prompt an adverse CFATF finding, and that finding is the principal mechanism that could re-trigger an EU listing under the EOIR criterion.
Current Status at a Glance and the Outlook Ahead
The position across all four registers is consistent and favourable.
| Register | Status | Note |
|---|---|---|
| EU Annex I (blacklist) | Not listed | Removed October 2021; never re-added |
| EU Annex II (grey list) | Not listed | Removed February 2024; absent 2025 reviews |
| FATF blacklist | Not listed | List held to three states |
| FATF grey list | Not listed | Absent from June 2025 list of 24 |
| OECD Global Forum EOIR | Positive rating | Under 2025 Enhanced Monitoring |
| CFATF | Standard follow-up | No public statement active |
Staying off the lists depends on holding the positive EOIR rating; a downgrade would re-open the EU Annex I or II question. The 2025 Enhanced Monitoring Report signals that the Global Forum continues to watch implementation.
IMF pressure on CBI reform keeps that programme the leading risk factor. The technical AML gaps named in the 2022 evaluation, DNFBP supervision, beneficial ownership of legal persons, and proliferation-financing sanctions, are the areas most likely to draw adverse findings in the next cycle if left unaddressed.
Conclusion
For a foreign owner, the headline is straightforward: Dominica carries no EU or FATF listing, and the formal triggers for defensive measures and surcharges have lapsed. What remains is the memory effect, a recent listing history that compliance systems still register, so banks may apply closer onboarding than for a jurisdiction with no such record. Clean corporate documentation and clear source-of-funds evidence answer most of that scrutiny. The variable to watch is the citizenship-by-investment programme, since its due-diligence standards are the most plausible route to any future re-listing.
How Expanship Can Help Your Business in Dominica
Expanship helps foreign owners read their listing exposure accurately, prepare the beneficial-ownership and source-of-funds documentation that enhanced due diligence demands, and present a clean compliance file to banks and counterparties. The same team handles the wider work of establishing and running a Dominican entity.
- Company formation and structuring for non-resident owners
- Registered agent and registered office services
- Tax registration and return filing
- Ongoing compliance and statutory maintenance
- Accounting and bookkeeping
- Introductions to banking partners
To discuss your position, contact Expanship Dominica.
Frequently Asked Questions
No. The country was on Annex I from February 2021 but moved to the grey list in October 2021 and was removed from both annexes in February 2024. It was absent from both the February 2025 and October 2025 EU reviews.
No. It appears on neither register, a position confirmed on the FATF country page, and it is not among the 24 jurisdictions on the June 2025 grey list. The FATF blacklist names only North Korea, Iran, and Myanmar.
The trigger was its OECD Global Forum rating. A 2020 EOIR score of Partially Compliant fell below the EU's "at least Largely Compliant" threshold for tax transparency, which placed it on Annex I in February 2021.
It committed to tax good governance in October 2021, then satisfied the EOIR standard through a Global Forum supplementary review published in November 2023. That positive rating produced full removal from the EU lists in February 2024.
It can. The 2021 blacklisting and the grey-list period through 2024 persist in AML risk models, so onboarding for Dominican entities or passport holders may run heavier than for jurisdictions with no listing history. Documented FSU inspection findings also surface in enhanced due-diligence checks.
Yes, if it loses its positive EOIR rating or if CFATF issues an adverse finding. The citizenship-by-investment programme is the chief variable, since weakened applicant due diligence could lead to a CFATF finding that re-triggers EU listing.
Legal Disclaimer
The information provided in this article is for general informational purposes only and does not constitute legal, tax, or professional advice. While we strive to ensure the accuracy and timeliness of the content, laws and regulations are subject to change, and the application of laws can vary widely based on specific facts and circumstances.
Readers should not act upon this information without seeking professional counsel tailored to their individual situation. Expanship and its authors disclaim any liability for actions taken or not taken based on the content of this article.
For specific advice regarding your business setup, compliance requirements, or any legal matters, please consult with qualified legal and tax professionals in the relevant jurisdiction.
