Is Guernsey on Any Grey or Black List? The Answer

Guernsey's Standing on the World's Grey and Black Lists: A Consolidated SnapshotCopy link to section

For a foreign owner weighing where to base a company, the grey/black list position of Guernsey is a clean one: the jurisdiction sits on none of the principal international blacklists or greylists. It is absent from the EU's Annex I list of non-cooperative jurisdictions, absent from the EU Annex II greylist, and has never been named by the Financial Action Task Force (FATF) on either its grey or black list.

This matters to anyone holding or planning a Guernsey entity, because listing status drives banking access, counterparty due diligence, and the defensive tax measures EU states apply to flows from named territories. The article walks through each regime that could in theory list the jurisdiction, what was assessed, and what the outcome means in practice for a non-resident owner.

It will be most useful to overseas business owners, investors, and the advisers screening Guernsey against competing offshore centres.

How International Listing Regimes Work and Which Bodies Assess GuernseyCopy link to section

Three separate processes can lead to a jurisdiction being named, and they test different things. The EU's list, run by the Code of Conduct Group (Business Taxation) under a Council mandate from November 2016, looks at tax transparency, fair taxation, and anti-BEPS minimum standards. The FATF list, by contrast, concerns anti-money-laundering and counter-terrorism-financing standards, while the OECD's Forum on Harmful Tax Practices reviews preferential regimes and information exchange.

FATF, founded by the G7 in 1989, sets the 40 Recommendations that form the global AML/CFT benchmark. It assesses countries through Mutual Evaluation Reports, peer reviews that grade both the technical compliance of a legal framework and how effectively that framework actually works.

Most jurisdictions are reviewed not by FATF directly but by a regional body. The assessor for Guernsey is MONEYVAL, the Council of Europe's AML/CFT committee, whose most recent on-site visit ran from 15 to 26 April 2024, with the resulting report published on 7 March 2025.

The EU updates its non-cooperative jurisdictions list twice a year, usually in February and October. Its first version, adopted on 5 December 2017, named 17 non-EU countries or territories.

Keeping the three regimes distinct avoids a common confusion. A clean record under one does not guarantee a clean record under another, so a foreign owner should read each on its own terms.

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Guernsey and the EU Annex I Blacklist of Non-Cooperative JurisdictionsCopy link to section

The headline fact is simple: the island has never appeared on Annex I, the EU's blacklist, at any revision since the list began in December 2017. The most recent blacklist, from October 2025, names 11 jurisdictions, including American Samoa, Panama, Russia, and Vanuatu. Guernsey is not among them.

Annex I listing carries real cost. EU member states applying defensive measures may impose higher withholding taxes, deny deductions for payments to listed territories, pull such territories into controlled-foreign-company regimes, or restrict the participation exemption on dividends, and the European Commission separately advises limiting EU funding flows to listed places.

Because Guernsey has never been listed, none of those measures has ever been triggered against a Guernsey structure by reason of an EU blacklisting. For a non-resident owner, that removes a category of risk entirely from the analysis.

Guernsey and the EU Annex II Greylist: Past Inclusions and Commitments MadeCopy link to section

Annex II, the greylist, captures jurisdictions that do not yet meet every international tax standard but have committed to reform. Guernsey did appear here once.

When the EU published its first list on 5 December 2017, the island was placed on Annex II alongside the Cayman Islands, Bermuda, and Jersey. The commitments sought related to the EU's economic substance and fair-taxation criteria, the concern being that a zero-corporate-tax centre should show real activity behind the profits booked there.

The response was legislative. Guernsey enacted the Income Tax (Substance Requirements) (Implementation) Regulations 2018, later consolidated in the 2021 regulations, to align with international substance standards.

Once those commitments were verified, the name was removed. Guernsey does not appear on any published Annex II list from 2020 onward, and the February 2026 Council update confirms it remains off the greylist.

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Guernsey's Position with the FATF Grey and Black ListsCopy link to section

Guernsey sits on neither the FATF grey list ("Jurisdictions under Increased Monitoring") nor the black list ("High-Risk Jurisdictions subject to a Call for Action"), and it has never been on either. The black list is short, naming only North Korea, Iran, and Myanmar. The June 2025 grey list runs to 24 jurisdictions, from Algeria to Yemen, and the island appears on none of them.

The MONEYVAL report behind this status, drawn from the April 2024 on-site visit and published in March 2025, assessed the jurisdiction across 11 Immediate Outcomes. Guernsey received "Highly Effective" ratings on the first five of those outcomes (IO1 to IO5), a result that gives no basis for grey-listing.

Grey-listing typically follows weak effectiveness scores that place a country in a follow-up process with an agreed action plan. The 2024 and 2025 evaluation results do not put Guernsey on that pathway.

OECD Assessments: Economic Substance, Harmful Tax Practices and Forum RatingsCopy link to section

The OECD's Forum on Harmful Tax Practices classifies the island as one of 12 "no or only nominal tax jurisdictions" that hold the domestic legal framework needed to meet the substance standard. The others in that group include Bermuda, the BVI, the Cayman Islands, the Isle of Man, and Jersey.

Two recent monitoring rounds came back clean. The February 2024 review flagged no issues for Guernsey, and the fourth annual exercise completed in December 2024, approved by the Inclusive Framework on 31 January 2025, again raised none.

Since 2021, these jurisdictions have exchanged information under the NTJ standard, reporting on the substance and activity of entities to the places where their parents and beneficial owners reside. On transparency more broadly, the island holds a "Largely Compliant" rating for Exchange of Information on Request under the OECD Global Forum, the same standard that feeds EU listing criteria.

Its exchange network is wide: 17 full double taxation agreements, more than 61 tax information exchange agreements, and membership of the OECD Multilateral Convention on Mutual Administrative Assistance in Tax Matters.

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National and Regional Lists: UK, US and Other Country-Level WatchlistsCopy link to section

As a British Crown Dependency, the island is not on any UK blacklist or sanctions list. An intergovernmental agreement governs automatic exchange of financial account information with the United Kingdom, and Guernsey adopted the Common Reporting Standard from 1 January 2016, with first reporting in 2017.

The United States relationship is settled through formal agreements rather than any watchlist. A FATCA intergovernmental agreement was signed on 13 December 2013, and a US tax information exchange agreement signed in September 2002 was amended by protocol the same day. The IRS does not carry Guernsey on a "non-cooperative" or "tax haven" list.

The island has signed 61 tax information exchange agreements in total, with partners including the UK, the US, Switzerland, and Ireland, and participates in the OECD Multilateral Competent Authority Agreement for CRS exchange.

One caveat applies to individual EU states. Member countries may keep their own national tax blacklists with differing criteria and defensive measures, and although no major EU jurisdiction is known to list Guernsey, an adviser should confirm the position country by country for the specific states in a structure.

Reasons Cited Across Listings and the Action Plans for ExitCopy link to section

The single verified listing event in the island's record was its December 2017 placement on the EU greylist, tied to the fair-taxation criterion. As a zero-corporate-tax centre, it had to demonstrate that entities booking profits locally were carrying on genuine economic activity there.

The fix was the substance regime. The Income Tax (Substance Requirements) Regulations require companies in defined sectors to meet a substance test of adequate employees, premises, and local expenditure proportionate to the activity.

• Banking, insurance, and fund management
• Finance and leasing, headquarters, distribution and service centres
• Intellectual property, shipping, and holding companies

No FATF action plan has ever been imposed, since the jurisdiction has never been grey-listed by FATF. There is no separate published "exit action plan" for the EU greylist period; the substance regulations are the confirmed legislative delivery that satisfied the commitment.

Practical Consequences for Non-Resident Owners: Due Diligence, Banking and PerceptionCopy link to section

Clean listing status removes a layer of friction. Because the jurisdiction is on neither the EU blacklist nor the FATF grey or black list, no enhanced due diligence is triggered against your structure purely by reason of where it is based.

Enhanced due diligence is mandatory under FATF standards for counterparties in grey-listed places, and many banks and investors now weigh EU and OECD listings when pricing risk. Neither channel applies to a Guernsey entity, so banking onboarding and investor confidence are not weighed down by a listing flag.

The defensive measures that follow an Annex I listing, higher withholding tax, denial of deductions, CFC inclusion, and limits on the participation exemption, do not reach Guernsey-connected payments. The reporting that does apply, under FATCA and CRS, is routine global compliance carried out by local banks, funds, and trust companies, not a consequence of any blacklisting.

On perception, the absence from every major list separates the island from centres such as the BVI, which was on the FATF grey list as of June 2025. For a foreign owner comparing options, that contrast is a concrete point of difference.

Track Record and Outlook: Why Guernsey Tends to Stay Off the ListsCopy link to section

A pattern of pre-emptive alignment explains the clean record. The substance regulations landed within the EU's original 2018 deadline, CRS was adopted from the earliest implementation date in January 2016, and both recent OECD monitoring rounds passed without a single flagged issue.

The treaty network reinforces the position. With 61 information-exchange agreements, 17 double taxation treaties, and membership of the OECD Multilateral Convention, the jurisdiction holds one of the broadest exchange frameworks among offshore centres, and official policy is to approach counterparties to negotiate rather than wait to be asked.

The next MONEYVAL cycle is scheduled for 2032, with plenary discussion expected that December, giving roughly a decade of regulatory stability if standards hold. The main watch point is the EU's periodic tightening of substance and BEPS criteria, which could in theory open a fresh Annex II commitment process, though the record of early legislative alignment makes that a low-probability scenario.

ConclusionCopy link to section

Guernsey carries a clean sheet across the regimes that matter to a foreign owner: never on the EU blacklist, never on the FATF lists, and off the EU greylist since it delivered its substance reforms. That standing means no listing-driven enhanced due diligence, no EU defensive tax measures, and a smoother path through banking and investor checks. The practical takeaway is that listing risk is not a reason to avoid a Guernsey structure; the live considerations are ordinary substance, reporting, and treaty obligations rather than any blacklist exposure. Sensible owners will keep their entity compliant with the substance and exchange rules that keep the jurisdiction off the lists in the first place.

How Expanship Can Help Your Business in GuernseyCopy link to section

Expanship advises foreign owners on what the island's listing status means for their structure and helps keep an entity aligned with the substance and exchange-of-information rules that underpin that clean record, and the same team handles the broader work of setting up and running a Guernsey company.

• Company formation and structuring for non-resident owners
• Registered agent and registered office services
• Tax registration and annual filing
• Ongoing compliance and substance management
• Accounting and bookkeeping
• Introductions to banking partners

To discuss your plans, contact Expanship Guernsey.

Frequently Asked QuestionsCopy link to section