Is Gibraltar on a Grey or Black List? The Real Answer

Gibraltar on the Global Watchlists: What "Grey" and "Black" Listing Really MeansCopy link to section

The grey and black list question in Gibraltar has a clear answer for a foreign owner: the jurisdiction sits on none of the major international watchlists. It cleared the FATF grey list in February 2024 and was removed from the EU's anti-money-laundering high-risk list with legal effect from 5 August 2025.

"Grey" and "black" are shorthand for two different kinds of international assessment. One concerns money laundering and terrorist financing controls; the other concerns tax transparency and fair taxation.

A grey listing signals that a country has acknowledged weaknesses and committed to fixing them under monitoring. A black listing marks a country judged uncooperative, carrying heavier consequences for cross-border business.

This article explains which bodies maintain these lists, what happened during the past listing episode, where the jurisdiction stands on each list, and what the practical effect is for a non-resident owner. It is most useful to foreign investors, fund managers, and advisers weighing a structure here or already running one.

The Listing Bodies That Matter for Gibraltar: EU, FATF, OECD and OthersCopy link to section

Several distinct institutions run lists that can touch a foreign-owned company, and they do not coordinate their decisions. Confusing one for another is the most common mistake an adviser makes.

The Financial Action Task Force (FATF) maintains two AML/CFT lists. Its grey list, formally the "List of Jurisdictions under Increased Monitoring," covers countries that have committed to resolving identified deficiencies on agreed timeframes; its black list, the "Call for Action" list maintained since 2000, names jurisdictions judged non-cooperative.

The European Union runs lists of its own. Annex I is the EU tax blacklist of non-cooperative jurisdictions, Annex II its tax grey list for countries reforming toward compliance, and a separate AML High-Risk Third-Country List shadows the FATF process but follows its own legislative track.

Two more bodies complete the picture. The OECD Global Forum peer-reviews transparency and information exchange, while MONEYVAL, the Council of Europe's AML/CFT monitoring body, is the regional supervisor with primary responsibility for this jurisdiction.

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Gibraltar's FATF Grey List Episode: Listing, Reasons Cited and Delisting TimelineCopy link to section

On 17 June 2022, FATF placed the jurisdiction under increased monitoring, following review by its International Co-operation Review Group. The decision drew on a MONEYVAL mutual evaluation that had issued 78 recommended actions.

The listing rested on a narrow base. By the time it took effect, all but two of those 78 actions had been completed, and the territory was rated Compliant or Largely Compliant with 39 of the 40 FATF Recommendations.

The agreed Action Plan contained only two items, the fewest of any previously grey-listed jurisdiction. Both concerned enforcement: weak sanctions against AML/CFT breaches outside the banking sector, and too few final confiscation judgments.

Delisting followed a defined path. FATF judged the Action Plan substantially complete in October 2023, ordered an on-site assessment, and at its Paris plenary of 21 to 23 February 2024 removed the jurisdiction from increased monitoring.

A MONEYVAL enhanced follow-up report in May 2024 recorded further progress, upgrading the rating for Recommendation 36 on international instruments from Partially Compliant to Largely Compliant.

Gibraltar and the EU Lists: Annex I Blacklist and Annex II Greylist StatusCopy link to section

On the EU tax lists, the record is straightforward. The territory has never appeared on Annex I or Annex II, meaning the EU Code of Conduct Group never named it deficient on tax transparency or fair taxation. As of October 2025, Annex I held 11 jurisdictions and Annex II a further 11, none of them this one.

The EU AML High-Risk Third-Country List is a different instrument, and this is where the jurisdiction did appear. The European Commission had listed it under the Fourth Anti-Money Laundering Directive, separate from anything on the tax side.

What followed was an unusual divergence. After FATF delisting in February 2024, the Commission proposed AML removal in March 2024, but the European Parliament rejected that proposal on 23 April 2024, citing alleged evidence of Russia-related sanctions evasion.

The deadlock held for more than 18 months. The Parliament approved removal of both this jurisdiction and the UAE on 9 July 2025, and de-listing took legal effect on 5 August 2025.

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OECD Assessments and Gibraltar's Standing on Transparency and Information ExchangeCopy link to section

The OECD Global Forum has reviewed the territory across several rounds: a Phase 1 peer review in 2011, a Phase 2 review in 2014, and a Second Round report covering exchange of information on request published in 2020. It also features in OECD harmful tax practices peer reviews on tax rulings for 2023 and 2024.

The Global Forum assigns four ratings, from Compliant down to Non-Compliant. The current numeric rating from the 2020 report is best confirmed directly on the OECD portal.

One inference is reliable. Because OECD peer review ratings are the primary trigger for EU tax listing, and the jurisdiction does not appear on Annex I or II, no disqualifying EOIR rating was active at screening time. Membership of the Global Forum and participation in the Common Reporting Standard confirm a commitment to automatic exchange of financial account information.

The Specific Deficiencies Cited and the Action Plan Commitments for ExitCopy link to section

The two-point Action Plan defined exactly what had to change. Both items were about enforcement in practice, not gaps in the law itself.

The first deficiency was that regulatory sanctions did not yet meet the "effective, proportionate, and dissuasive" standard in non-bank financial institutions and designated non-financial businesses and professions. Coverage extended to supervisors of trust and company service providers, lawyers, gaming operators, and real estate agents.

The second concerned confiscation. FATF required proof that the jurisdiction was "more actively and successfully pursuing final confiscation judgments," through criminal or civil proceedings, on a scale matching its risk profile.

The original May 2023 deadline was missed, but work continued. FATF confirmed both requirements met by February 2024, and the government began planning its next evaluation, expected roughly three years out.

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Current Status at a Glance: Where Gibraltar Sits on Each List TodayCopy link to section

For a foreign owner running a quick due-diligence check, the answer is the same on every major list: not listed.

FATF acknowledged significant progress across every area it had flagged, and the delisting decision reflects that recognition.

Practical Consequences for Non-Resident Owners: Enhanced Due Diligence and Banking FrictionCopy link to section

A listing matters to a non-resident owner mainly through banking. Financial institutions facing a listed counterparty tend to apply heavier checks, slow onboarding, and in some cases decline relationships outright.

While the AML high-risk listing remained in force, EU-based banks, law firms, and fund managers had to apply enhanced due diligence to any relationship touching this jurisdiction. That meant detailed source-of-funds and source-of-wealth checks, closer review of cross-border transactions, and more frequent reporting of unusual activity.

The timing gap created a real problem. FATF removed the territory in February 2024, but EU obligations to apply enhanced due diligence persisted until August 2025 because the EU AML list lagged behind.

Removal from the EU list ended that obligation. EU counterparties no longer apply the mandatory enhanced measures previously required for relationships involving the jurisdiction, which lowers compliance costs and friction when using a structure here to deal with EU banks and funds.

One nuance is worth keeping in mind. FATF never mandated enhanced due diligence for grey-listed jurisdictions; it only asked members to factor the information into their own risk analysis, so national responses varied even during the listing.

Investor Perception and Reputational Impact of Past ListingsCopy link to section

The grey listing was treated as a serious matter by both the government and the financial services sector, given the potential harm to the territory's standing as a finance centre. The concern was reputational as much as procedural.

The measured effect differed by industry. The local gambling commissioner reported "only a limited detrimental effect" on gaming, which kept growing through the listing period.

The 18-month divergence between FATF and EU status caused the sharper damage. After the Parliament's April 2024 veto, regulated firms faced legal uncertainty over which rules applied, while the government firmly rejected the underlying allegations about Russia-related sanctions evasion as baseless.

With both listings now resolved, commentary points to gains across insurance, fintech, crypto, funds, wealth management, and trust services, supported by UK passporting rights, a European location, a low-tax regime, and a common-law system.

Outlook: Staying Off the Lists and What to Monitor Going ForwardCopy link to section

Staying off the lists depends on sustaining the improvements, not just achieving them once. FATF asked the territory to keep working with MONEYVAL, and the government has set a 2024–27 national AML/CFT strategy built around 11 goals.

The next evaluation window falls at roughly 2027, three years from delisting. Between now and then, several review cycles can affect a foreign-owned entity's position.

An adviser should watch four schedules:

• FATF biannual plenaries each February and June, for any re-listing
• EU AML high-risk list updates, tabled by the Commission and subject to Parliament and Council scrutiny
• EU Annex I and II tax list updates, issued twice yearly, with the next expected in February 2026
• OECD Global Forum peer review timing for any new EOIR or AEOI assessment

The recent history shows why EU and FATF status can diverge. EU listing decisions need the assent of both the Parliament and member states, and a separate Parliament measure requiring the Commission to review jurisdictions with suspended FATF membership by 31 December 2025 signals that geopolitics will keep shaping EU decisions independently of FATF.

ConclusionCopy link to section

For a foreign owner, the position is clean: the jurisdiction carries no grey or black listing on any major FATF, EU, or OECD measure, having cleared the FATF process in February 2024 and the EU AML list in August 2025. That removes the enhanced due diligence that once added cost and delay to banking and counterparty relationships across the EU. The point to manage is forward-looking, since the next FATF evaluation is expected around 2027 and EU list updates run on their own cycle. Build your structure on the assumption that monitoring continues, and check counterparty-facing status against each list separately rather than treating them as one.

How Expanship Can Help Your Business in GibraltarCopy link to section

Expanship helps foreign owners confirm and document a counterparty's current listing status, prepare for the enhanced due diligence questions banks and partners still ask, and structure an entity that meets the transparency and AML expectations behind these reviews. That support sits within a wider set of services for running a foreign-owned company in the jurisdiction.

• Company formation and entity setup
• Registered agent and registered office
• Tax registration and ongoing filings
• Compliance monitoring and statutory upkeep
• Accounting and bookkeeping
• Introductions to banking partners

To discuss your structure or a compliance review, contact Expanship Gibraltar.

Frequently Asked QuestionsCopy link to section