Key Takeaways
- Listing status is set by separate bodies including the EU, FATF and OECD, each applying its own criteria and reaching different conclusions about Montserrat.
- Foreign owners feel any listing mainly through heavier due diligence, banking friction and reputational perception rather than outright prohibition.
- Montserrat's FATF position differs from the wider UK umbrella, so assumptions based on the UK's standing may not apply to the territory.
- Delisting typically follows action plans and exit commitments that address the specific deficiencies cited when a jurisdiction was first listed.
Montserrat on the Global Watchlists: What Listing Status Means for Foreign Owners
For a foreign owner weighing where to incorporate, the question of whether a jurisdiction sits on a grey or black list often matters more than its headline tax rate. The grey/black list position of Montserrat is straightforward: the territory appears on none of the major international lists, neither the EU list of non-cooperative jurisdictions nor the FATF grey or black lists.
That clean standing is the result of reviews by several distinct bodies, each measuring a different thing. This article explains who maintains the lists that bear on Montserrat, where the jurisdiction stands on each, how it got there, and what open recommendations remain.
The material is most useful to non-resident business owners, investors, and their advisers assessing reputational and compliance exposure before forming or maintaining an entity there.
The Listing Bodies That Matter: EU, FATF, OECD and Others Explained
Several institutions publish lists, and they do not measure the same thing. Confusing one for another is the most common error advisers make when assessing a jurisdiction.
The EU list of non-cooperative tax jurisdictions targets tax governance and unfair tax competition. Its first version was adopted on 5 December 2017 with 17 non-EU countries or territories named.
It carries two annexes. Annex I is the blacklist for jurisdictions that fail the criteria outright; Annex II, often called the greylist, covers those that fall short of all standards but have formally committed to reform.
The Code of Conduct Group for Business Taxation manages the list, with the European Commission monitoring it. Updates land twice a year.
Membership has teeth. From 1 January 2021, each EU Member State committed to applying at least one of four defensive measures against Annex I jurisdictions: denial of cost deductibility, controlled foreign company rules, withholding tax measures, or limits on the dividend participation exemption.
The OECD Global Forum runs a separate exercise. It peer-reviews jurisdictions against the Exchange of Information on Request standard and the Automatic Exchange of Information standard, rating each as Compliant, Largely Compliant, Partially Compliant, or Non-Compliant.
The FATF channel addresses money laundering and terrorist financing rather than tax. It keeps two public lists: a "call for action" list for high-risk jurisdictions and a "jurisdictions under increased monitoring" list, the latter commonly described as the FATF grey list.
Being named on one list does not place a jurisdiction on another. EU tax annexes, the EU anti-money laundering blacklist, and the FATF lists are governed by separate bodies and separate tests.
For Montserrat, the AML evaluations run through the Caribbean Financial Action Task Force, the FATF-style regional body responsible for the Caribbean.
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Montserrat's Current Status on the EU Lists (Annex I Blacklist and Annex II Greylist)
The headline for any foreign owner is that the jurisdiction sits on neither EU annex.
| List | Status | Reference point |
|---|---|---|
| Annex I (blacklist) | Not listed | Revision of 17 February 2026 |
| Annex II (greylist) | Not listed | Update of October 2025 |
After the February 2026 revision, the blacklist contained only ten jurisdictions: American Samoa, Anguilla, Guam, Palau, Panama, Russia, the Turks and Caicos Islands, the US Virgin Islands, Vanuatu, and Vietnam. Montserrat is absent from that group.
The greylist as updated in October 2025 named Antigua and Barbuda, Belize, the British Virgin Islands, Brunei Darussalam, Eswatini, Greenland, Jordan, Montenegro, Morocco, the Seychelles, and Türkiye. Again, the territory does not feature.
Its exit traces to October 2023, when it was confirmed to have met every pending Annex II commitment tied to country-by-country reporting. Complete absence from both annexes is the central finding for owners and their advisers.
Montserrat and the OECD: Forum Reviews, Ratings and Transparency Standards
The territory has belonged to the OECD Global Forum since 2002. Its transparency record is judged through periodic peer review rather than any blacklist.
A new peer review report, Second Round Phase 1, was published on 29 April 2026. Because the practice of Exchange of Information on Request is limited, the review covered only the legal and regulatory framework, which was found overall to be in place.
The practical-implementation stage, Phase 2, is scheduled to begin by 2029. No overall EOIR rating has yet been assigned under the Second Round, since that second phase remains pending.
The 2026 peer review flagged work still to be done. Outstanding items cover the availability of beneficial ownership information, ownership and accounting records for struck-off entities, and limitations on the tax use of exchanged information that do not align with the standard.
On country-by-country reporting under BEPS Action 13, the position is settled. The 2025 peer review confirmed the rules remain effectively applied and continue to meet all terms of reference.
The jurisdiction has notified as non-reciprocal under the CbC framework, meaning it will not receive CbC reports filed with tax authorities elsewhere. Its FATCA and CRS frameworks were implemented under S.R.O. 45 of 2016, and it holds tax information exchange agreements in force with countries including Australia, Ireland, and Iceland.
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The FATF Angle: Where Montserrat Sits and Why It Differs from the UK Umbrella
The jurisdiction appears on neither FATF list. The June 2025 FATF public statement, circulated locally by the Montserrat Financial Services Commission, names it in neither the call-for-action list nor the increased-monitoring list.
A point of confusion deserves clearing up. Although Montserrat is a British Overseas Territory and the United Kingdom is an FATF member in its own right, the territory is evaluated separately through CFATF rather than under the UK's membership.
The Caribbean Financial Action Task Force completed its Fourth Round mutual evaluation of the local AML/CFT regime, with the on-site visit running from 8 to 19 April 2024. Findings were endorsed by the FATF and approved at the CFATF Plenary in Jamaica in December 2024.
As the smallest CFATF member by population and economic size, the territory showed that its risk-based model worked comparatively well despite limited resources. You can read the government statement on the evaluation outcome for the official summary.
The domestic regime rests on the Anti-Money Laundering and Terrorist Financing Regulations and the accompanying Code of 2016, which require relevant businesses to maintain policies, procedures, and enhanced customer due diligence.
Listing and Delisting History: How Montserrat Got On and Off Each List
The record across bodies is short and, on balance, favourable.
- EU Annex I (December 2017 to March 2019): The territory sat in the initial screening group when the EU list was first adopted. It was among 25 jurisdictions cleared and removed by March 2019, a period of roughly fifteen months.
- EU Annex II (post-2019): After clearing Annex I, it moved to the greylist with one outstanding commitment, the introduction of country-by-country reporting. The exact placement date is not confirmed in the primary sources.
- Removal from Annex II (October 2023): At the October 2023 ECOFIN meeting, the jurisdiction was delisted alongside Thailand, Jordan, and Qatar after implementing its CbC regime. It has been clear of both annexes since.
- FATF/CFATF: No record exists of placement on any FATF list. AML compliance has been assessed only through the CFATF mutual evaluation process, most recently in 2024 and 2025.
- OECD Global Forum: A Phase 2 EOIR review took place in 2014; the Second Round Phase 1 report followed in April 2026, with no adverse rating issued.
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Reasons Cited: The Specific Deficiencies and Commitments Behind Any Listing
The single deficiency that held the jurisdiction on Annex II was the absence of a country-by-country reporting regime aligned with BEPS Action 13. That gap was closed by enacting S.R.O. 11 of 2023, supported by Guidance Notes issued in May 2023, which established the CbC framework under the Tax Administration Act.
The 2026 OECD Phase 1 review identified separate, narrower points. These concern the availability of beneficial ownership information and the availability of ownership and accounting records for struck-off entities.
The territory must also remove the limitations it imposes on the tax use of information it exchanges, which sit outside the EOIR standard.
On the AML side, the 2024 CFATF evaluation noted two supervisory weaknesses: insufficient staffing and training at the Financial Services Commission, and the absence of on-site AML/CFT risk-based examinations of any designated non-financial businesses and professions during the review window. The regulator's risk-based approach was described as at an early stage of implementation.
Action Plans and Exit Commitments: What Montserrat Has Pledged to Address
The CbC commitment is complete. Enacting the reporting framework fulfilled the obligation behind the October 2023 EU delisting, and the 2025 OECD peer review confirmed continued conformity with the terms of reference.
The EOIR work remains open. Phase 2 of the review is due to launch by the second quarter of 2029, and before then the jurisdiction must close the beneficial ownership gaps and lift the information-use limitations identified in Phase 1.
A concrete structural step supports this. Under the Companies Act of 2023, all local companies, LLCs, and international business companies previously established were required to re-register, a reform intended in part to improve the availability of ownership data.
On AML follow-up, the territory remains engaged with CFATF, FATF, and the OECD. It completed a Sectoral Risk Assessment covering both financial and DNFBP sectors in January 2024, followed by onsite examinations of money service businesses, real estate dealers, and legal professionals.
No quantified penalty clauses or further timelines for the EOIR recommendations were available beyond the 2029 start date for Phase 2.
Practical Consequences for Foreign Owners: Due Diligence, Banking Friction and Perception
The clean EU position carries direct practical weight. Because the defensive measures, including withholding taxes, CFC rules, denial of cost deductibility, and limits on the participation exemption, attach only to Annex I jurisdictions, none of them apply to an entity incorporated here.
The same logic covers public reporting. The EU Public Country-by-Country Reporting Directive forces jurisdiction-by-jurisdiction disclosure for Annex I and for Annex II for at least two years, but the 2023 delisting means this obligation does not reach Montserrat-linked multinationals.
On the AML front, absence from both FATF lists matters at the banking counter. Financial institutions dealing with locally based entities are not required to apply mandatory FATF-triggered enhanced due diligence on jurisdictional grounds alone.
That said, local rules cut the other way for licensed providers. The territory's own AML regulations require licensees to apply enhanced due diligence where warranted, including toward counterparties in FATF-listed high-risk jurisdictions.
The 2026 Phase 1 review left open recommendations on beneficial ownership and information use. Sophisticated counterparties such as correspondent banks may note these even without a formal listing, making them a due-diligence friction point rather than a legal barrier.
One administrative consequence is unavoidable for existing structures. Foreign-owned IBCs must re-register under the Companies Act of 2023, which may call for updated documentation from owners.
Outlook: Where Montserrat's Listing Status Is Likely to Head
The EU position looks stable. With the CbC commitment fulfilled and confirmed again in the 2025 OECD review, no current EU criterion points toward re-listing.
The OECD track holds the live exposure. Phase 2 does not begin until 2029, but the outstanding beneficial ownership gaps and information-use limits need resolving before then to avoid a poor rating and any downstream EU re-listing risk. Full implementation of the Companies Act 2023 re-registration requirement should help close the ownership gap.
On AML, the jurisdiction is in a follow-up phase after passing its Fourth Round evaluation. CFATF will track progress on DNFBP supervision and regulator staffing, and the risk of a future FATF greylisting is low but not zero if those weaknesses persist.
The recurring theme across both the OECD and CFATF reviews is resource constraint. Limited staffing and capacity in a small jurisdiction are structural pressures that could slow delivery of the Phase 2 commitments, and no listing action by any body was identified as current or imminent.
Conclusion
For a non-resident owner, the practical takeaway is that Montserrat carries no listing penalty: it sits on neither EU annex nor either FATF list, and the OECD has issued no adverse rating. That clean standing removes the defensive-measure and mandatory enhanced-due-diligence triggers that burden listed jurisdictions. The open items are the OECD Phase 1 recommendations on beneficial ownership and information use, due for resolution before the 2029 Phase 2 review. Treat those as monitoring points and factor the Companies Act 2023 re-registration into your administrative planning.
How Expanship Can Help Your Business in Montserrat
Expanship helps foreign owners read their actual exposure to grey and black list dynamics, confirm where an entity stands against EU, FATF, and OECD criteria, and meet the documentation that open recommendations such as beneficial ownership and re-registration now demand. The same team handles the wider operating needs of a foreign-owned firm in the territory.
- Company formation and structuring for non-resident owners
- Registered agent and registered office services
- Tax registration and exchange-of-information filing support
- Ongoing compliance management, including Companies Act 2023 re-registration
- Accounting and bookkeeping
- Introductions to banking partners
To discuss your situation, contact Expanship Montserrat.
Frequently Asked Questions
No. The jurisdiction appears on neither Annex I nor Annex II of the EU list of non-cooperative tax jurisdictions, confirmed by the blacklist revision of 17 February 2026 and the greylist update of October 2025. It has been clear of both annexes since its October 2023 removal from the greylist.
It was delisted at the October 2023 ECOFIN meeting after enacting a country-by-country reporting regime aligned with BEPS Action 13, the sole commitment that had kept it on Annex II. The framework was introduced through S.R.O. 11 of 2023, supported by Guidance Notes issued in May 2023.
No. The June 2025 FATF public statement places it on neither the call-for-action list nor the increased-monitoring list, and there is no record of it ever having been listed. Its AML regime is assessed through the Caribbean Financial Action Task Force rather than directly by the FATF.
No. Although the United Kingdom is an FATF member in its own right, the territory is evaluated separately as its own jurisdiction through CFATF. Its Fourth Round mutual evaluation involved an on-site visit from 8 to 19 April 2024, with findings endorsed at the December 2024 CFATF Plenary.
Not as a regulatory barrier today, since no adverse EOIR rating has been issued and the Phase 2 review does not begin until 2029. The outstanding points on beneficial ownership and information-use limits may, however, be noted by correspondent banks or institutional counterparties as a due-diligence consideration.
Yes, if you hold an existing entity. Local companies, LLCs, and international business companies established before the reform were required to re-register under the Companies Act of 2023, which may require updated ownership documentation from you.
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.
