Key Takeaways
- Listing status carries distinct meanings across the EU Annex I and II, FATF and OECD frameworks, so Samoa's position differs by body.
- Specific reasons cited for listing connect to commitments and action plans that shaped Samoa's path toward delisting.
- Foreign owners and advisers can face practical effects on banking, correspondent relationships and investor perception tied to listing status.
- Reviewing Samoa's delisting track record alongside its current status clarifies the outlook for those operating there.
Samoa on the Global Watchlists: What Listing Status Actually Means
The grey and black list status of Samoa has shifted decisively: the EU Council removed it from the list of non-cooperative jurisdictions on 17 February 2026, after more than eight years on Annex I. This matters to any foreign owner, investor, or adviser holding or planning a Samoan entity, because listing status drives banking access, tax treatment in counterparty countries, and reporting obligations abroad.
Three separate frameworks decide how the rest of the world treats a jurisdiction: the EU tax list, the FATF anti-money-laundering process, and the OECD Global Forum's transparency reviews. This article explains where the country stood under each, why it was listed, how it secured removal, and what the change means in practice. It is most relevant to non-resident parties weighing an international finance structure or assessing the residual risk attached to existing Samoan companies.
The EU Lists: Samoa on Annex I (Blacklist) and Annex II (Greylist)
The EU operates two annexes. Annex I is the blacklist of non-cooperative jurisdictions; Annex II is the greylist for places that fall short of the standards but have committed to reform. Samoa went directly onto Annex I when the first list was adopted on 5 December 2017, and it stayed there.
It never appeared on Annex II at any point. There was no intermediate greylist phase and no transfer between the two annexes as a softening step.
The Council updates both annexes twice a year. The 18 February 2025 revision kept the country on Annex I alongside Panama, Vanuatu, Russia, Fiji, and others.
That position changed at the following revision. On 17 February 2026, the Council removed Fiji, Samoa, and Trinidad and Tobago, having determined they comply with all agreed international standards.
| Date | Annex I (blacklist) | Annex II (greylist) |
|---|---|---|
| 5 December 2017 | Listed | Not listed |
| 18 February 2025 | Listed | Not listed |
| 17 February 2026 | Removed | Not listed |
Following the February 2026 revision, ten jurisdictions remain on Annex I, including American Samoa, Anguilla, Guam, Palau, Panama, Russia, Vanuatu, and Vietnam. Samoa is not among them.
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The FATF Position on Samoa: Grey and Black List History
The two FATF lists are distinct from the EU tax list and are read by banks worldwide as risk inputs. The blacklist names "High-Risk Jurisdictions subject to a Call for Action"; the grey list covers "Jurisdictions under Increased Monitoring."
Samoa sits on neither. The FATF blacklist holds only North Korea, Iran, and Myanmar, and the grey list of June 2025 ran from Algeria through to the British Virgin Islands without including the country.
Anti-money-laundering oversight runs through the Asia/Pacific Group on Money Laundering (APG), the FATF-style regional body that conducts the country evaluation. The APG published a Mutual Evaluation Report following an on-site visit of 3 to 14 November 2014, with a follow-up report dated 22 January 2025 tracking progress on technical compliance.
No public record shows the country was ever formally placed on the FATF grey list in its own right. Its AML/CFT track record has been handled through APG enhanced follow-up rather than formal increased-monitoring status.
The OECD and Global Forum Assessments of Samoa
The Global Forum on Transparency and Exchange of Information for Tax Purposes brings together more than 170 jurisdictions and peer-reviews how they implement the standards on Exchange of Information on Request (EOIR) and Automatic Exchange of Information.
There are four possible EOIR ratings. The rating scale runs Compliant, Largely Compliant, Partially Compliant, and Non-Compliant, with the first two treated as satisfactory.
A 2017 Global Forum update rated the country "Largely Compliant" with EOIR standards, the same band as Panama, the UAE, and Vanuatu at that time. By round-2 data, 91 percent of the 132 fully reviewed jurisdictions held a satisfactory overall rating.
This rating is significant for one reason: it shows the EU listing was not driven by transparency failings. The transparency criterion was met; the obstacle lay elsewhere, in the tax regime addressed in the next section.
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Why Samoa Has Been Listed: The Specific Reasons Cited
The EU applies three headline criteria: tax transparency, fair taxation without harmful preferential regimes, and the BEPS anti-avoidance minimum standards. The country cleared the first and third but failed the second.
Council conclusions stated the position plainly: "Samoa has a harmful preferential tax regime (Offshore Business) and has not resolved this issue yet." That wording was carried through successive revisions to at least February 2025.
The "Offshore Business" regime is the offshore company and international business company (IBC) framework. The EU's Code of Conduct Group and the OECD Forum on Harmful Tax Practices (FHTP) assessed it as offering harmful preferential treatment.
Reform was not refused outright. Authorities signalled an intention to move away from preferential treatment toward a territorial tax system, proposing a measured transition to limit disruption.
The country's transparency and anti-BEPS standing met EU requirements. Its continued listing turned almost entirely on one unresolved issue: the harmful Offshore Business regime.
Commitments and Action Plans: Samoa's Path to Delisting
Removal depended on a clean FHTP assessment confirming that the Offshore Business regime had been amended or abolished to the body's satisfaction. Without that, the EU criterion on fair taxation could not be marked as met.
The Samoa International Finance Authority (SIFA) is the designated regulator for the offshore and international finance sector, and it managed both IBC reform and engagement with EU counterparts. SIFA stated that the process involved domestic consultation alongside sustained dialogue with Brussels.
Legislative amendments were introduced in late 2025 to secure delisting. The work concentrated on international business taxation, transparency obligations, and alignment with global tax governance standards.
The precise Act and section numbers of those 2025 amendments are not part of the public record reviewed here. The Samoan government's legislative database or the SIFA portal should be consulted for the exact statutory references.
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The Delisting Track Record: When and How Samoa Came Off Lists
Removal from Annex I took effect on 17 February 2026, when the Council judged the country to comply with all agreed international standards. Samoan authorities described the change as a boost to the territory's international standing and economic credibility.
The total spell on the blacklist ran roughly eight years and two months, from December 2017 to February 2026, one of the longest continuous presences among active jurisdictions. There was no movement onto the greylist on the way out: the entry was struck from both annexes at once.
That path was a single, unbroken listing followed by a clean exit. It avoided the "yo-yo" pattern seen with Palau, which moved from the blacklist to the grey list, then returned to the blacklist after missing its commitment deadline.
On the AML side, no public record confirms the country was ever added to and then removed from the FATF grey list. Monitoring proceeded through APG enhanced follow-up rather than formal FATF placement.
Practical Consequences for Foreign Owners and Advisers
Annex I listing carries real cost for groups with entities in a listed jurisdiction, because the consequences sit in counterparty countries rather than locally. While a place is blacklisted, the following can apply:
- Increased withholding taxes on flows into the listed jurisdiction
- Disallowance of deductions for interest or royalties paid to related parties established there
- Inclusion under controlled foreign company (CFC) regimes in the parent country
- Loss or limitation of the participation exemption on shareholder dividends
- Reporting under DAC 6 Hallmark C.1.b.ii for cross-border deductible payments between associated enterprises
EU Public Country-by-Country Reporting adds a further layer, applying generally to financial years starting on or after 22 June 2024. Data points must be disclosed for each Annex I jurisdiction and for each jurisdiction that has sat on Annex II for at least two years.
From 17 February 2026, these Annex I consequences no longer attach to the country under the EU framework. One caution remains: national blacklists maintained by individual member states can lag the EU list, so advisers should check each relevant member state's domestic list separately rather than assume automatic alignment.
Banking, Correspondent Relationships, and Investor Perception
Blacklisting affects banking long before any tax rule bites. EU-regulated institutions were expected to apply enhanced scrutiny to Samoa-linked transactions under their AML/CFT risk frameworks throughout the listing period, even though the country never appeared on the FATF grey list.
FATF holds no enforcement powers of its own. The practical pressure comes from the compliance programs of banks and payment processors, which treat these lists as mandatory inputs to risk assessment, with non-compliance exposing institutions to penalties, lost correspondent banking, and reputational harm.
Pacific island economies feel this acutely. Listing can raise the cost of doing business, complicate cross-border transactions, and affect access to development finance for economies reliant on remittances, tourism, and external trade.
Delisting works in the other direction. Economists note that removal lowers reputational risk and may improve access to correspondent banking, though no public figure quantifies the relationships lost during the listed years; SIFA or the Central Bank of Samoa would be the source for that data.
Current Status and Outlook for Samoa
The position is clean across all three frameworks. The country is off the EU Annex I blacklist, was not moved to the Annex II greylist, and sits on neither the FATF blacklist nor the FATF grey list as of the February 2026 plenary data reviewed.
The next EU revision is scheduled for October 2026. The country enters that cycle from a delisted starting point and will be monitored to confirm it sustains compliance.
The main forward risk is durability. If the reforms to the Offshore Business regime were to regress, re-listing at a future review becomes possible, and Pacific island states remain exposed to the unilateral nature of EU assessment.
Anyone structuring a Samoan entity for 2026 and beyond should obtain written confirmation from SIFA and local counsel that the specific regime their structure relies on is not the one previously flagged as harmful. Watching the outcome of the October 2026 review is a sensible part of that diligence.
Conclusion
A foreign owner can now treat the country as a delisted jurisdiction: the EU consequences that once attached to Annex I status fell away on 17 February 2026, and there is no FATF or greylist overhang. The practical caveats are narrow but real, namely that individual EU member states may run national lists that lag the EU position, and that delisting rests on reforms that must hold. Verify the status of any specific regime your structure depends upon, and confirm the outcome of the next scheduled review before relying on the clean position long term.
How Expanship Can Help Your Business in Samoa
Expanship supports foreign owners in confirming how the delisting affects an existing or planned structure, checking the relevant regime against the reforms that secured removal, and coordinating the SIFA and counsel confirmations that prudent diligence calls for. That work sits within a fuller set of services for non-resident entities operating in the jurisdiction.
- Company formation and entity structuring for non-resident owners
- Registered agent and registered office services
- Tax registration and preparation of statutory filings
- Ongoing compliance monitoring against EU and FATF list developments
- Accounting and bookkeeping for international entities
- Introductions to banking and correspondent banking partners
To review your structure against the current status, contact Expanship Samoa.
Frequently Asked Questions
No. The EU Council removed it from the list of non-cooperative jurisdictions on 17 February 2026, having found that it complies with all agreed international standards. It was on Annex I continuously from December 2017 until that date.
No. It was placed directly onto Annex I in December 2017 and stayed there until delisting, with no period on Annex II. It was removed from both annexes at once rather than moved to the greylist.
It is on neither. The FATF blacklist holds only North Korea, Iran, and Myanmar, and the country does not appear on the grey list of jurisdictions under increased monitoring. Its AML/CFT progress has been handled through the Asia/Pacific Group on Money Laundering follow-up process.
The reason cited consistently was a harmful preferential tax regime, the Offshore Business or IBC framework, which the EU and the OECD's Forum on Harmful Tax Practices assessed as harmful. Its tax transparency rating was satisfactory, so the listing turned on this fair-taxation criterion rather than on information exchange.
The Annex I defensive measures, such as non-deductibility of related-party interest or royalties and certain CFC and reporting consequences, no longer apply under the EU framework from 17 February 2026. Individual EU member states' national lists can lag the EU list, so each relevant member state's domestic position should be checked separately.
Yes, if the legislative reforms underpinning removal were to regress. The next EU revision is scheduled for October 2026, and Pacific island states remain exposed to the unilateral nature of EU assessment, so sustained compliance is the key factor.
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.
