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Saint Barthélemy

Brief summary:

Saint Barthélemy

Medium-Low Risk

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Risk Indicators

  • FATF/EU Blacklist/Greylist (Lower Concern)
  • Terrorism Financing (Lower Concern)
  • US Dept of State INCSR
  • Proliferation Financing
  • Corruption
  • Criminality
  • Resilience & Governance
  • Financial Transparency
  • Offshore Finance Centres
  • Sanctions

Background

Saint Barthélemy’s history reflects a shifting balance of French and Swedish influence, beginning with its settlement by France in 1648 and its transfer to Sweden in 1784. Gustavia, the free-port capital named for King GUSTAV III, prospered as a trading and supply center while Swedish street names and the three-crown emblem remained part of the island’s identity. France reclaimed the island in 1877, and later political changes led from administration by Guadeloupe to overseas collectivity status in 2007.

A 2003 vote supported separation from Guadeloupe, while Saint Barthélemy’s 2012 relationship with the EU provided local authority over the immigration of foreign workers, including non-French European citizens. The island retained its free-port tradition through successive constitutional arrangements and faced a major modern test when Hurricane Irma caused extensive damage in 2017. Its broader setting is tied to France’s influential role in Europe and globally, including membership in the EU, NATO, and the United Nations Security Council.

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AML & Terrorist Financing

Saint Barthélemy operates within France’s AML/CFT framework, which is not subject to FATF strategic-deficiency listing and benefits from strong national coordination, financial intelligence, confiscation, and terrorist-financing enforcement. Key vulnerabilities include cross-border illicit flows, tax and customs fraud, narcotics, corruption, luxury assets and real estate, while implementation and supervision remain uneven across DNFBPs, particularly real estate, notaries, lawyers, and payment or electronic-money providers. TRACFIN, ACPR, AMF, PNF, and OCRGDF provide specialized oversight and investigative capacity, supported by the beneficial-owner register, although challenges remain around beneficial-owner verification, timely suspicious transaction and sanctions screening obligations, smaller high-risk institutions, and certain nonprofit and proliferation-financing risks.

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Sanctions

As an overseas collectivity of France, Saint Barthélemy falls under France’s implementation of UN and EU restrictive measures, including asset freezes, travel bans, sectoral controls, and arms embargoes affecting Russia, Belarus, Iran, and other connected entities. French authorities such as the Customs Office and financial regulators investigate evasion, conduct raids, freeze assets, and prosecute networks using neighboring transit states, shadow fleets, and third-country intermediaries, with France also participating in the REPO Task Force. No international sanctions are currently in force against Saint Barthélemy.

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Criminality

Saint Barthélemy operates within France’s anti-corruption framework, which includes the Sapin II law, the Agence Française Anticorruption (AFA), and the High Authority for Transparency in Public Life (HATVP), alongside protections for whistleblowers and public disclosures of certain interests and assets. However, persistent concerns include political appointments involving individuals facing corruption cases, limited results in foreign-bribery enforcement, unresolved legal and investigative obstacles, and continuing questions about prosecutorial independence and enforcement resources.

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Reports

As an overseas collectivity of France, Saint Barthélemy falls within a national framework that fully meets international standards on trafficking, while authorities continue confronting exploitation risks affecting domestic and foreign victims across sex trafficking, forced labor, and criminality. France remains at its highest “Emergency Attack” alert level, with Operation Sentinelle, extensive international cooperation, and nine disrupted terrorist plots—including three linked to the Olympic and Paralympic Games—highlighting the broader security environment.

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Economy & Investment Climate

Saint Barthélemy’s high-income economy is centered on international tourism, luxury real estate, and duty-free commerce, with the Territorial Council operating within the stability of French administration and civil law. Strong import dependence and limited freshwater availability—managed through desalination, rainwater collection, and tanker deliveries—contrast with notable trade in jewelry, watches, refined copper, and other luxury goods across European and international markets.

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Cryptocurrency Regulations

Cryptocurrency is permitted in Saint Barthélemy but is not legal tender, with the euro remaining the official currency and oversight largely reflecting France’s PACTE framework through the AMF and ACPR. Exchanges and token projects face expected registration, AML/KYC, reporting, and potential tax obligations involving institutions such as the DGFiP, while developments including MiCA, the Travel Rule, CARF, and France’s optional ICO visa point to an evolving compliance landscape.

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