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United States

Brief summary:

United States

Medium-Low Risk

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Risk Indicators

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

Background

The United States emerged from thirteen British colonies in 1776 and was recognized as a nation after the 1783 Treaty of Paris, later expanding to include 37 additional states and overseas possessions. Its history was shaped by the Civil War and the Great Depression, followed by influential roles in both World Wars and the Cold War’s conclusion in 1991. These developments accompanied sustained economic growth, low unemployment, rapid technological progress, and enduring global power.

Today, the United States manages complicated relationships with Mexico and Canada involving border security, migration, transnational crime, trade measures, and sanctions enforcement. Drug cartel violence, fentanyl trafficking, and migration pressures feature prominently in relations with Mexico, while tariff disputes and USMCA compliance remain significant with Canada. Cooperation through mechanisms such as the G7 Enforcement Coordination Mechanism, alongside concerns over third-country sanctions evasion and transshipment networks, adds another layer to North American security and economic policy.

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AML & Terrorist Financing

The United States maintains a sophisticated, multi-agency AML/CFT framework and is not identified by FATF as having strategic deficiencies, with the 2024 follow-up reflecting generally strong but uneven compliance. Significant exposure remains tied to the scale and openness of the dollar-based financial system, while fraud, drug trafficking, cybercrime, human trafficking, corruption, emerging technologies, and complex legal structures continue to generate laundering risks. FinCEN, OFAC, DOJ/MLARS, IRS Criminal Investigation, and geographically focused HIFCA and HIDTA initiatives form important parts of the response, although beneficial ownership access and coverage of certain professional and non-financial sectors remain areas of particular interest.

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Sanctions

The United States administers comprehensive and targeted sanctions through OFAC, supported by IEEPA prosecutions and coordinated actions with the Department of Justice and Commerce Department, focusing on countries including Russia, Iran, North Korea, and Venezuela. Enforcement increasingly emphasizes foreign banks, financial intermediaries, transshipment hubs, dual-use technology, maritime networks, and third-country facilitators operating through corridors such as Türkiye, the UAE, Hong Kong, and Singapore. No international sanctions are currently identified as being in force against the United States, while evolving cryptocurrency, shipping, and technology-based evasion methods continue to shape enforcement priorities.

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Criminality

The United States faces a broad range of criminal activity, from fentanyl-linked drug markets, arms trafficking, and human smuggling along the US–Mexico border to ransomware, fraud, counterfeiting, and illegal wildlife trade. Corruption concerns are less overtly defined but include alleged involvement of officials in border smuggling networks, while tax evasion, money laundering, and financial scams contribute to substantial economic losses.

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Reports

The United States remained compliant with its arms control, nonproliferation, and disarmament commitments, including completing chemical weapons stockpile destruction at facilities in Pueblo and Blue Grass as verified by the OPCW, while navigating treaty-related tensions with Russia. The State Department’s human trafficking assessment keeps the United States at Tier 1, highlighting expanded enforcement and victim-status approvals alongside persistent vulnerabilities nationwide, reduced federal convictions, and shortcomings in survivor services, housing, and screening.

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Industry/Product Sector Risk

The United States presents a complex financial and commercial landscape in which banking, correspondent services, securities, money remittance, casinos, real estate and wealth management feature prominently among areas exposed to illicit finance. Vulnerabilities commonly involve cash-intensive activity, cross-border flows, opaque legal structures, beneficial ownership gaps and the use of professional intermediaries, with risks connected to fraud, drug trafficking, corruption, tax crimes, organized crime and proliferation-related activity. Oversight spans institutions and mechanisms associated with FinCEN, IRS-SBSE, the SEC, FINRA, federal banking agencies, State regulators and FinCEN’s Geographic Targeting Orders, revealing a framework whose coverage and effectiveness vary across sectors.

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Economy & Investment Climate

The United States combines an economy exceeding $29 trillion with a highly diversified, technology-driven industrial base, though services account for the clear majority of output and consumer spending remains a defining force. Strong legal institutions, major financial markets such as the New York Stock Exchange, and extensive trade links support investment and global reach, while regulatory complexity, inequality, and environmental pressures add important nuances.

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Cryptocurrency Regulations

Cryptocurrency is permitted in the United States but operates within a fragmented framework in which FinCEN, the SEC, the CFTC, and the IRS apply different requirements to AML controls, market activity, token classification, and taxation. From FinCEN’s Travel Rule and Form 107 obligations to IRS property treatment, Form 1099-DA, and evolving SEC guidance on offerings and tokenized assets, businesses and taxpayers face extensive compliance responsibilities across federal and state jurisdictions.

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