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Vanuatu

Brief summary:

Vanuatu

Medium-High Risk

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Risk Indicators

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

Background

Vanuatu’s history stretches from Austronesian settlement and localized chieftain systems to the unifying influence of Chief Roi Mata and successive European encounters. The New Hebrides later became the unusual UK-France condominium, with separate legal, policing, currency, education, and health arrangements before independence in 1980 under Prime Minister Walter Lini. The brief secession of Espiritu Santo and the legacy of Anglophone–Francophone political divisions continue to provide important context for the country’s fractious coalition politics.

Today, Vanuatu sits amid intensifying strategic competition involving China, Australia, the United States, France, and neighbouring Pacific states, while cyclones, earthquakes, and rising seas place additional pressure on governance and migration. Regional developments include Solomon Islands’ security relationship with Beijing, Papua New Guinea’s defence access arrangements, and political tensions surrounding New Caledonia and Fiji. Vanuatu has also drawn international scrutiny over financial oversight, including FATF grey listing, EU tax measures, and concerns associated with its Golden Passport program.

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AML & Terrorist Financing

Vanuatu has strengthened its AML/CFT framework and was removed from FATF monitoring in 2018, yet the APG evaluation identified continuing exposure to foreign tax crimes, offshore-sector misuse, illicit cross-border flows, and transnational organised crime. Significant vulnerabilities remain around beneficial ownership, offshore companies, remittance and currency exchange businesses, casinos, gaming, and the largely unregulated flags-of-convenience register, while terrorism-financing and proliferation-financing controls were assessed as having low effectiveness. The VFIU, VFSC, Reserve Bank of Vanuatu, and ICCU form the core institutional response, but historic resource, coordination, supervision, investigation, and information-sharing limitations—and scrutiny of investor citizenship schemes—remain important areas for closer attention.

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Sanctions

Vanuatu is expected to implement United Nations Security Council measures, including the restrictions consolidated on the UN’s single list, while no international sanctions are currently in force against the country itself. Its offshore companies, citizenship-by-investment structures, and maritime sector have nevertheless been associated with alleged evasion involving Russian oil, Iranian trade networks, and North Korean cash movements. Recent EU blacklisting has intensified scrutiny of regulatory gaps, ship reflagging, and weak oversight, even as domestic reforms remain gradual.

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Criminality

Vanuatu’s criminal activity is shaped by trafficking routes, illegal logging and fishing, emerging synthetic-drug and cybercrime threats, and the exploitation of its offshore financial structures. Corruption reportedly facilitates localized timber crime, while foreign actors and financial networks take advantage of institutional vulnerabilities, including those exposed by the 2022 ransomware attack on government systems.

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Reports

Vanuatu remains on the Tier 2 Watch List, with a five-year anti-trafficking plan and labor mobility policy offering a framework for progress, but persistent gaps include absent investigations, prosecutions, convictions, victim identification, protection services, awareness campaigns, and systematic training. Vulnerabilities span customary bride-price practices, child swapping, disasters and displacement, commercial sex, fishing and construction, while migrant and ni-Vanuatu workers face risks across agriculture, tourism, logging, domestic service, seasonal employment, and other sectors.

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Industry/Product Sector Risk

Vanuatu’s financial and business landscape combines a significant offshore orientation with cash-heavy domestic activity, creating varied exposure across banking, casinos, remitters, currency exchange, property, and tourism-related services. The VFSC, RBV, and VFIU feature prominently in the regulatory framework, yet uneven supervision, limited beneficial-ownership transparency, informal operators, and cross-border transactions leave important vulnerabilities. Risks linked to foreign tax offences, fraud, corruption, drug trafficking, weapons smuggling, and other transnational activity appear to intersect with international companies, trusts, professional facilitators, transport channels, and emerging mobile-payment services.

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Economy & Investment Climate

Vanuatu’s economy rests on subsistence agriculture, tourism, and services, with copra, kava, fish, and other primary products supporting livelihoods while remittances and a narrow export base add important external links. Recovery is emerging alongside inflation, elevated public debt, disaster exposure, and governance concerns, even as tax-haven features and the citizenship-by-investment program attract capital amid questions about transparency and international relations.

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Cryptocurrency Regulations

Vanuatu permits cryptocurrency activity within an evolving framework, while the Reserve Bank of Vanuatu maintains that the vatu is the country’s sole legal tender and the VASP Act No. 3 of 2025 places exchanges, custodians, and token offerings under licensing oversight. The Vanuatu Financial Services Commission and Financial Intelligence Unit focus on registration, KYC, AML/CFT controls, Travel Rule obligations, and market integrity, alongside a generally favorable direct-tax position and a high-risk assessment concerning unlicensed virtual-asset activity.

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