FATF AML Deficient List


Higher Risk

EU Commission’s list of AML/CFT deficient countries

Not on EU White list equivalent jurisdictions

EU Tax Blacklist

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FATF Status

Guam is not on the FATF List of Countries that have been identified as having strategic AML deficiencies


Compliance with FATF Recommendations

Guam falls within the USA jurisdiction with regard to the FATF Mutual Evaluation.  The latest follow-up Mutual Evaluation Report relating to the implementation of anti-money laundering and counter-terrorist financing standards in the USA was undertaken by in 2020. According to that Evaluation, the USA was deemed Compliant for 9 and Largely Compliant for 22 of the FATF 40 Recommendations. It was also deemed Highly Effective for 4 and Substantially Effective for 4 with regard to the 11 areas of Effectiveness of its AML/CFT Regime.


EU Commission’s list of AML/CFT deficient countries


On 13 February 2019, the EU Commission adopted a new list of 23 third countries that had been identified as having strategic deficiencies in their anti-money laundering and counter-terrorist financing frameworks as defined under the Fourth and Fifth Anti-Money Laundering Directives. Guam has been included on this list. This list currently includes all countries currently on the FATF AML deficiency lists together with 11 additional jurisdictions.

It is noted that to date the EU Member States have declined to adopt this list. However, as this country has been identified as having AML deficiencies by the EU Commission, we have rated it accordingly.

EU Tax Blacklist

Guam does not apply any automatic exchange of financial information, has not signed and ratified, including through the jurisdiction they are dependent on, the OECD Multilateral Convention on Mutual Administrative Assistance as amended, does not apply the BEPS minimum standards and did not commit to addressing these issues by 31 December 2018. 

On March 12, 2019, the EU Commission confirmed that Guam had taken no commitments since the first blacklist adopted in 2017 and, therefore, it will remain on the list.



There are no international sanctions currently in force against this country.




Rating                                                                           (100-Good / 0-Bad)

Transparency International Corruption Index                           N/A

World Governance Indicator – Control of Corruption              87



US national defence spending is the main driver of Guam’s economy, followed by tourism and other services. Total federal spending (defence and non-defence) amounted to $1.973 billion in 2014, or 40.4% of GDP. Service exports, mainly spending by foreign tourists while on Guam, amounted to $651 million in 2013, or 13.3% of GDP. In 2013, Guam’s economy grew 0.6%. Despite slow growth, Guam’s economy has been stable over the last decade. National defence spending cushions the island’s economy against fluctuations in tourism. Guam serves as a forward US base for the Western Pacific and is home to thousands of American military personnel. Federal grants amounted to $373.3 million in 2013, or 32.6% of Guam’s total revenues for the fiscal year.


Agriculture - products:

fruits, copra, vegetables; eggs, pork, poultry, beef


national defence, tourism, construction, transhipment services, concrete products, printing and publishing, food processing, textiles

Exports - commodities:

transhipments of refined petroleum products, construction materials, fish, foodstuffs and beverages

Imports - commodities:

petroleum and petroleum products, food, manufactured goods

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World Bank
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