This report was prepared by the National AML&CFT Coordinating Committee to support stakeholders ahead of the Asia-Pacific Group (APG/FATF) evaluation team visit scheduled for November 2026.
Foreword
Through an effective AML/CFT system we can improve the reputation of Vanuatu. This occurs through recognising our risks and then developing strategies, policies, and processes in direct response to those recognised risks. This NRA has identified key areas of risk that now requires a response which will strengthen the integrity of our financial system and ensure our financial system is hostile to crime.
The 2024 NRA builds on the 2017 NRA, and the updated sectoral classification from 2018. This NRA informs all stakeholders across Vanuatu’s AML/CFT community of current risk. The NRA identifies the significant criminal behaviours that generate illicit income that threaten Vanuatu’s system, it also assesses and identifies the vulnerabilities within our financial system that criminals are taking advantage of to launder proceeds of crime. This NRA identifies that corruption, misuse of government funds, and transnational money laundering are currently the highest threat to Vanuatu’s AML/CFT system.
For this reason, the banking sector remains highly vulnerable to money laundering along with any sector that offers services and products enabling movement of proceeds out or into Vanuatu, including the remittance sector. The citizenship for investment programs and the associated payments for citizenship to Vanuatu are recognised to be high risk. These programs require the highest levels of control and oversight, as this NRA has identified multiple instances where foreign criminals have taken advantage of these programs to obtain citizenship with associated payment likely made with illicit wealth. These programs have damaged the reputation of Vanuatu, and reviewing, improving and strengthening these programs is acknowledged to be a priority.
Ths NRA also includes Vanuatu’s first assessment of proliferation financing (PF) risk. Proliferation financing activities refer to the raising and moving of funds to finance the development of weapons of mass destruction. It is recognised that preventing the proliferation of these dangerous weapons is a global collective responsibility. Although being a small Pacific nation Vanuatu is not immune to being misused for avoiding sanctions and disguising funds ultimately used to finance these weapons. This NRA identifies that Vanuatu is ‘high-risk’ with regards to PF, it also acknowledges that the citizenship programs are the cause of this risk.
Finally, this NRA relies on a range of sources of information – in particular, information received from reporting entities, government agencies, and the private sector. I take this opportunity to thank those who have provided important contributions. The important information provided now requires us to work together again. We must take collective responsibility to address our countries risk; we must accept and respond to the opportunities identified within this NRA, we must challenge ourselves to strengthen and improve the resilience of our AML/CFT system, to make it harder for criminals to operate.
Table of contents
- Background and context
- Citizenship by Investment Programs (CIPs)
- NRA Key Findings
- Most Threatening Criminal Behaviours
- Lower Threat Criminal Behaviours
- Sectoral Vulnerabilities
- Legal Persons Legal Arrangements
- Terrorism Financing Risk Assessment
- Non Profit Organisation (NPO) Sector
- Proliferation Financing Risk Assessment
