--- title: "Iceland (IS) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/iceland/ source_html: /jurisdictions/iceland/index.html description: "Financial integrity intelligence for Iceland (IS): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: 074ba8d14f628b8ae9e4976d9094e491184b848b3320593fcd728734fe75c6cb generator: "fe-fleet/md-twin@1.0" --- # Iceland (IS) — Financial-Integrity Intelligence · Sentinel Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved. Financial Integrity Monitor # Iceland IS Domains covered 8 of 8 Sources 162 Role actions 8 Horizon <90d 0 Jurisdiction profile FATF status: Largely Compliant Tier: B Risk direction: Stable Enablement vs enforcement: Mixed Iceland is a full FATF member (not MONEYVAL-assessed) with a modern AML Act, a dedicated Sanctions Act No. More 64/2019, and a Beneficial Ownership Act No. 82/2019. AML/CFT supervision sits with the Central Bank of Iceland's Financial Supervisory Authority (FSA) and the Directorate of Internal Revenue for DNFBPs. As an EEA/EFTA state (not an EU member), Iceland incorporates EU AML directives into the EEA Agreement with a structural lag rather than being directly bound by EU regulations. Key deficiencies - Chronically low AML conviction numbers and available penalties relative to legal framework strength - Limited FSA supervisory guidance and feedback to registered virtual asset service providers - Structural EEA/EFTA incorporation lag delaying application of the new EU AML Package (AMLR/AMLA/6AMLD) and MiCA relative to EU member states - Historical beneficial-ownership opacity exploited by senior officials via offshore structures (Panama Papers/Wintris Inc.) Recent developments (18m) - Continued autonomous alignment with successive EU Council sanctions decisions on Russia (Dec 2025, Jan 2026 statements) under Iceland's Sanctions Act framework - Iceland remains off the FATF grey and black lists as of the June 2026 plenary statement, having been delisted in October 2020 - Continued rapid growth of Iceland's renewable-energy-powered Bitcoin mining sector, sustaining exposure to crypto-asset integrity questions - EFTA Surveillance Authority's July 2025 Internal Market Scoreboard shows Iceland's EEA transposition deficit narrowing to 1.4%, though legislative backlog persists Law made at European Economic Area level that applies in Iceland is covered once, on the [European Economic Area](/jurisdictions/eea/) page. This page covers Iceland’s own layer: implementation, national authorities, national options and local enforcement. Brief ## Lead signal #### Lead Signal Iceland sits among a bloc of twelve states that co-signed an 8 September 2026 joint foreign ministers statement restricting trade in goods originating from Israeli West Bank settlements, yet as of reporting dated 24 September 2026 Iceland had not enacted a corresponding national measure. Six of the twelve signatories, Iceland included alongside Denmark, Finland, Poland, Portugal and Sweden, remained in that same pre-implementation posture, while Spain, Ireland and the Netherlands had already moved domestic measures into force. The gap between political signature and legal effect is itself the finding: a joint statement creates no enforceable screening obligation for banks or trade-finance desks operating out of Reykjavik until a national instrument gives it force, and none has yet been identified. Read full brief #### Lead Signal Iceland sits among a bloc of twelve states that co-signed an 8 September 2026 joint foreign ministers statement restricting trade in goods originating from Israeli West Bank settlements, yet as of reporting dated 24 September 2026 Iceland had not enacted a corresponding national measure. Six of the twelve signatories, Iceland included alongside Denmark, Finland, Poland, Portugal and Sweden, remained in that same pre-implementation posture, while Spain, Ireland and the Netherlands had already moved domestic measures into force. The gap between political signature and legal effect is itself the finding: a joint statement creates no enforceable screening obligation for banks or trade-finance desks operating out of Reykjavik until a national instrument gives it force, and none has yet been identified. This is a sanctions-architecture story rather than an enforcement story. Where a state signs a multilateral political commitment and the implementing instrument lags, correspondent banks and trade-finance counterparties relying on Icelandic institutions face a window in which screening lists and internal policy may not yet reflect the stated political position. The asymmetry among signatories is itself a data point for institutions mapping jurisdiction-by-jurisdiction sanctions exposure across aligned-but-uneven blocs. #### Other Developments FATF standing confirmed stable. Iceland remains off the FATF list of jurisdictions with strategic AML/CFT deficiencies, a status that has held since its 2018 mutual evaluation and subsequent follow-up cycle. FATF's own assessment calendar names Iceland for a 5th-round mutual evaluation, with a possible on-site period from June 2026 and possible plenary discussion in February 2027. This is a scheduling development, not a finding of new deficiency, but it marks the point at which Iceland's post-2018 AML/CFT architecture will next be tested against the current FATF methodology. MiCA/EEA incorporation status disputed for Iceland. Secondary commentary is divided on whether Iceland has completed EEA Joint Committee incorporation of the Markets in Crypto-Assets Regulation. No Icelandic primary instrument was located this cycle to resolve the conflict between a reading that treats incorporation as complete and one that treats it as still pending. This is a genuine unresolved legal-status question rather than a settled fact awaiting restatement, and it bears directly on which crypto-asset service providers operating in or from Iceland are presently subject to MiCA-equivalent obligations. Beneficial-ownership baseline unchanged. Iceland's beneficial-ownership registration obligation continues to run through the Tax Administration under AML legislation implemented from 2019. No new development was sourced this cycle; the regime is carried forward as stable background against which any future transparency change would register. #### Cross-Monitor Connections The MiCA/EEA incorporation ambiguity is a direct intersection point with the crypto and world-payments monitors, both of which separately encounter the same unresolved classification question for Icelandic-licensed digital-asset activity. Where a crypto-asset service provider's licensing status is contingent on an EEA incorporation question that cannot presently be resolved from available sources, the AML/CFT obligations that would attach to that provider under an in-force MiCA regime are equally unresolved. The settlement-trade sanctions signature also carries a correspondent-banking dimension relevant to world-payments' settlement-access tracking, insofar as correspondent banks assessing Icelandic counterparty risk will weigh the political commitment against the absence of a domestic implementing instrument. #### Outlook Two threads carry forward. Whether Iceland moves from signatory to enactor on the settlement-trade restriction is likely to surface in reporting before the next FATF-calendar milestone; until a national measure is identified, the correct characterisation remains signed-but-not-implemented rather than in force. Separately, Iceland's 5th-round FATF mutual evaluation, with a possible on-site period from June 2026 and a possible plenary discussion in February 2027, as scheduled, is the next point at which its AML/CFT framework faces formal reassessment; the prior evaluation rated Iceland compliant or largely compliant on the substantial majority of FATF recommendations, so the evaluation is a confirmation exercise rather than a presumption of deficiency. Earlier periodic briefs (1) 25 Oct 2026 · fim-2026-10-25 #### Lead Signal Iceland sits among a bloc of twelve states that co-signed an 8 September 2026 joint foreign ministers statement restricting trade in goods originating from Israeli West Bank settlements, yet as of reporting dated 24 September 2026 Iceland had not enacted a corresponding national measure. Six of the twelve signatories, Iceland included alongside Denmark, Finland, Poland, Portugal and Sweden, remained in that same pre-implementation posture, while Spain, Ireland and the Netherlands had already moved domestic measures into force. The gap between political signature and legal effect is itself the finding: a joint statement creates no enforceable screening obligation for banks or trade-finance desks operating out of Reykjavik until a national instrument gives it force, and none has yet been identified. This is a sanctions-architecture story rather than an enforcement story. Where a state signs a multilateral political commitment and the implementing instrument lags, correspondent banks and trade-finance counterparties relying on Icelandic institutions face a window in which screening lists and internal policy may not yet reflect the stated political position. The asymmetry among signatories is itself a data point for institutions mapping jurisdiction-by-jurisdiction sanctions exposure across aligned-but-uneven blocs. #### Other Developments FATF standing confirmed stable. Iceland remains off the FATF list of jurisdictions with strategic AML/CFT deficiencies, a status that has held since its 2018 mutual evaluation and subsequent follow-up cycle. FATF's own assessment calendar names Iceland for a 5th-round mutual evaluation, with a possible on-site period from June 2026 and possible plenary discussion in February 2027. This is a scheduling development, not a finding of new deficiency, but it marks the point at which Iceland's post-2018 AML/CFT architecture will next be tested against the current FATF methodology. MiCA/EEA incorporation status disputed for Iceland. Secondary commentary is divided on whether Iceland has completed EEA Joint Committee incorporation of the Markets in Crypto-Assets Regulation. No Icelandic primary instrument was located to resolve the conflict between a reading that treats incorporation as complete and one that treats it as still pending. This is a genuine unresolved legal-status question rather than a settled fact awaiting restatement, and it bears directly on which crypto-asset service providers operating in or from Iceland are presently subject to MiCA-equivalent obligations. Beneficial-ownership baseline unchanged. Iceland's beneficial-ownership registration obligation continues to run through the Tax Administration under AML legislation implemented from 2019. No new development was sourced; the regime is carried forward as stable background against which any future transparency change would register. #### Cross-Monitor Connections The MiCA/EEA incorporation ambiguity is a direct intersection point with the crypto and world-payments monitors, both of which separately encounter the same unresolved classification question for Icelandic-licensed digital-asset activity. Where a crypto-asset service provider's licensing status is contingent on an EEA incorporation question that cannot presently be resolved from available sources, the AML/CFT obligations that would attach to that provider under an in-force MiCA regime are equally unresolved. The settlement-trade sanctions signature also carries a correspondent-banking dimension relevant to world-payments' settlement-access tracking, insofar as correspondent banks assessing Icelandic counterparty risk will weigh the political commitment against the absence of a domestic implementing instrument. #### Outlook Two threads carry forward. Whether Iceland moves from signatory to enactor on the settlement-trade restriction is likely to surface in reporting before the next FATF-calendar milestone; until a national measure is identified, the correct characterisation remains signed-but-not-implemented rather than in force. Separately, Iceland's 5th-round FATF mutual evaluation, with a possible on-site period from June 2026 and a possible plenary discussion in February 2027, as scheduled, is the next point at which its AML/CFT framework faces formal reassessment; the prior evaluation rated Iceland compliant or largely compliant on the substantial majority of FATF recommendations, so the evaluation is a confirmation exercise rather than a presumption of deficiency. Domain intelligence (D1–D8) #### Sanctions Iceland is a signatory to the 8 September 2026 joint foreign ministers statement among twelve states restricting trade in goods from Israeli West Bank settlements. As of reporting dated 24 September 2026, Iceland had not brought a national implementing measure into force, placing it alongside Denmark, Finland, Poland, Portugal and Sweden in a group of six signatories yet to legislate, while Spain, Ireland and the Netherlands had already done so. The architectural point is that a joint political statement does not itself create a binding trade restriction enforceable by Icelandic authorities or screenable by financial institutions as a sanctions obligation; it signals intent that has not yet crystallised into domestic law. Continue reading For institutions with Icelandic counterparty exposure, particularly in correspondent banking and trade finance, this divergence between stated political alignment and enacted legal obligation is itself a risk-relevant fact. A counterparty's sanctions-screening posture calibrated only to currently-enacted restrictions will not yet capture the settlement-trade position Iceland has publicly endorsed, and institutions relying on jurisdiction-level alignment signals rather than enacted-instrument checks could misjudge Iceland's current legal exposure in either direction. The six-of-twelve split among signatories also illustrates a broader pattern of enforcement-posture divergence within otherwise aligned sanctions blocs: political consensus at the statement level does not translate uniformly or promptly into domestic legal effect, and the lag varies significantly by jurisdiction for reasons not established in available sourcing. No Icelandic foreign-ministry instrument was located this cycle confirming whether a national measure has since entered into force, and no enforcement action tied to the settlement-trade position has been identified for Iceland. The absence of enforcement here is not itself anomalous given the absence of an enacted domestic obligation to enforce; it would become analytically significant only if a national measure were later found to have been enacted without accompanying implementation. #### Outlook The near-term question is whether Iceland moves from signatory to enactor, and on what timeline relative to the other five currently non-implementing signatories. Until a national instrument is identified, the correct characterisation for compliance purposes remains that Iceland has stated political intent without an enacted trade restriction. Institutions tracking this corridor should treat the present position as provisional rather than as either a confirmed restriction or a confirmed absence of one, pending a primary Icelandic source. Judgment: Iceland signed the 8 September 2026 joint statement with Canada and ten European states on restricting trade in goods from Israeli settlements; this predates the window and was not found to have moved further. Probable Iceland is EEA/EFTA, not EU; AMLR/AMLAReg/6AMLD incorporation into the EEA Agreement remains pending via the EEA Joint Committee (improving trajectory, transposition deficit narrowed 2.1%->1.4% per EFTA Surveillance Authority, July 2025). Judgment: Iceland's beneficial-ownership registration regime, in force since summer 2019, shows no amendment this cycle. Uncertain Samherji/Fishrot professional-enablement architecture (Iceland/Norway/Cyprus/Marshall Islands) remains evolving; no Icelandic domestic conviction of implicated executives identified despite active Namibian prosecutions; chronically low AML conviction numbers persist (stable trajectory, persistent structural gap). Judgment: No enabler-jurisdiction signal for Iceland found this cycle. Uncertain Judgment: No conflict-finance signal for Iceland found this cycle. Uncertain #### Crypto / Digital Assets / Financial Innovation The status of the Markets in Crypto-Assets Regulation in Iceland remains genuinely disputed across available secondary sources, and no Icelandic primary instrument has been located this cycle to settle the question. One reading holds that Iceland completed the constitutional steps required for EEA Joint Committee incorporation of MiCA by a mid-2025 date, with a transitional window running to 1 July 2026. A competing reading holds that Iceland remains outside MiCA pending completion of incorporation. Both readings rest on secondary commentary rather than an Icelandic gazette text, Alþingi act, or Central Bank notice, and the conflict has not been resolved this cycle. Continue reading This is not a stable-background fact being restated; it is an active legal-status gap with direct consequences for which obligations currently attach to crypto-asset service providers operating in or from Iceland. If MiCA is in force in Iceland, authorisation, prudential and conduct obligations under the Regulation would apply directly; if it is not yet incorporated, Icelandic VASPs would instead remain under whatever pre-MiCA national framework predates incorporation, with materially different compliance and passporting consequences. Financial institutions and crypto-asset counterparties assessing Icelandic exposure should treat the applicable regime as unresolved rather than assume either reading is authoritative. The dispute also bears on AML/CFT compliance mapping specifically: MiCA's authorisation regime carries its own AML-relevant conduct and governance obligations for crypto-asset service providers, distinct from Iceland's existing VASP registration arrangements under the Tax Administration framework referenced in the beneficial-ownership context. Until the incorporation question is resolved, institutions relying on VASP counterparties domiciled in Iceland cannot reliably determine whether MiCA-level AML-adjacent governance requirements currently apply, or whether a narrower pre-MiCA national standard remains the operative baseline. #### Outlook Resolution likely depends on an Icelandic or EEA Joint Committee primary publication rather than further secondary commentary, which has already produced conflicting accounts. Until such a source is located, the Disputed confidence tier on this question should be read as a genuine sourcing gap rather than as a preliminary finding leaning toward either incorporation-complete or incorporation-pending. Judgment: Iceland's MiCA transposition and the Central Bank's June 2026 CASP authorisation of Myntkaup are licensing facts tracked by the crypto monitor; no AML-specific crypto-integrity finding for Iceland located this cycle. Uncertain FSA supervisory-guidance and feedback deficit to registered VASPs remains unresolved since the 2020 FATF follow-up (watch status, no material tech-adoption development this cycle). Judgment: No RegTech/compliance-technology development specific to Iceland found this cycle. Uncertain #### AML/CTF Regime The standing AML/CTF posture of Iceland was reconfirmed rather than changed this cycle, but the reconfirmation itself carries analytical weight. Iceland was removed from the FATF list of jurisdictions under increased monitoring following its 2018 Mutual Evaluation and the 2019-2021 follow-up reporting cycle, and this Tier-1 FATF source confirms that Iceland remains off that list, with no new plenary action recorded this cycle. This is the highest-confidence finding in the AML/CTF material this cycle, sourced directly to FATF rather than to secondary commentary, and it establishes a stable baseline against which the remaining developments in this domain should be read. Continue reading The more structurally interesting development concerns the relationship of Iceland to the AML Package of the EU: the AML Regulation (AMLR), the sixth Anti-Money Laundering Directive (6AMLD), and the AMLA Regulation establishing the Anti-Money Laundering Authority. As an EEA state rather than an EU member, Iceland does not sit on the same implementation clock as EU member states for this package. The AMLR is scheduled to apply directly from 10 July 2027, and the 6AMLD transposition deadline for EU member states falls on 10 July 2026, but incorporation of both instruments by Iceland proceeds via EEA Joint Committee decision on a lag rather than automatic application. This is a standing structural feature of the EEA relationship of Iceland with the AML architecture of the EU, not a new development in itself, but it is worth stating plainly: the beneficial-ownership and AML supervisory framework of Iceland, built around Act No. 82/2019, already predates the AML Package of the EU, and the actual timetable for the transposition of the newer package by Iceland has not been established this cycle. That is a genuine gap in the evidence base this cycle, not a finding that transposition is delayed or at risk, simply that the schedule is not yet visible. Read together, the FATF and EU-AML-Package findings describe a jurisdiction whose baseline AML/CTF credibility is not in question, Iceland is not grey-listed and has no open FATF follow-up action, but whose formal alignment with the next-generation AML architecture of the EU will lag EU member states by an amount that is not yet quantifiable. This is the kind of enablement-relevant structural fact that matters more for architecture-over-incident analysis than any single enforcement action would: a jurisdiction can have strong underlying AML/CTF fundamentals, as the FATF status of Iceland suggests, while still operating for a period under an older EU-adjacent legal instrument than its EU neighbours, simply as a function of EEA incorporation timing rather than substantive non-compliance. This matters for firms with Icelandic exposure because supervisory expectations built around the AMLR and 6AMLD may diverge from the current Act 82/2019-based regime of Iceland for a transitional window whose length is not yet fixed; cross-border correspondent relationships and payment corridors touching Iceland should treat the EEA incorporation lag as a live variable rather than a settled timetable. #### Outlook Two horizon markers are relevant here. The transposition process for 6AMLD via EEA Joint Committee incorporation is expected, per Iceland-specific projection, in the second half of 2026, albeit with meaningful uncertainty around that timing. The application date for AMLR and 6AMLD at the EU level falls in the third quarter of 2027, with a similar uncertainty band. Neither marker resolves how quickly Iceland itself will move once the EU-level instruments are in force; incorporation of AML directives by Iceland has historically proceeded via Joint Committee decision, and no date more specific than these horizon estimates is available this cycle. The beneficial-ownership register rules of Iceland may be updated once 6AMLD is incorporated, given the more granular central-register requirements of that Directive, but this is a forward-looking illustration rather than a confirmed development. This is illustrative orientation, not a prediction of legislative timing. Judgment: Iceland's AML/CFT standing remains anchored to its February 2018 FATF Mutual Evaluation Report; it exited increased monitoring in October 2020. As an EEA (not EU) state, AMLR/6AMLD/AMLA require EEA Joint Committee incorporation, not yet confirmed for Iceland. Probable Judgment: No commercial activity in the integrity-infrastructure market specific to Iceland found this cycle. Uncertain Regulatory horizon Proposed 2027 · ±year ### Iceland's next FATF national risk assessment refresh Pending third NRA would update risk assumptions underlying AML Act 140/2018 supervisory prioritisation. [National Commissioner of the Icelandic Police (NCIP/FIU) Source](https://www.fatf-gafi.org/content/dam/fatf-gafi/fur/Follow-Up-Report-Iceland-2020.pdf.coredownload.pdf) Proposed 2027-Q1 · ±half_year ### Iceland 5th Round FATF Mutual Evaluation A new mutual evaluation report would reset Iceland's compliance and effectiveness ratings and could trigger a new enhanced follow-up cycle if deficiencies are found. [Source](https://www.fatf-gafi.org/en/calendars/assessments.html) 2 dated · 3 pending date · baseline financial-integrity-2026-07-05 Role action cards MLRO ### Iceland signed a settlement-trade sanctions statement but has not enacted a national measure as of late September 2026. Screening policies calibrated only to enacted restrictions will not capture Iceland's stated political position; institutions should not infer an enforceable sanctions obligation currently exists. 2 evidence refs Compliance ### MiCA applicability to Iceland is disputed across sources with no primary resolution. Compliance mapping for Icelandic VASP counterparties cannot presently determine whether MiCA-level obligations or a pre-MiCA national standard is the operative regime. 1 evidence refs Legal ### No enacted Icelandic trade restriction has been identified despite the September 2026 joint statement. Legal exposure assessments should distinguish the political commitment from an enforceable domestic obligation, which has not been confirmed. 1 evidence refs Board ### Iceland's AML/CFT standing remains off the FATF deficiency list ahead of its 5th-round evaluation. The institution's Icelandic counterparty risk remains at a stable baseline, with the next formal reassessment scheduled for 2026-2027. 1 evidence refs CTO ### Icelandic MiCA incorporation status cannot presently be confirmed from available sources. Platform or integration decisions resting on Icelandic VASP licensing status should treat the regulatory basis as unresolved rather than settled. 1 evidence refs Risk ### Enforcement-posture divergence persists among settlement-trade-ban signatories, Iceland among the non-implementing group. Jurisdiction-level sanctions-exposure models should treat signature and implementation as distinct risk markers rather than a single composite signal. 1 evidence refs Audit ### Beneficial-ownership registration arrangements for Iceland remain unchanged and undocumented beyond the 2019 baseline. No new audit-trail evidence was sourced this cycle regarding Iceland's BO register; the standing 2019 framework remains the reference point. 1 evidence refs Scenario sketches ### AMLA direct-supervision transition and cross-border obliged entities Illustrative orientation only: as the AMLA Regulation (Reg (EU) 2024/1620) moves toward operational direct and indirect supervision of selected cross-border obliged entities, alongside the directly-applicable AML Regulation (Reg (EU) 2024/1624) and per-state 6AMLD transposition, the supervisory perimeter for entities with cross-border EEA exposure could shift from purely national authorities toward a hybrid EU-level structure. For an EEA-adjacent jurisdiction such as Iceland, which sits outside the EU AML Package's direct institutional perimeter, this could illustrate a structural divergence between EU-supervised cross-border entities and EEA-national-supervised equivalents, a gap that evasion typologies could in principle seek to exploit. This is architecture-over-incident illustration, not an observed development for Iceland this cycle. Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact. Standing trackers (T1–T6) Tracker Status Note T1 · Russian Sanctions-Evasion Architecture no_change No Iceland-specific dark-fleet, tech-procurement or commodity-rerouting signal found this cycle. T2 · EU AML Package / AMLA no_change Iceland is EEA, not EU; AMLR/6AMLD/AMLA require EEA Joint Committee incorporation, not yet confirmed for Iceland. T3 · FATF Grey List no_change Iceland is not currently on the FATF grey list; exited increased monitoring October 2020. T4 · Beneficial-Ownership Register Status no_change Iceland's beneficial-ownership registration regime, in force since summer 2019, shows no amendment this cycle. T5 · Crypto & Digital-Asset Integrity no_change No AML-specific crypto integrity finding for Iceland located this cycle; MiCA licensing facts tracked separately by crypto monitor. T6 · Sanctions Regime Divergence no_change Iceland joined an 11-country-plus-Canada joint statement of 8 September 2026 restricting trade in goods from Israeli settlements; predates this window. Registers ### Enforcement actions - 7 Jan 2026 - 4 Sep 2025 - 8 Jan 2026 - Iceland formally aligned itself with EU Council Decision (CFSP) 2025/2572 of 15 December 2025, which added 12 natural persons and two entities to the EU's Russia destabilising-activities sanctions list, committing to conform its national asset-freeze and travel-ban measures accordingly. 7 Jan 2026 - Iceland aligned with EU Council Decision (CFSP) 2025/1425 of 15 July 2025, adding five individuals to the EU's Russia human-rights sanctions framework, incorporating the listing into Icelandic domestic enforcement. 4 Sep 2025 - Iceland aligned with EU Council Decision (CFSP) 2025/2594 of 15 December 2025 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, adding 5 persons and 4 entities to the relevant list. 8 Jan 2026 ### Sanctions changes - 4 Sep 2025 - 23 Oct 2025 - 26 May 2026 - 2 Apr 2026 - 15 Jun 2026 - 6 Jan 2026 - 2 Apr 2026 - 15 Jun 2026 - 8 Sep 2026 - EU Council Decision (CFSP) 2025/1070 of 26 May 2025 prolonged Russia restrictive measures for a further year, until 28 May 2026; Iceland aligned itself with the extension under its own Sanctions Act framework. 4 Sep 2025 - The EU's 19th sanctions package (October 2025) enacted a transaction ban on the Russian ruble-backed stablecoin A7A5 and related crypto-provider entities; as an EEA/EFTA state Iceland's autonomous sanctions regime tracks EU listings of this kind rather than acting unilaterally. 23 Oct 2025 - On 26 May 2026 the UK designated Huobi Global S.A. under the Russia (Sanctions) (EU Exit) Regulations 2019. Because Iceland's autonomous sanctions regime tracks EU Council decisions rather than UK OFSI designations, this UK-only listing is not automatically mirrored in Icelandic domestic sanctions law. 26 May 2026 ### Regulatory horizon (register) - AMLD6 beneficial-ownership register provisions and AMLA technical standards - 6AMLD transposition via EEA Joint Committee incorporation - AMLR / 6AMLD application date - AMLD6 beneficial-ownership register provisions and AMLA technical standards - MiCA incorporation into EEA Agreement for Iceland - Iceland's next FATF national risk assessment refresh - Iceland 5th Round FATF Mutual Evaluation - EEA incorporation of the EU AML Package (AMLR/6AMLD/AMLA) for Iceland - Iceland's 5th-round FATF mutual evaluation scheduling - EEA incorporation of EU AML Package (AMLR/AMLA/6AMLD) into Icelandic law - EEA incorporation of MiCA crypto-asset framework ### Active schemes - Samherji/Fishrot bribery-and-layering architecture - Iceland renewable-energy Bitcoin mining concentration - PEP offshore structuring via Mossack Fonseca (Wintris) Sources - [https://www.fatf-gafi.org/en/countries/detail/Iceland.html](https://www.fatf-gafi.org/en/countries/detail/Iceland.html) - [https://www.fatf-gafi.org/en/publications/Mutualevaluations/Fur-iceland-2021.html](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Fur-iceland-2021.html) - [https://www.consilium.europa.eu/en/press/press-releases/2026/06/29/statement-by-the-high-representative-on-behalf-of-the-european-union-on-the-alignment-of-certain-countries-concerning-restrictive-measures-in-view-of-russia-s-destabilising-activities-20261351/](https://www.consilium.europa.eu/en/press/press-releases/2026/06/29/statement-by-the-high-representative-on-behalf-of-the-european-union-on-the-alignment-of-certain-countries-concerning-restrictive-measures-in-view-of-russia-s-destabilising-activities-20261351/) - [https://globalsanctions.com/sanctioning-state/iceland/](https://globalsanctions.com/sanctioning-state/iceland/) - [https://en.highnorthnews.com/notice/1116066](https://en.highnorthnews.com/notice/1116066) - [https://www.topograph.co/guides/business-registers-in-iceland](https://www.topograph.co/guides/business-registers-in-iceland) - [https://www.o2k.tech/blog/mica-in-the-nordics-2026](https://www.o2k.tech/blog/mica-in-the-nordics-2026) - [https://www.moodys.com/web/en/us/kyc/resources/insights/a-review-of-amla-and-amlr-2026.html](https://www.moodys.com/web/en/us/kyc/resources/insights/a-review-of-amla-and-amlr-2026.html) - [https://zavia.ai/eu-beneficial-ownership-in-2026-amlr-amld6-amla-explained/](https://zavia.ai/eu-beneficial-ownership-in-2026-amlr-amld6-amla-explained/) - [https://www.offshorecorporation.com/icelandcorporation-2/](https://www.offshorecorporation.com/icelandcorporation-2/) - [https://centerformaritimestrategy.org/publications/the-intensification-of-russian-shadow-fleet-activities/](https://centerformaritimestrategy.org/publications/the-intensification-of-russian-shadow-fleet-activities/) - [https://www.imf.org/en/Publications/CR/Issues/2023/07/26/Iceland-Financial-Sector-Assessment-Program-Technical-Note-on-Anti-Money-Laundering-537018](https://www.imf.org/en/Publications/CR/Issues/2023/07/26/Iceland-Financial-Sector-Assessment-Program-Technical-Note-on-Anti-Money-Laundering-537018) - [https://www.fatf-gafi.org/content/dam/fatf-gafi/fur/Follow-Up-Report-Iceland-2020.pdf.coredownload.pdf](https://www.fatf-gafi.org/content/dam/fatf-gafi/fur/Follow-Up-Report-Iceland-2020.pdf.coredownload.pdf) - [https://www.sanctionscanner.com/aml-guide/anti-money-laundering-in-iceland-359](https://www.sanctionscanner.com/aml-guide/anti-money-laundering-in-iceland-359) - [https://www.aljazeera.com/news/2026/9/8/uk-announces-sanctions-on-illegal-israeli-settlements](https://www.aljazeera.com/news/2026/9/8/uk-announces-sanctions-on-illegal-israeli-settlements) - [https://www.haaretz.com/israel-news/israel-politics/2026-09-08/ty-article/.premium/not-just-factories-the-settlement-sanctions-could-hit-israeli-banks/000001a0-8189-d854-afe5-ffbbf70a0000](https://www.haaretz.com/israel-news/israel-politics/2026-09-08/ty-article/.premium/not-just-factories-the-settlement-sanctions-could-hit-israeli-banks/000001a0-8189-d854-afe5-ffbbf70a0000) - [https://en.wikipedia.org/wiki/2026_Icelandic_European_Union_membership_negotiations_referendum](https://en.wikipedia.org/wiki/2026_Icelandic_European_Union_membership_negotiations_referendum) - [Al Jazeera](https://www.aljazeera.com/news/2026/9/24/israel-offers-cash-to-firms-hit-by-trade-ban-europe-dithers-on-new-rules) - [Al Jazeera](https://www.aljazeera.com/news/2026/9/8/uk-announces-sanctions-on-illegal-israeli-settlements) - [FATF](https://www.fatf-gafi.org/en/countries/detail/Iceland.html) - [wiki.private.law](https://wiki.private.law/en/mica-eu) - [OECD](https://www.oecd.org/en/publications/anti-corruption-and-integrity-outlook-2026_0c8910f8-en/iceland_69c6f06f-en.html) - [https://www.fatf-gafi.org/en/publications/mutualevaluations/documents/mer-iceland-2018.html](https://www.fatf-gafi.org/en/publications/mutualevaluations/documents/mer-iceland-2018.html) - [https://www.fatf-gafi.org/en/calendars/assessments.html](https://www.fatf-gafi.org/en/calendars/assessments.html) - [https://www.morganlewis.com/pubs/2026/10/11-european-countries-and-canada-move-to-restrict-trade-with-israeli-settlements](https://www.morganlewis.com/pubs/2026/10/11-european-countries-and-canada-move-to-restrict-trade-with-israeli-settlements) - [Mutual Evaluation of Iceland](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationoficeland.html) - [Assessments](https://www.fatf-gafi.org/en/calendars/assessments.html) - [Consolidated assessment ratings](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Assessment-ratings.html) - [Iceland](https://www.fatf-gafi.org/en/countries/detail/Iceland.html) - [Countries / Jurisdictions](http://www.fatf-gafi.org/countries/#Iceland) - [Iceland's progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Fur-iceland-2021.html) - [Outcomes of meetings](https://www.fatf-gafi.org/en/the-fatf/outcomes-of-meetings.html) - [Mutual Evaluations](https://www.fatf-gafi.org/en/topics/mutual-evaluations.html) - [Consolidated Processes and Procedures for Mutual Evaluations and Follow-Up Universal Procedures](https://www.fatf-gafi.org/en/publications/Fatfgeneral/Universal-procedures.html) - [Publications](https://www.fatf-gafi.org/en/publications.html) - ["Black and grey" lists](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [Jurisdictions under Increased Monitoring - 19 June 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions.html) - [Iceland - Financial Action Task Force (FATF)](https://www.fatf-gafi.org/countries/d-i/iceland/) - [FATF changes its grey listing criteria to further focus on risk](https://www.fatf-gafi.org/en/publications/Fatfgeneral/FATF-grey-listing-criteria.html) - [Jurisdictions under Increased Monitoring - 13 February 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html) - [List of competent authorities under Article 48(1a) of AMLD](https://finance.ec.europa.eu/document/download/f06c27f5-d6e5-4a65-ae17-0be452594fde_en?filename=amld-article-48-competent-authorities-iceland_en.pdf&prefLang=bg) - [Anti-money laundering and counter-terrorist financing measures Iceland](https://www.fatf-gafi.org/content/dam/fatf-gafi/fur/Follow-Up-Report-Iceland-2020.pdf.coredownload.pdf) - [Iceland’s measures to fight money laundering and the financing of terrorism and proliferation](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mer-iceland-2018.html) - [Anti-money laundering and countering the financing of terrorism at international level - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level_en) - [Global Crypto Policy Review Outlook 2025/26 Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/global-crypto-policy-review-outlook-2025-26) - [GUIDANCE FOR A RISK-BASED APPROACH EFFECTIVE SUPERVISION AND ENFORCEMENT BY](https://www.fatf-gafi.org/content/dam/fatf-gafi/guidance/RBA-Effective-supervision-and-enforcement.pdf) - [Civil Penalties and Enforcement Information | Office of Foreign Assets Control](https://ofac.treasury.gov/civil-penalties-and-enforcement-information) - [Statement by the High Representative on behalf of the EU on the alignment of certain countries concerning restrictive measures in view of Russia’s destabilising activities - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2026/01/07/statement-by-the-high-representative-on-behalf-of-the-eu-on-the-alignment-of-certain-countries-concerning-restrictive-measures-in-view-of-russia-s-destabilising-activities/) - [Statement by the High Representative on behalf of the EU on the alignment of certain countries with Council Decision concerning restrictive measures in view of the situation in Russia - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2025/09/04/statement-by-the-high-representative-on-behalf-of-the-eu-on-the-alignment-of-certain-countries-with-council-decision-concerning-restrictive-measures-in-view-of-the-situation-in-russia/) - [Statement by the High Representative on behalf of the EU on the alignment of certain countries concerning restrictive measures in view of the situation in Russia - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2025/09/04/high-representative-statement-on-behalf-of-the-eu-on-the-alignment-of-certain-countries-concerning-restrictive-measures-in-view-of-the-situation-in-russia/) - [Timeline - EU sanctions against Russia - Consilium](https://www.consilium.europa.eu/en/policies/sanctions-against-russia/timeline-sanctions-against-russia/) - [Statement by the High Representative on behalf of the EU on the alignment of certain countries concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2026/01/07/statement-by-the-high-representative-on-behalf-of-the-eu-on-the-alignment-of-certain-countries-concerning-restrictive-measures-in-respect-of-actions-undermining-or-threatening-the-territorial-integrity-sovereignty-and-independence-of-ukrain/) - [EU adopts 20th package of sanctions against Russia - Finance](https://finance.ec.europa.eu/news/eu-adopts-20th-package-sanctions-against-russia-2026-04-23_en) - [Sanctions adopted following Russia’s military aggression against Ukraine - Finance](https://finance.ec.europa.eu/eu-and-world/sanctions-restrictive-measures/sanctions-adopted-following-russias-military-aggression-against-ukraine_en) - [Crypto Sanctions: 2026 Crypto Crime Report](https://www.chainalysis.com/blog/crypto-sanctions-2026/) - [UK Financial Sanctions FAQs - GOV.UK](https://www.gov.uk/government/publications/uk-financial-sanctions-faqs/uk-financial-sanctions-faqs) - [1 Imposition of Monetary Penalty – Bank of Scotland PLC SUMMARY](https://assets.publishing.service.gov.uk/media/697741f167ae94b3280137ee/Penalty_Publication_Notice_LBG_2026.pdf?amp=&=&=) - [The Spoils of Fishrot: Tracking the Property Holdings of Key Figures In Namibia’s Biggest Bribery Scandal | OCCRP](https://www.occrp.org/en/investigation/the-spoils-of-fishrot-tracking-the-property-holdings-of-key-figures-in-namibias-biggest-bribery-scandal) - [Icelandic Firm Gave Bribes for Fishing Rights in Namibia | OCCRP](https://www.occrp.org/en/news/icelandic-firm-gave-bribes-for-fishing-rights-in-namibia) - [A Fishy Business: Shifting Profits Out of Africa | OCCRP](https://www.occrp.org/en/investigation/a-fishy-business-shifting-profits-out-of-africa) - [Largest Norwegian Bank Faces Fine For Anti-Money Laundering Failures | OCCRP](https://www.occrp.org/en/news/largest-norwegian-bank-faces-fine-for-anti-money-laundering-failures) - [Fishing with Dynamite: The Secret Scheme That Helped Namibia’s President Stay in Power | OCCRP](https://www.occrp.org/en/investigation/fishing-with-dynamite-the-secret-scheme-that-helped-namibias-president-stay-in-power) - [Iceland Police Probe Journalists for Reporting on Harassment by Fishing Company | OCCRP](https://occrp.org/en/daily/15994-iceland-police-probe-journalists-for-reporting-on-harassment-by-fishing-company) - [Namibia: Fishrot Whistleblower Condemns ‘Cowrot’ Scandal | OCCRP](https://www.occrp.org/en/news/namibia-fishrot-whistleblower-condemns-cowrot-scandal) - [Leaked Affidavit Implicates Namibian President in Fishrot Scandal | OCCRP](https://www.occrp.org/en/daily/13669-leaked-affidavit-implicates-namibian-president-in-fishrot-scandal) - [Fishrot | OCCRP](https://www.occrp.org/en/organizations/fishrot/page/1) - [Namibia: Fishrot Whistleblower Condemns ‘Cowrot’ Scandal](https://www.occrp.org/en/daily/12772-namibia-fishrot-whistleblower-condemns-cowrot-scandal) - [2026 Crypto Crime Report – Illicit Crypto Trends & Typologies | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/2026-crypto-crime-report) - [US Sanctions North Korean Crypto-Laundromat, Indicts Bitcoin Mining CEO | OCCRP](https://www.occrp.org/en/daily/16297-us-sanctions-north-korean-crypto-laundromat-indicts-bitcoin-mining-ceo) - [Blog - Chainalysis](https://www.chainalysis.com/blog/) - [US: Mastermind of Bitcoin Fog Money Laundering Conspiracy Convicted | OCCRP](https://www.occrp.org/en/news/us-mastermind-of-bitcoin-fog-money-laundering-conspiracy-convicted) - [US: CEO of Bitcoin Platform Charged in Multi-Million Dollar Ponzi Scheme | OCCRP](https://www.occrp.org/en/news/us-ceo-of-bitcoin-platform-charged-in-multi-million-dollar-ponzi-scheme) - [Bitcoin (BTC) Miners Like Bit Digital Draw From Iceland Renewable Energy Surplus - Bloomberg](https://www.bloomberg.com/news/articles/2023-08-30/bitcoin-btc-miners-like-bit-digital-draw-from-iceland-s-renewable-energy-surplus) - [Five ways coin swap services facilitate money laundering and sanctions evasion](https://www.elliptic.co/blog/five-ways-coin-swap-services-facilitate-money-laundering-and-sanctions-evasion) - [What Is Money Laundering? Definition, Stages, and Crypto Laundering Methods - Chainalysis](https://www.chainalysis.com/glossary/money-laundering/) - [Seðlabanki Íslands - Central Bank of Iceland | EU Digital Finance Platform](https://digital-finance-platform.ec.europa.eu/cross-border-services/cross-border-testing/participants/sedlabanki-islands-central-bank-iceland) - [Special Measures | FinCEN.gov](https://www.fincen.gov/resources/statutes-and-regulations/special-measures) - [European e-Justice Portal - Beneficial ownership registers interconnection system (BORIS)](https://webgate.ec.europa.eu/e-justice/38590/EN/beneficial_ownership_registers_interconnection_system_boris?init=true&idSubpage=1) - [European Economic Area (EEA) Agreement | Access2Markets](https://trade.ec.europa.eu/access-to-markets/en/content/european-economic-area-eea-agreement) - [Guidance on Beneficial Ownership of Legal Persons](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-Beneficial-Ownership-Legal-Persons.html) - [eeas cms transmission sheet - Data](https://data.consilium.europa.eu/doc/document/WK-1090-2026-INIT/en/pdf) - [European Commission - Have your say](https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14851-Anti-money-laundering-formats-for-the-submission-of-beneficial-ownership-information-to-central-registers/F33264940_en) - [6220/1/24 REV 1 GBJ/lhg 1 ECOFIN.1.B LIMITE EN Council of the European Union](https://data.consilium.europa.eu/doc/document/ST-6220-2024-REV-1/en/pdf) - [Beneficial Ownership Registers Interconnection System](https://webgate.ec.europa.eu/e-justice/searchBoris.do) - [Incentives and Legislation | European Alternative Fuels Observatory](https://alternative-fuels-observatory.ec.europa.eu/transport-mode/road/iceland/incentives-legislations) - [Iceland - Employment, Social Affairs & Inclusion - European Commission](https://ec.europa.eu/social/main.jsp?catId=1114&intPageId=4600&langId=en) - [Country data: Iceland | Single Market and Competitiveness Scoreboard](https://single-market-scoreboard.ec.europa.eu/index.php/countries/iceland_en) - [Arion Banki HF - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/1620253D:SS) - [Excel Spreadsheet's Incorrect Format Hurt Profits From Islandsbanki Sale - Bloomberg](https://www.bloomberg.com/news/articles/2022-11-14/bungled-excel-sheet-hurts-profits-from-islandsbanki-sale) - [GLITNIR BANKI HF. overview - Find and update company information - GOV.UK](https://find-and-update.company-information.service.gov.uk/company/FC023491) - [Iceland’s Biggest IPO Ever Values Islandsbanki at $1.3 Billion - Bloomberg](https://www.bloomberg.com/news/articles/2021-06-16/iceland-s-biggest-ipo-ever-values-islandsbanki-at-1-3-billion) - [Islandsbanki hf.: Íslandsbanki issues SEK 750 million Additional Tier 1 notes - Bloomberg](https://www.bloomberg.com/press-releases/2021-09-21/islandsbanki-hf-slandsbanki-issues-sek-750-million-additional-tier-1-notes) - [After Goldman Purchase, Iceland Eyes More Foreign Cash for Banks - Bloomberg](https://www.bloomberg.com/news/articles/2018-12-11/after-goldman-investment-iceland-prepares-more-bank-asset-sales) - [Stocks - Bloomberg - Bloomberg Markets](http://www.bloomberg.com/research/stocks/private/snapshot.asp?privcapId=875696) - [Gisli Halldorsson, Islandssjodir HF: Profile and Biography - Bloomberg Markets](https://www.bloomberg.com/profile/person/19539608) - [Glitnir in Talks With Offshore Investors on Islandsbanki Sale - Bloomberg](https://www.bloomberg.com/news/articles/2013-05-30/islandsbanki-quarterly-profit-drops-18-on-foreign-exchange-loss) - [UK-Norway, Iceland, and Liechtenstein FTA: joint declaration on financial services - GOV.UK](https://www.gov.uk/government/publications/uk-norway-iceland-and-liechtenstein-free-trade-agreement-joint-declarations/uk-norway-iceland-and-liechtenstein-fta-joint-declaration-on-financial-services) - [Countries in the EU and EEA - GOV.UK](https://www.gov.uk/eu-eea) - [Commission register of competent authorities under Article 48(1a) of AMLD - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-eu-level/commission-register-competent-authorities-under-article-481a-amld_en) - [Anti-money laundering and countering the financing of terrorism at EU level - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-eu-level_en) - [Agreement on Arrangements between Iceland, Liechtenstein, Norway and UK following the Withdrawal of UK from the EU, the EEA Arrangement and other Agreements applicable between UK and EEA EFTA States by virtue of UK's Membership of the EU [TS No.35/2025] - GOV.UK](https://www.gov.uk/government/publications/agreement-on-arrangements-between-iceland-liechtenstein-norway-and-uk-following-the-withdrawal-of-uk-from-the-eu-the-eea-arrangement-and-other-agre--2) - [EFTA-EEA - Agriculture and rural development - European Commission](https://agriculture.ec.europa.eu/international/agricultural-trade/bilateral-agreements/efta-enp-countries/efta-eea_en) - [Where do these rules apply? - Employment, Social Affairs & Inclusion - European Commission](https://ec.europa.eu/social/main.jsp?catId=853&langId=en) - [Timeline: EU action against money laundering and terrorist financing - Consilium](https://www.consilium.europa.eu/en/policies/fight-against-terrorist-financing/timeline/) - [Virtual Assets](https://www.fatf-gafi.org/en/topics/virtual-assets.html) - [ISA2 Digital Public Administration factsheet 2020 Iceland](https://interoperable-europe.ec.europa.eu/sites/default/files/inline-files/Digital_Public_Administration_Factsheets_Iceland_vFINAL.pdf) - [Virtual Assets and Virtual Asset Service Providers](https://www.fatf-gafi.org/content/dam/fatf-gafi/guidance/RBA-VA-VASPs.pdf) - [Virtual Assets: Targeted Update on Implementation of the FATF Standards on VAs and VASPs](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/targeted-update-virtual-assets-vasps-2023.html) - [Seðlabanki Íslands - Central Bank of Iceland | EU Digital Finance Platform](https://digital-finance-platform.ec.europa.eu/efif/cross-border-testing/participants/sedlabanki-islands-central-bank-iceland) - [Financial Supervisory Authority FIN-FSA | EU Digital Finance Platform](https://digital-finance-platform.ec.europa.eu/cross-border-services/cross-border-testing/participants/financial-supervisory-authority-fin-fsa) - [GOVERNMENT OF ICELAND overview - Find and update company information - GOV.UK](https://find-and-update.company-information.service.gov.uk/company/OE027832) - [The Panama Papers: Exposing the Rogue Offshore Finance Industry - ICIJ](https://www.icij.org/investigations/panama-papers/) - [Ten years after the Panama Papers, enablers and tax cheats are still being brought to justice - ICIJ](https://www.icij.org/investigations/panama-papers/ten-years-after-the-panama-papers-enablers-and-tax-cheats-are-still-being-brought-to-justice/) - [A new ICIJ investigation exposes a rogue offshore industry - ICIJ](https://www.icij.org/investigations/panama-papers/new-icij-investigation-exposes-rogue-offshore-industry/) - [Behind the scenes of the Panama Papers story that brought down Iceland's PM - ICIJ](https://www.icij.org/investigations/panama-papers/behind-the-scenes-of-the-panama-papers-story-that-brought-down-icelands-pm/) - [Giant Leak of Offshore Financial Records Exposes Global Array of Crime and Corruption - The Panama Papers](https://admin.occrp.org/en/panamapapers/overview/intro/) - [Global headlines and a public reckoning: Ten years of the Panama Papers, part 3 - ICIJ](https://www.icij.org/investigations/panama-papers/global-headlines-and-a-public-reckoning-ten-years-of-the-panama-papers-part-3/) - [Investigations, protest, and call for election in Iceland as world responds to Panama Papers - ICIJ](https://www.icij.org/investigations/panama-papers/investigations-begin-world-responds-panama-papers/) - [Offshore havens and hidden riches of world leaders and billionaires exposed in unprecedented leak - ICIJ](https://www.icij.org/investigations/pandora-papers/global-investigation-tax-havens-offshore/) - [Giant Leak of Offshore Financial Records Exposes Global Array of Crime and Corruption | OCCRP](https://www.occrp.org/en/project/the-panama-papers/giant-leak-of-offshore-financial-records-exposes-global-array-of-crime-and-corruption) - [Tax evasion & ICIJ reporting: governments recoup millions](https://www.icij.org/investigations/panama-papers/hundreds-of-millions-more-dollars-recouped-by-governments-after-icij-investigations/) - [Unodc](https://www.unodc.org/documents/treaties/UNCAC/IRG-Experts/English/FirstCycle/Iceland_E.pdf) - [CAC/COSP/WG.2/2021/CRP.1 23 August 2021 English only V.21-06348 (E) *2106348*](https://www.unodc.org/documents/treaties/UNCAC/WorkingGroups/workinggroup2/2021-September-6-10/CAC-COSP-WG.2-2021-CRP.1.pdf) - [Iceland Police Probe Journalists for Reporting on Harassment by Fishing Company | OCCRP](https://www.occrp.org/en/news/iceland-police-probe-journalists-for-reporting-on-harassment-by-fishing-company) - [Report on the work of the seventy-sixth session (2025) — International Law Commission](https://legal.un.org/ilc/reports/2025/) - [International Criminal Court-Related Designations; Issuance of International Criminal Court-Related General License | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20250820) - [Report on the work of the seventy-fifth session (2024) — International Law Commission](https://legal.un.org/ilc/reports/2024/) - [Information for British people arrested or detained in Iceland - GOV.UK](https://www.gov.uk/government/publications/iceland-prisoner-pack/information-for-british-people-arrested-or-detained-in-iceland) - [Historical Survey of the Question of International Criminal ...](https://legal.un.org/ilc/documentation/english/a_cn4_7_rev1.pdf) - [CPS data summary Quarter 3 2024-2025 | The Crown Prosecution Service](https://www.cps.gov.uk/publication/cps-data-summary-quarter-3-2024-2025) - [CPS data summary Quarter 2 2024-2025 | The Crown Prosecution Service](https://www.cps.gov.uk/publication/cps-data-summary-quarter-2-2024-2025) - [Iceland Delivers Second Hike in Two Months to Cool Economy - Bloomberg](https://www.bloomberg.com/news/articles/2026-05-20/iceland-delivers-second-hike-in-two-months-to-cool-economy) - [EUROPA - EURES - Vinnuskilyrði og lífskjör](https://ec.europa.eu/eures/printLWCText.jsp?lwcLang=is&countryId=IS) - [FIN-NET members in Lithuania](https://finance.ec.europa.eu/consumer-finance-and-payments/retail-financial-services/financial-dispute-resolution-network-fin-net/fin-net-network/members-fin-net-country/fin-net-members-lithuania_en) - [Iceland Central Bank Hikes Rates, Citing Aluminum, Fishing, Tourism Factors - Bloomberg](https://www.bloomberg.com/news/articles/2026-05-20/solar-eclipse-cod-catch-and-aluminum-factor-in-icelandic-rates) - [FIN-NET members in Iceland - Finance - European Commission](https://finance.ec.europa.eu/consumer-finance-and-payments/retail-financial-services/financial-dispute-resolution-network-fin-net/members-fin-net-country/fin-net-members-iceland_en) - [Statistics and Research](https://www.gamblingcommission.gov.uk/about-us/statistics-and-research) - [Iceland - Úrskurðarnefnd um viðskipti við fjármálafyrirtæki - Consumer Redress in the EU](https://consumer-redress.ec.europa.eu/list-alternative-dispute-resolution-adr-bodies/iceland-urskurdarnefnd-um-vidskipti-vid-fjarmalafyrirtaeki_en) - [Comhairle Establishes Major Development Oversight Board | Comhairle nan Eilean Siar](https://www.cne-siar.gov.uk/news/2024/comhairle-establishes-major-development-oversight-board) - [PR1 Application for student finance - 2026/27](https://assets.publishing.service.gov.uk/media/69b98b936736ec37c8a46692/sfe_pr1_form_2627_o.pdf) - [Giant Leak of Offshore Financial Records Exposes Global Array of Crime and Corruption - ICIJ](https://www.icij.org/investigations/panama-papers/20160403-panama-papers-global-overview/) - [Welcome to Iceland, Where Bad Bankers Go to Prison - Bloomberg](https://www.bloomberg.com/news/features/2016-03-31/welcome-to-iceland-where-bad-bankers-go-to-prison) - [Financial Action Task Force Groupe d'action financière](https://www.fatf-gafi.org/content/dam/fatf-gafi/mer/MER%20Iceland%20ES.pdf) - [2022 Procedures for the FATF AML/CFT/CPF Mutual Evaluations, Follow-Up and ICRG](https://www.fatf-gafi.org/en/publications/Mutualevaluations/5th-Round-Procedures.html) - [Mutual Evaluations](https://www.fatf-gafi.org/en/publications/Mutualevaluations.html) - [What are FATF mutual evaluations?](https://www.fatf-gafi.org/content/dam/fatf-gafi/methodology/Handout-5th-Round-Methodology.pdf.coredownload.pdf) - [Events](https://www.fatf-gafi.org/en/calendars/events.html) - [FATF MUTUAL EVALUATIONS? FATF METHODOLOGY?](https://www.fatf-gafi.org/content/dam/fatf/documents/methodology/Handout-5th-Round-Methodology.pdf) - [Calendars](https://www.fatf-gafi.org/en/calendars.html) - [Financial Action Task Force (FATF)](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mer-iceland-2018.html) - [Financial Action Task Force (FATF)](https://www.fatf-gafi.org/content/dam/fatf-gafi/fur/Follow-Up-Report-Iceland-2020.pdf.coredownload.pdf) - [Financial Action Task Force (FATF)](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [Council of the European Union](https://www.consilium.europa.eu/en/press/press-releases/2026/01/07/statement-by-the-high-representative-on-behalf-of-the-eu-on-the-alignment-of-certain-countries-concerning-restrictive-measures-in-view-of-russia-s-destabilising-activities/) - [Council of the European Union](https://www.consilium.europa.eu/en/press/press-releases/2025/09/04/statement-by-the-high-representative-on-behalf-of-the-eu-on-the-alignment-of-certain-countries-with-council-decision-concerning-restrictive-measures-in-view-of-the-situation-in-russia/) - [UK Office of Financial Sanctions Implementation (OFSI)](https://www.gov.uk/government/publications/uk-financial-sanctions-faqs/uk-financial-sanctions-faqs) - [European Commission](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-eu-level_en) - [Organized Crime and Corruption Reporting Project (OCCRP)](https://www.occrp.org/en/news/icelandic-firm-gave-bribes-for-fishing-rights-in-namibia) - [UNODC / UNCAC Working Group](https://www.unodc.org/documents/treaties/UNCAC/WorkingGroups/workinggroup2/2021-September-6-10/CAC-COSP-WG.2-2021-CRP.1.pdf) - [International Consortium of Investigative Journalists (ICIJ)](https://www.icij.org/investigations/panama-papers/20160403-panama-papers-global-overview/) - [Bloomberg](https://www.bloomberg.com/news/articles/2023-08-30/bitcoin-btc-miners-like-bit-digital-draw-from-iceland-s-renewable-energy-surplus) - [TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/2026-crypto-crime-report) Coverage gaps fim-int-2026-07-05-G001: No material domestic Icelandic AML … fim-int-2026-07-05-G001: No material domestic Icelandic AML prosecution or supervisory-penalty outcome has been identified in open-source reporting for this baseline window, limiting assessment of enforcement effectiveness beyond legal-framework strength. [resolved] fim-int-2026-07-05-G002: FSA VASP-specific supervisory guida… fim-int-2026-07-05-G002: FSA VASP-specific supervisory guidance and feedback practices post-2020 are not independently documented beyond the original FATF follow-up finding, limiting confidence in whether the capacity deficit has narrowed. [resolved] fim-int-2026-07-05-G003: No confirmed EEA Joint Committee ti… fim-int-2026-07-05-G003: No confirmed EEA Joint Committee timetable or draft incorporation text for the EU AML Package (AMLR/AMLAReg/6AMLD) or MiCA into the EEA Agreement has been identified, limiting precision of the improving-trajectory horizon assessment. [resolved] fim-int-2026-07-05-G004: No Icelandic domestic criminal-just… fim-int-2026-07-05-G004: No Icelandic domestic criminal-justice outcome for Samherji executives has been identified, despite active Namibian prosecutions, limiting assessment of whether the extraterritorial-bribery accountability gap is closing or persistent. [resolved] fim-int-2026-07-05-G005: The USD 154 billion 2025 global cry… fim-int-2026-07-05-G005: The USD 154 billion 2025 global crypto-illicit-inflow figure rests on a single vendor (Chainalysis) source with no independent T1-T2 corroboration specific to Icelandic-linked flows. [resolved] fim-int-2026-07-05-G006: No confirmed Icelandic alignment st… fim-int-2026-07-05-G006: No confirmed Icelandic alignment statement with the EU's 20th sanctions package (adopted 23 April 2026) has been identified in this baseline window. [resolved] fim-int-2026-08-20-G001: Tier D watch jurisdictions (KH, LA,… fim-int-2026-08-20-G001: Tier D watch jurisdictions (KH, LA, MX, CO) were not resolved this cycle due to pooled search-budget allocation prioritising the bound jurisdiction IS. [resolved] fim-int-2026-08-20-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-08-20-G002 ({'scheme': 'financial_integrity', 'value': 'D3'}): No D3 (Enabler Jurisdictions) or D4 (Conflict Finance) primary-source evidence was reached for Iceland this cycle. [resolved] fim-int-2026-08-20-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-08-20-G003 ({'scheme': 'financial_integrity', 'value': 'D1'}): Court reasoning in the Vélfag Supreme Court sanctions ruling remains unpublished, limiting analytical depth on the legal basis for upholding the asset freeze. [resolved] fim-int-2026-09-05-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-09-05-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): No EU official primary source (EUR-Lex/European Commission) retrieved this cycle to confirm Iceland's AMLR/AMLD6/AMLA EEA-incorporation timing. [resolved] fim-int-2026-09-05-G002: Tier D jurisdictions (Cambodia, Lao… fim-int-2026-09-05-G002: Tier D jurisdictions (Cambodia, Laos, Mexico, Colombia) not actively searched this cycle within pooled union search budget. [resolved] fim-int-2026-09-05-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-09-05-G003 ({'scheme': 'financial_integrity', 'value': 'D1'}): No T1 government.is primary source located specifically for the Vélfag Supreme Court ruling; two T3 press sources corroborate. [resolved] fim-int-2026-09-21-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-09-21-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): No Icelandic government primary-source (Foreign Ministry) statement located confirming a specific national designation instrument for Israeli settlement goods; the joint statement is corroborated only by Tier-3 press. [resolved] fim-int-2026-09-21-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-09-21-G002 ({'scheme': 'financial_integrity', 'value': 'D5'}): No Tier-1 EEA Joint Committee source confirms a MiCA incorporation timeline for Iceland; all corroboration is Tier 3/4. [resolved] fim-int-2026-09-21-G003: Tier D watch jurisdictions (KH, LA,… fim-int-2026-09-21-G003: Tier D watch jurisdictions (KH, LA, MX, CO) were not actively searched this cycle due to JID-bound dispatch scope; recorded as a run-scope gap, not a no-material-change assertion. [resolved] fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): No primary Icelandic foreign-ministry instrument located confirming whether a national settlement-trade restriction has since entered into force. [open] fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', 'value': 'D5'}): No Icelandic primary instrument (Stjórnartíðindi text or Alþingi act) located to resolve whether MiCA currently applies in Iceland via EEA incorporation. [open] fim-int-2026-10-18-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G003 ({'scheme': 'financial_integrity', 'value': 'D7'}): 6AMLD/AMLR transposition status for Iceland via EEA lag not established this cycle. [open] fim-int-2026-10-18-G004: Tier D jurisdiction watch (Cambodia… fim-int-2026-10-18-G004: Tier D jurisdiction watch (Cambodia, Laos, Mexico, Colombia) not actively re-swept this cycle given single-jurisdiction scope. [open] fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): Iceland's EEA incorporation status/date for the EU AML Package (AMLR/6AMLD/AMLA) could not be confirmed this cycle; budget-limited. [open] fim-int-2026-10-25-G002: Tier D jurisdictions (KH, LA, MX, C… fim-int-2026-10-25-G002: Tier D jurisdictions (KH, LA, MX, CO) were not actively searched this cycle because this run is bound to Iceland alone. [open] FIM-GAP-001 (D3): FATF's assessment record for Iceland has r… FIM-GAP-001 (D3): FATF's assessment record for Iceland has repeatedly found that while Iceland has a sound legal AML framework, available penalties and the number of money-laundering convictions remain low; no material domestic Icelandic AML prosecution or supervisory-penalty outcome was identified in open-source reporting during this 18-month baseline window. FIM-GAP-002 (D5): FATF's 2020 follow-up review found that de… FIM-GAP-002 (D5): FATF's 2020 follow-up review found that despite extensive general AML guidance, evidence of guidance specific to virtual-asset service providers is limited and the FSA does not appear to provide sufficient feedback to VASPs registered with it, even as Iceland's renewable-energy sector continues to attract large-scale crypto mining operations. FIM-GAP-003 (D2): As an EEA/EFTA state rather than an EU mem… FIM-GAP-003 (D2): As an EEA/EFTA state rather than an EU member, Iceland is not directly bound by the EU's 2024 AML Package (AMLR, AMLA Regulation, 6AMLD); these instruments must be separately incorporated into the EEA Agreement, a process subject to a documented legislative backlog affecting Iceland's transposition of EU law generally. FIM-GAP-004 (D4): Unlike Namibia's active prosecutions of im… FIM-GAP-004 (D4): Unlike Namibia's active prosecutions of implicated officials in the Fishrot bribery scandal, no comparable, publicly documented Icelandic domestic criminal conviction of Samherji executives has been identified in reporting available for this baseline, despite the parent company being Icelandic-headquartered. ## Evidence #### Confidence-tiered claims Iceland co-signed an 8 September 2026 joint statement restricting trade with Israeli settlements but had not enacted a national measure as of 24 September 2026 [[Source 1]](#sec-sources) Probable · 1 source Off FATF strategic-deficiency list; 5th-round mutual evaluation scheduled with possible on-site from June 2026 [[Source 1]](#sec-sources) Probable · 1 source Secondary sources disagree on whether Iceland has completed EEA Joint Committee incorporation of MiCA [[Source 1]](#sec-sources) Disputed · 1 source BO registration obligation runs via the Tax Administration under AML legislation implemented from 2019; no new material this cycle [[Source 1]](#sec-sources) Probable · 1 source Six of twelve settlement-trade-ban signatories (incl. Iceland, Denmark, Finland, Poland, Portugal, Sweden) had not enacted a national measure as of 24 September 2026 [[Source 1]](#sec-sources) Probable · 1 source Fourth Round Mutual Evaluation Report adopted February 2018; exited increased monitoring (grey list) October 2020; next possible onsite from June 2026, plenary possible February 2027. [[Source 1]](#sec-sources) Probable · 1 source Iceland is a signatory to the 8 September 2026 joint statement by Canada and eleven European states restricting trade in goods from Israeli settlements in the West Bank. [[Source 1]](#sec-sources) Probable · 1 source Possible onsite period beginning June 2026; possible plenary discussion February 2027 [[Source 1]](#sec-sources) Probable · 1 source Removed from FATF grey list October 2020; 2021 follow-up rated Compliant/Largely Compliant on 38 of 40 Recommendations [[Source 1]](#sec-sources) Uncertain · 1 source Disputed: secondary sources disagree on whether MiCA has been incorporated into the EEA Agreement for Iceland [[Source 1]](#sec-sources) Disputed · 1 source