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Jurisdiction Risk Matrix

An AML country risk model for 255 jurisdictions: an Excel file and a guide for putting it to work in your own firm. Three risk tiers, five indicators, a change log and a source register.

Coverage
255 jurisdictions
Categories
Three tiers, blacklist, manual review
Indicators
Five
Version
1.0, July 2026

What is inside

The matrix classifies 255 countries and territories into Low, Medium, High Risk, Blacklist and Manual Review. The workbook ships with a README, a lookup sheet, a dashboard, the full matrix, source data, a configuration sheet, a source register, a change log and the methodology in short form.

The guide explains how the model decides, why each indicator is there, how the weights were set, and what a supervisor will ask when you present it.

How the 255 jurisdictions fall out

Blacklist3
High Risk62
Medium Risk80
Low Risk40
Manual Review70

Manual Review is not a gap in the data but a decision: where the sources are too thin, the model refuses to rate Low and hands the question to the compliance function.

What an answer looks like

Matrix255 rows, one per jurisdiction
JurisdictionRatingWhy
IranBlacklistRule: FATF blacklist
MonacoHighRule: FATF greylist, EU high-risk list
KazakhstanMediumScored on indices
EstoniaLowScored on indices
Cayman IslandsManual ReviewCoverage below minimum

One row per category, as the file rates them today. The answer sits next to the name and the rule that produced it sits beside the answer: some jurisdictions are set by a list, others by the index. The workings stay further along the same row.

Who needs it

Compliance officers who need a defensible country-risk rating for onboarding, periodic review, transaction monitoring calibration and product eligibility, and who would rather start from a documented model than from a blank sheet.

How the model decides

Classification is strictly hierarchical: a tier only runs when the tier above it has not fired.

Tier 1. BlacklistThe jurisdiction appears on the FATF call-for-action list, UN Security Council sanctions, your home sanctions regime or your internal blacklist.
Tier 2. High riskThe FATF greylist and equivalent flags set High Risk without scoring.
Tier 3. Weighted indexWhere neither override applies, the model scores the weighted index across five indicators and sets Low, Medium or High Risk.

What it does not do

It does not screen names. Sanctions and PEP screening remain separate mandatory controls. It does not replace judgement: the model gives a defensible starting point, the Compliance function owns the final rating. It does not stay current by itself, because lists move. It is not legal advice.

The home-jurisdiction sanctions column ships empty on purpose. A template cannot assume whose law binds you, and the guide explains how to fill it.

This material is informational. It is not legal advice and does not replace the judgement of your compliance officer or a decision by your supervisor. Facts and rules change, so check the date above before you rely on it.

You may use it in your own work, inside your firm and in documents for your supervisor. When you quote it, name the source, Northhold Advisory, northholdadvisory.com. Selling it or passing it off as your own material is not allowed.

Need this adapted to your firm?

We calibrate the model to your risk appetite, products and country of registration, and leave it usable without us.

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