FATF’s recent list updates: what’s changed and what next?

The Financial Action Task Force (FATF) plays a crucial role in safeguarding the integrity of the global financial system. When countries fall short in implementing effective measures against money laundering, terrorist financing, and proliferation financing, the FATF steps in, placing them on public ‘grey and black lists’ that reflect their compliance standing.  

What are the FATF grey and black lists?

• Grey list: Countries with strategic deficiencies in their anti-money laundering and counter-terrorist financing AML/CFT systems that are under ‘increased monitoring’ and are actively working with FATF to resolve them within a set timeline. These countries face reputational damage, increased scrutiny, and reduced investor confidence.

• Black list: Countries with 'significant strategic deficiencies’ in their compliance regimes. FATF calls on these jurisdictions to apply enhanced due diligence and, in some cases, countermeasures against financial transactions involving these countries.

Which countries have been added and removed from the FATF grey list?

On 13 June 3035, the FATF announced changes to its high-risk and other monitored jurisdictions lists. According to the announcement,  

• Bolivia and the British Virgin Islands were added to the grey list after FATF assessments revealed significant shortcomings in their AML/CFT frameworks.

• Croatia, Mali, and Tanzania were removed from the grey list after FATF confirmed they had successfully implemented their action plans and underwent positive on-site evaluations.

What changes have been made to the FATF black list?

The FATF’s Black list remains unchanged, with North Korea, Iran, Myanmar continuing to be in the list and the FATF reiterating its call to apply countermeasures on these high-risk jurisdictions.

What’s next for the new grey list jurisdictions?

Jurisdictions under increased monitoring are actively working with the FATF or their FATF-style regional bodies (FSRBs) to correct strategic deficiencies. Each jurisdiction has an agreed action plan and a timeline for completion.  

FATF closely monitors progress but does not call for de-risking or cutting off entire sectors or customer groups. Instead, it encourages members to adopt a balanced, risk-based approach that ensures legitimate financial activities such as humanitarian aid, and remittances are not disrupted.

Bolivia

According to the January 2025 FATF report on Bolivia’s progress on strengthening its compliance measures, Bolivia has made meaningful progress in areas such as risk understanding, financial intelligence, and the seizure of criminal proceeds. However, to be removed from the Grey List, Bolivia must now implement several key reforms.  

These include enabling the use of special investigative techniques in money laundering investigations, enhancing risk-based supervision of high-risk non-financial sectors and ensuring that beneficial ownership data is accurate, current, and subject to effective sanctions in case of non-compliance. In addition, Bolivia is expected to increase the volume and quality of money laundering investigations and prosecutions in line with its national risk profile.

British Virgin Islands (BVI)

Since publication of its Mutual Evaluation Report (MER) in November 2023, the BVI has taken meaningful steps forward, including increasing its use of international cooperation channels and developing a dedicated counter-terrorist financing (CFT) strategy.

The territory has also conducted a targeted risk assessment of the non-profit organisation (NPO) sector, identifying which NPOs may be vulnerable to terrorist financing abuse, and has strengthened its outreach and training for financial institutions and designated non-financial businesses and professions (DNFBPs).

As it moves forward under FATF monitoring, the BVI has committed to implementing a detailed action plan. The next phase of reform will focus on six core areas:

1. Enhancing risk-based supervision of higher-risk entities, including trust and company service providers (TCSPs), investment businesses, and virtual asset service providers (VASPs);

2. Ensuring beneficial ownership information is accurate, up-to-date, and readily accessible by competent authorities, with appropriate sanctions applied for non-compliance;

3. Improving the quality of suspicious activity reports (SARs) and aligning reporting practices with the jurisdiction’s identified risk profile;

4. Scaling up investigations and prosecutions for money laundering offences in line with risk;

5. Increasing the seizure and confiscation of assets linked to criminal activity; and

6. Operationalising a new asset management framework to manage confiscated property effectively.

The BVI’s continued progress in these areas will be critical to demonstrating its commitment to global AML/CFT standards and securing its eventual removal from the FATF Grey List.

FATF’s monitoring process is not punitive. It is designed to support countries in closing critical gaps that threaten global financial integrity. The removal of Croatia, Mali, and Tanzania from the FATF Grey List highlights the tangible benefits of meaningful, sustained progress in strengthening AML/CFT frameworks. Exiting the list not only enhances a country's global reputation and investment appeal but also improves its access to international financial systems.  

For governments, regulators, and financial institutions, these developments serve as a clear reminder: robust compliance is not just about meeting obligations. It's about enabling secure, transparent, and sustainable participation in the global financial landscape. And for this, it’s time to move to AI-powered anti-money laundering solutions that could reduce your costs while ensuring compliance.

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