The principal development is the removal of Monaco, Bulgaria, Côte d’Ivoire and the Democratic Republic of the Congo from the list of jurisdictions under increased monitoring, following successful on-site visits. No new jurisdictions were added to the grey list at this Plenary.
Jurisdictions under Increased Monitoring (Grey List)
The four jurisdictions have completed their FATF action plans and are no longer subject to increased monitoring. They will continue working with their respective FATF-style regional bodies to sustain the improvements achieved.
Inclusion on the grey list does not, in itself, trigger a FATF call for enhanced due diligence. The FATF advocates a risk-based approach rather than the indiscriminate termination of business relationships. Businesses must nevertheless comply with any enhanced due diligence requirements imposed by applicable legislation and regulatory guidance.
High-Risk Jurisdictions (Black List)
The Democratic People’s Republic of Korea (DPRK), Iran and Myanmar remain subject to a FATF call for action.
The FATF continues to call for countermeasures concerning the DPRK and Iran. For Myanmar, it calls for enhanced due diligence proportionate to the risks, rather than countermeasures at this stage. If Myanmar makes no further progress by February 2027, the FATF will consider countermeasures.
Focus on Selected Jurisdictions
Monaco: Removal from the Grey List
Monaco’s removal follows reforms addressing the strategic deficiencies identified in June 2024.
The FATF recognised improvements in:
- understanding money laundering risks linked to foreign income tax fraud;
- international asset recovery;
- sanctions for compliance and beneficial ownership breaches;
- financial intelligence resources and suspicious transaction reporting;
- judicial effectiveness and the seizure of suspected criminal property.
Monaco will continue working with MONEYVAL to sustain these improvements. MONEYVAL Chair Nicola Muccioli said: “On behalf of MONEYVAL, I warmly congratulate Bulgaria and Monaco on their tremendous progress in improving the effectiveness of their AML/CFT regimes. MONEYVAL will continue working with both countries to sustain these improvements.
Monaco remains on the European Union's list of high-risk third countries until Brussels takes action to update its own listing.
British Virgin Islands (BVI)
The BVI remain under increased monitoring. The FATF recognised progress in beneficial ownership information, suspicious activity reporting and law enforcement resources.
Remaining priorities include stronger supervision, sanctions for beneficial ownership breaches, international financial intelligence sharing, money laundering investigations and prosecutions, and confiscation of criminal proceeds.
Lebanon
Lebanon also remains under increased monitoring. Recent progress includes guidance and training on targeted financial sanctions. Further work is required across supervision, beneficial ownership transparency, financial intelligence, investigations, asset recovery and sanctions implementation.
Vietnam
Vietnam remains under increased monitoring. The FATF expressed significant concern about the pace of progress and Vietnam’s failure to complete its action plan, for which all deadlines expired in May 2025.
The FATF strongly urged Vietnam to accelerate implementation and address the remaining strategic deficiencies. It expects tangible improvements by February 2027 and will consider further steps if these are not demonstrated.
The Plenary agreed to significantly accelerate the effective implementation of the FATF Standards on virtual assets (VAs) in jurisdictions with materially important VA activity. The Plenary recognised the need to urgently strengthen countries’ defences against the rising threat posed by the misuse of virtual assets for money laundering, terrorist financing and proliferation financing.
The Plenary approved a landmark report that elevates the fight against fraud and scam compounds as a global priority, providing a strong basis for the FATF and its Global Network to intensify efforts to identify, disrupt and deprive the criminal networks behind these operations of their illicit profits.
The Plenary adopted reports of Mexico and the United States under the new round of mutual evaluations. The reports will be published in December 2026, following a quality and consistency review.
Under the new round of mutual evaluations, countries receive a timebound Roadmap of Key Recommended Actions required within three years to strengthen the effectiveness of their defences against illicit finance.
And the Plenary agreed to introduce tailored assessments for low-capacity countries, enabling a more risk-based prioritisation of high-impact reforms.
Practical Considerations for Businesses
For compliance teams, this update provides an opportunity to review country risk assessments, internal policies and relevant client files. Any changes to due diligence procedures should take account of applicable legislation, regulatory guidance and the circumstances of each relationship.
For further information, please contact: office@rosemont-mc.com.