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On October 25, 2024, the Financial Action Task Force (FATF) issued updates to its official lists, specifying which jurisdictions are under increased monitoring and which fall under a call for action due to strategic deficiencies. These lists, often updated during FATF’s plenary meetings, reflect the organization’s analysis in conjunction with changing global political and economic circumstances.
Jurisdictions placed under "increased monitoring" are those where the FATF has identified strategic deficiencies in Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) policies. While inclusion on this list does not necessarily mean that jurisdictions are subject to strict customer rejection protocols or that enhanced due diligence measures are required, the FATF advocates for a “risk-based approach.” This approach urges entities to take into account the FATF’s findings and apply discretion based on each case, as part of their own risk analyses.
Many jurisdictions on the increased monitoring list make commitments to swiftly address their deficiencies, often within agreed timeframes, which the FATF then monitors. This list, commonly known as the “grey list,” has been updated following the October 2024 review, and now includes new jurisdictions such as Algeria, Angola, Côte d’Ivoire, and Lebanon. At the same time, Senegal’s significant progress in reinforcing its AML/CFT framework has resulted in its removal from increased monitoring.
The full list of jurisdictions the FATF has identified as requiring increased monitoring as of October 2024 includes:
Algeria
Angola
Bulgaria
Burkina Faso
Cameroon
Côte d’Ivoire
Croatia
Democratic Republic of the Congo
Haiti
Kenya
Lebanon
Mali
Monaco
Mozambique
Namibia
Nigeria
Philippines
South Africa
South Sudan
Syria
Tanzania
Venezuela
Vietnam
Yemen
High-risk jurisdictions subject to a call for action, which indicates a need for enhanced due diligence due to significant strategic deficiencies, were also confirmed. These jurisdictions, listed under what is often referred to as the “blacklist,” include:
Myanmar
Democratic People’s Republic of Korea (DPRK)
Iran
The FATF has also reiterated the suspension of the Russian Federation’s membership, calling for vigilance against risks associated with Russia across all jurisdictions.
Strategic Initiatives and Revisions to FATF Standards
In addition to the updated lists, the FATF outlined ongoing initiatives targeting unintended consequences in the application of FATF standards. A key report revealed that many jurisdictions are not fully leveraging the flexibility inherent in the FATF’s risk-based approach. FATF’s new revisions aim to encourage more jurisdictions to implement simplified measures when a lower risk level is determined.
In a historical move, the FATF has invited two jurisdictions—Cayman Islands and Senegal—to participate as guests in the FATF Plenary and Working Groups. This invitation, issued on a rotational basis for a year, marks a strategic initiative to increase inclusivity and introduce a broader range of perspectives in FATF proceedings.
The FATF standards are also undergoing revisions to stay aligned with evolving cross-border payment mechanisms and changing industry standards, with additional updates being made to reflect emerging terrorist financing risks. Furthermore, the FATF has launched a new project aimed at ensuring that jurisdictions do not misuse FATF requirements as a way to limit the operations of Non-Profit Organisations (NPOs).
Entities obliged under the Prevention and Suppression of Money Laundering and Terrorist Financing Law of 2007, specifically Cyprus Law 188(I)/2007, must take these updates into account in their AML risk-scoring and due diligence processes for both customer onboarding and ongoing monitoring. The FATF highlighted that non-compliance or deviation from these recommendations is a breach of the law and exposes entities to additional AML risks, including potential administrative or criminal penalties.
In line with FATF’s standards and updates, entities should continue to strengthen their risk-based approaches and tailor their compliance measures to the latest developments. The FATF’s detailed list and initiatives underscore the ongoing global commitment to mitigating money laundering and terrorist financing risks, with a growing emphasis on both compliance flexibility and inclusivity in its mission to maintain financial integrity worldwide.
*DISCLAIMER: This article and its publication are intended to provide a brief introduction and act as a general guide. This is provided for information purposes only and cannot be utilized as a substitute for professional advice. This document does not represent a legal opinion and one must not rely on it without receiving independent advice based on the particular facts of its own case. No responsibility is accepted by the author or the publishers for any loss suffered from acting or refraining from acting based on the contents of this publication.
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