FATF Grey List October 2025: Jurisdictions Under Review

October 2025 overview

The October 2025 update mattered because FATF removed four jurisdictions and left 19 under increased monitoring. For compliance teams, the main operational question was not whether every customer linked to a listed country should be rejected. The question was whether country-risk settings, customer review cadence, beneficial ownership checks, or monitoring rules needed to change.

Burkina Faso, Mozambique, Nigeria, and South Africa were removed from increased monitoring. Nineteen jurisdictions remained on the list, including recent additions such as Monaco, Namibia, Nepal, and the British Virgin Islands.

For an AML program, the right response was a risk-based review: identify affected customers, UBOs, counterparties, and payment corridors; decide whether the customer-risk assessment changed; and document why standard monitoring, closer monitoring, EDD, or no action was proportionate.

Why the October 2025 FATF update mattered

FATF does not directly regulate a bank, fintech, marketplace, or payments company. Its influence comes from the way supervisors, correspondent banks, payment partners, and regulated firms use FATF findings as part of country-risk assessment.

For an MLRO, the October 2025 grey-list update created three practical questions:

• Which customers, UBOs, counterparties, or payment corridors had exposure to countries that were removed or remained under increased monitoring?
• Did the country-risk change alter the customer-risk assessment, review cadence, or monitoring profile?
• Can the firm show why it chose standard monitoring, closer monitoring, EDD, or no action?

That is the compliance value of a historical FATF update: not just knowing which countries moved, but showing that the firm had a proportionate review process when the list changed.

FATF standards behind the grey-list process

The FATF 40 Recommendations are the baseline standards behind AML/CFT/CPF supervision. They matter to private-sector compliance teams because FATF assessments influence national rules, supervisor expectations, correspondent-bank risk appetite, and the way firms document country-risk decisions.

For an MLRO, the practical link is simple: FATF findings should feed the firm's country-risk methodology, customer-risk assessment, onboarding controls, ongoing monitoring, and escalation records.

Understanding the FATF grey list

FATF uses public statements to identify jurisdictions with strategic AML/CFT/CPF weaknesses. The two classifications matter for compliance teams because they have different operational consequences:

• Jurisdictions under Increased Monitoring, commonly called the grey list.
• High-Risk Jurisdictions subject to a Call for Action, often called the black list.

What increased monitoring means

Increased monitoring means the jurisdiction has committed to work with FATF or a FATF-style regional body to address identified strategic deficiencies. FATF monitors progress against an action plan and may later conduct an on-site assessment before removal.

FATF does not call for automatic enhanced due diligence for every grey-listed jurisdiction. For firms, the practical response is to use grey-list status as a country-risk input, then decide whether the specific customer, UBO, counterparty, corridor, or activity needs a change in controls.

Grey list vs call-for-action list

• Grey list: a monitoring and remediation process for jurisdictions that have committed to address deficiencies.

• Call-for-action list: a higher-risk classification where FATF calls for enhanced due diligence and, in the most serious cases, countermeasures.

October 2025 grey-list update

The October 2025 FATF plenary removed four jurisdictions from increased monitoring and left 19 jurisdictions on the list.

Key developments

The main outcome was the removal of four African countries from the grey list.

• Jurisdictions Removed: Burkina Faso, Mozambique, Nigeria, and South Africa are no longer subject to increased monitoring by the FATF. These de-listings followed successful on-site visits that confirmed the sustainability of the reforms undertaken by each country to strengthen their AML/CFT/CPF regimes.
• Jurisdictions Added/Remaining: No new jurisdictions were added to the grey list during this plenary session. The list now comprises 19 jurisdictions that remain under increased monitoring. During the plenary, the FATF reviewed the progress of Algeria, Angola, Bulgaria, Cameroon, Côte d'Ivoire, the Democratic Republic of the Congo, Kenya, Lao PDR, Monaco, Namibia, Nepal, South Sudan, Syria, Venezuela, and Vietnam. Five other jurisdictions—Bolivia, Haiti, Lebanon, the Virgin Islands (UK), and Yemen—chose to defer their reporting, so their status remained unchanged from previous FATF statements.

Jurisdictional notes

The notes below summarize the jurisdictions that remained under increased monitoring after the October 2025 plenary. They are historical notes, not a live country-risk list.

Algeria

Algeria was added to the grey list in October 2024 and made a high-level political commitment to work with the FATF and the Middle East and North Africa Financial Action Task Force (MENAFATF) to strengthen its AML/CFT regime. Its action plan is centered on two key areas: (1) improving risk-based supervision, particularly for higher-risk sectors, through enhanced inspections and the application of effective, proportionate, and dissuasive sanctions; and (2) developing an effective legal and operational framework for ensuring access to adequate, accurate, and up-to-date basic and beneficial ownership information. As of the October 2025 review, the FATF noted that Algeria has taken "significant steps" towards improving its regime, with progress on some action items occurring ahead of schedule. These early achievements include the adoption of new supervision procedures, risk assessments, and guidelines, as well as the establishment of a foundational legal framework for beneficial ownership.

Angola

Angola was also placed under increased monitoring in October 2024, committing to work with the FATF and the Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG). The jurisdiction's action plan focuses on three primary deficiencies: (1) enhancing its national understanding of money laundering and terrorist financing (ML/TF) risks; (2) improving risk-based supervision of both financial and non-financial entities, including DNFBPs; and (3) ensuring that competent authorities have adequate, accurate, and timely access to beneficial ownership information. The October 2025 statement confirms that Angola is actively working with the FATF to implement this action plan.

Bolivia

Bolivia was added to the grey list in June 2025, making a high-level political commitment to work with the FATF and the Financial Action Task Force of Latin America (GAFILAT). Its action plan is designed to address deficiencies in its investigative and supervisory frameworks, including: (1) ensuring that relevant special investigative techniques can be utilized for ML investigations; (2) implementing risk-based supervision for high-risk DNFBPs such as real estate agents, lawyers, accountants, and dealers in precious metals and stones (DPMS); and (3) ensuring that beneficial ownership information is adequate, accurate, and accessible in a timely manner. For the October 2025 Plenary, Bolivia chose to defer reporting on its progress. The FATF's previous statement from June 2025, issued at the time of its listing, had acknowledged that Bolivia had already made significant progress on the recommended actions from its December 2023 Mutual Evaluation Report (MER), including enhancing its ML/TF risk understanding and strengthening the production and dissemination of financial intelligence.

Bulgaria

Bulgaria has been under increased monitoring since October 2023, working with the FATF and the Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism (MONEYVAL). Its action plan is focused on improving the effectiveness of its enforcement outcomes, specifically by: (1) addressing remaining technical compliance deficiencies related to the confiscation of criminal assets; and (2) improving the investigation and prosecution of different types of money laundering in a manner consistent with the country's risk profile. In its October 2025 statement, the FATF noted that while Bulgaria has continued to make progress across its action plan, all agreed-upon deadlines have now expired and significant work remains. The FATF encouraged Bulgaria to build on its recent progress and expedite the implementation of its action plan, with a particular emphasis on its efforts to investigate and prosecute money laundering more effectively.

Cameroon

Cameroon was placed on the grey list in February 2023 and is working with the FATF and the Action Group against Money Laundering in Central Africa (GABAC). Its action plan addresses a broad range of deficiencies, including the need to enhance its national understanding of ML/TF risks, improve international cooperation, strengthen risk-based supervision, ensure transparency of beneficial ownership, and increase the effectiveness of its FIU and law enforcement agencies in investigating financial crimes. The October 2025 update confirms that Cameroon is continuing to make progress on implementing its action plan.

Côte d'Ivoire

Côte d'Ivoire was added to the grey list in October 2024, committing to work with the FATF and the Inter-Governmental Action Group against Money Laundering in West Africa (GIABA). The core elements of its action plan include: (1) improving the implementation of risk-based supervision for both financial institutions and DNFBPs; and (2) enhancing the use of financial intelligence by law enforcement authorities and improving the quality of disseminations from its FIU. Since its listing, Côte d'Ivoire has already taken steps to improve its AML/CFT regime, notably by enhancing its use of international cooperation in ML/TF investigations and prosecutions.

Democratic Republic of the Congo (DRC)

The DRC has been under increased monitoring since October 2022. Its action plan requires it to: (1) finalize and implement a risk-based supervision plan for its financial sector; (2) build capacity to identify and investigate TF activities in line with its risk profile; and (3) demonstrate the effective implementation of targeted financial sanctions related to both terrorist financing and proliferation financing. In its October 2025 statement, the FATF acknowledged that the DRC has continued to make progress across its action plan. However, a critical issue is that all of its agreed-upon deadlines have now expired, and substantial work remains to be completed. The FATF has strongly encouraged the DRC to continue implementing its action plan to address the remaining strategic deficiencies as soon as possible.

Haiti

Haiti has been on the grey list since June 2021, working with the FATF and the Caribbean Financial Action Task Force (CFATF). Its action plan addresses systemic deficiencies across its AML/CFT framework, including the need to complete and disseminate its ML/TF risk assessment, implement risk-based supervision, address legal and practical obstacles to accessing beneficial ownership information, and improve the quality of financial intelligence to support investigations. Haiti chose to defer reporting for the October 2025 Plenary. The previous statement from June 2025 noted that Haiti had taken some steps towards improvement, including the implementation of risk-based AML/CFT supervision for all financial institutions. Progress is likely hampered by the severe political and social instability in the country.

Kenya

Kenya was added to the grey list in February 2024. Its current action plan requires Kenya to work with the FATF and ESAAMLG to develop and implement an AML/CFT framework to address its identified deficiencies. The October 2025 update confirms that Kenya is actively working on its action plan.

Monaco

Monaco was added to the grey list in June 2024, a significant development for a major European financial center. Its initial MER, adopted in December 2022, found that while technically compliant in many areas, major improvements were needed in the effectiveness of its supervision, ML investigations, and confiscation of criminal proceeds. Monaco's action plan therefore focuses on demonstrating results, requiring it to: (1) enhance the application of sanctions for AML/CFT breaches; (2) strengthen the timeliness of suspicious transaction reporting (STRs); and (3) apply effective, dissuasive, and proportionate sanctions for money laundering convictions. At the October 2025 plenary, FATF recognized significant improvements by Monaco, including more international-cooperation activity and more resources for its FIU and prosecutorial authorities.

Namibia

Namibia returned to the grey list in February 2024, driven by concerns over the effective implementation of its AML/CFT standards. Its 2022 MER had identified weaknesses, including an underdeveloped understanding of TF risks and a low number of prosecutions and convictions. The current action plan requires Namibia to work with ESAAMLG to strengthen risk-based supervision, enhance the human and resource capacities of competent authorities, and ensure timely access to accurate beneficial ownership information. The October 2025 FATF statement confirms that Namibia is working to implement its action plan.

Nepal

Nepal was added to the grey list in February 2025. The listing was prompted by regulatory weaknesses in the enforcement, investigation, and prosecution of financial crimes, as well as inadequate regulation of high-risk sectors such as cooperatives and real estate. Nepal's action plan, which it is implementing with the Asia/Pacific Group on Money Laundering (APG), requires it to: (1) improve its understanding of ML/TF risks; (2) implement effective risk-based supervision of high-risk sectors; (3) demonstrate an increase in ML investigations and prosecutions; and (4) demonstrate measures to identify, trace, and confiscate the proceeds of crime. As of October 2025, FATF noted that Nepal had taken some steps towards improving its regime.

South Sudan

South Sudan has been on the grey list since June 2021. It is working with ESAAMLG to address fundamental deficiencies in its financial crime framework. Its action plan requires implementation of an AML/CFT regime, addressing foundational elements of the FATF standards. The October 2025 update confirms that South Sudan continues to work on implementing its action plan.

Syria

Syria is one of the longest-standing jurisdictions under FATF monitoring, having been on a monitoring list since at least February 2010. It is working with MENAFATF to address systemic and deeply entrenched AML/CFT deficiencies, which are compounded by significant terrorist financing risks and the ongoing conflict in the region. The October 2025 statement confirms that Syria continues to work on its action plan.

Venezuela

Venezuela was added to the grey list in June 2024 and is working with CFATF. The listing followed weak results in its mutual evaluation, including serious effectiveness gaps across the AML/CFT regime. Its action plan focuses on addressing these fundamental gaps across its regime. The October 2025 report confirms that Venezuela is working to implement its action plan.

Vietnam

Vietnam was placed on the grey list in June 2023. Its 2022 MER identified key weaknesses in beneficial ownership transparency, supervision of DNFBPs, regulation of virtual assets, and a low rate of ML prosecutions. Its action plan, which it is implementing with the APG, requires Vietnam to address a wide range of issues, including: (1) increasing risk understanding and domestic coordination; (2) enhancing international cooperation; (3) implementing effective risk-based supervision; and (4) taking action to regulate virtual assets and virtual asset service providers (VASPs). As of October 2025, the FATF notes that Vietnam has taken "some steps" to improve its regime. Recent legislative and regulatory actions, such as the issuance of Circular 27 in September 2025, demonstrate a commitment to reform by tightening rules on CDD, risk assessment, and transaction reporting thresholds.

Virgin Islands (UK)

The British Virgin Islands (BVI) was added to the grey list in June 2025. The BVI's case illustrates FATF's focus on effectiveness: a jurisdiction can have a strong legal framework and still face increased monitoring if supervisors and law enforcement cannot show sufficient operational results. The listing was based purely on its lack of demonstrated effectiveness. Its action plan, therefore, does not focus on legal reforms but on producing tangible results. The BVI must work with the CFATF to: (1) improve the effectiveness of its risk-based supervision; (2) systematically pursue ML investigations and prosecutions in line with its risk profile; and (3) demonstrate an increase in the seizure and confiscation of criminal proceeds. The BVI chose to defer reporting for the October 2025 Plenary, but its government has expressed a high-level political commitment to complete the action plan within two years.

Yemen

Yemen has been under FATF monitoring since at least February 2010, making it one of the longest-tenured jurisdictions on the list. Its efforts to address systemic AML/CFT deficiencies are severely hampered by the ongoing conflict, humanitarian crisis, and fragmented governance. Yemen chose to defer reporting for the October 2025 plenary.

Lessons from de-listed jurisdictions

The October 2025 removals show what FATF expects before a jurisdiction exits increased monitoring: implemented reforms, evidence that controls work, and confirmation through an on-site review.

South Africa's exit from the grey list

"Major policy and institutional achievement"

South Africa's removal from the grey list in October 2025 followed nearly three years of increased monitoring and an on-site visit in July 2025. The point for compliance teams is not the politics of the de-listing. It is the evidence standard: FATF wanted to see implemented reforms and measurable AML/CFT outcomes.

South Africa's National Treasury described the removal as a "major policy and institutional achievement". It also warned against complacency. That warning matters for firms too: a country leaving the grey list can justify a country-risk review, but it should not automatically erase every customer-level risk factor.

Common factors in successful remediation plans

The same themes appear across many remediation plans:

• High-level political commitment: FATF action plans usually require visible government commitment, resourcing, and coordination between supervisors, FIUs, law enforcement, and prosecutors.
• Legislative and regulatory action: Countries often need to close technical compliance gaps through amended laws, regulations, guidance, or supervisory procedures.
• A Demonstrable Focus on Effectiveness: The ultimate objective is to prove that controls work in practice. Countries must be able to show an increase in the number and complexity of money laundering and terrorist financing investigations and prosecutions, and show that they are tracing, seizing, and confiscating proceeds of crime.
• Adequate Resource Allocation: Implementing an action plan is a resource-intensive endeavor. Success depends on dedicating significant and sustained financial and human resources to key institutions. This includes strengthening the analytical capacity of the FIU, providing advanced training and tools to law enforcement and prosecutors, and ensuring that supervisory bodies are adequately staffed to conduct effective risk-based supervision. Monaco's progress was explicitly linked to its investment in more human and technical resources for its FIU and judiciary.

Implications for financial institutions and businesses

The FATF list is not only a government-facing assessment. For banks, fintechs, payment firms, marketplaces, and other regulated businesses, a list change should trigger a practical review of country risk, customer exposure, monitoring rules, and evidence.

Practical EDD guidance for grey-list exposure

FATF does not call for automatic enhanced due diligence for every grey-listed jurisdiction. The practical requirement is more precise: firms should decide whether the customer's connection to the jurisdiction changes the total risk picture.

That decision may support no change, closer monitoring, targeted information gathering, EDD, senior review, or case escalation. The important point is to document the reasoning.

Integrating FATF list changes into compliance controls

To manage FATF list changes properly, firms should embed them into core compliance controls instead of treating them as occasional newsletter updates.

This is where software workflows matter. FATF changes should be traceable from list update to country-risk review, affected customers or counterparties, monitoring changes, case decisions, and audit evidence.

Future AML/CFT enforcement themes

Several themes from the 2025 cycle remained important for AML teams going into 2026: effectiveness, proportionality, beneficial ownership, payment transparency, virtual assets, and evidence that controls work in practice.

FATF priorities: effectiveness, risk-based controls, and technology

The FATF's strategic direction points towards several key priorities that will define the future of AML/CFT enforcement:

• Effectiveness over paper compliance: FATF continues to look for evidence that controls produce outcomes, not only that laws and policies exist.
• Risk-based controls: Firms should be able to show why controls are proportionate to the actual customer, product, geography, and transaction risk.
• Technology and data quality: Screening, transaction monitoring, case management, and audit evidence need reliable data and clear workflows.
• Virtual assets and payment transparency: VASP supervision and Recommendation 16 implementation remain important themes.

Grey-listing process and common misconceptions

Grey-listing is usually preceded by evaluation, observation, and action-plan engagement. For compliance teams, the operational point is not to speculate about politics; it is to track the official FATF status and translate list changes into proportionate control decisions.

The common mistakes are to treat grey-listing as a sanctions designation, to apply blanket customer rejection, or to leave no evidence showing why a customer review did or did not change.

Conclusion

The October 2025 FATF update remains useful as a historical reference because it shows how list changes should be handled operationally. Four jurisdictions were removed, 19 remained under increased monitoring, and firms needed to decide whether country-risk settings, customer reviews, monitoring rules, or evidence records should change.

For current country-risk decisions, use the live FATF grey-list reference page rather than this 2025 update.