Update to the FATF ‘at risk’ countries

IPA Insolvency Practitioner newsletter AML Digest, December 2025

FATF is the Financial Action Task Force and leads global action to tackle money laundering and terrorist and proliferation financing.

Three times a year (February, June & October) FATF hold a plenary session to consider jurisdictions that require increased monitoring (the ‘grey list’) and high-risk jurisdictions subject to a call for action (the ‘black list’).

Updates have been published from the October 2025 plenary session. There is no change to the black-listed countries which remain North Korea, Iran and Myanmar. Details of FATF findings on these countries can be found here.

There have been changes made to the grey list countries. Burkina Faso, Mozambique, Nigeria and South Africa have been removed from the grey-list. There are no new additions to the list. Full details are available here.

Consideration of the FATF lists is required per Reg 33(3)(a) of the MLR17 (as amended) where the existence of a high risk third country is a prompt to conduct Enhanced Due Diligence before or during a proposed appointment.