Changes to the FATF Black List and Grey Lists – October 2025 Update

On 24 October the Financial Action Task Force (FATF) published its latest list of high-risk jurisdiction subject to a Call for Action (the “Black List”) and jurisdictions under Increased Monitoring (the “grey list”).

The FATF Black List – no change

There have been no additions or removals to the FATF Black List – the list remains as:

• North Korea – FATF highlights ongoing use of front and shell companies and complex ownership structures to evade sanctions.
• Iran – Has not implemented most of its FATF action plan since 2016. Due to UN Security Council concerns over nuclear non-compliance, the FATF urges all jurisdictions to mitigate proliferation financing risks linked to Iran.
• Myanmar – because of “significant strategic deficiencies” in its anti‑money‑laundering (AML), counter‑terrorist‑financing (CFT), and proliferation‑financing regime

FATF Grey List – removals only

There have been changes to the FATF ‘Grey List’

Removed from the Grey List:

• Burkina Faso
• Mozambique
• Nigeria
• South Africa

New additions to the Grey List:

• None

The following countries remain on the Grey List:

Algeria, Angola, Bolivia, Bulgaria, Cameroon, Côte d’Ivoire, Democratic Republic of the Congo, Haiti, Kenya, Lao PDR, Lebanon, Monaco, Namibia, Nepal, South Sudan, Syria, Venezuela, Vietnam, Virgin Islands (UK), Yemen

Continued implications for law firms

Despite no additions to either the Black or Grey lists, law firms should continue to

• Screen clients, beneficial owners, and transactions linked to these countries.
• Apply enhanced due diligence and intensive source of funds and source of wealth investigations in every case.
• Update your Firm Wide Risk Assessment and AML policy, controls and procedures to reflect the changes
• Ensure your AML PCPs require MLRO authorisation when the firm is instructed by someone established in a black or grey list country.
• Send a communication to your team to alert them to the October FATF changes (and whenever there are future changes to the FATF lists)
• Stay updated on FATF lists to manage legal, regulatory and financial risks effectively.

For a more detailed action list, please revisit our article from June’s Compliance Lifeline here.