FATF removes four countries from anti-money laundering 'grey list' in October 2026 review

On October 30, 2026, the Financial Action Task Force removed Bulgaria, Cote d'Ivoire, the Democratic Republic of the Congo, and Monaco from its grey list following anti-money laundering reforms. However, FATF retained Vietnam on the grey list with explicit warnings of further action without improvements. Meanwhile, Iran, North Korea, and Myanmar remain on FATF's black list. FinCEN issued guidance instructing U.S. financial institutions to adjust risk procedures while cautioning against indiscriminate de-risking.

Removal of four countries from the grey list

• ▪Monaco Minister of State Christophe Mirmand stated that the Financial Action Task Force decision recognized more than two years of rigorous, coordinated work by Monaco state authorities.
• ▪The FATF removed Bulgaria, Cote d'Ivoire, the Democratic Republic of the Congo, and Monaco from its list of jurisdictions under increased monitoring
• ▪Democratic Republic of the Congo Finance Minister Doudou Roussel Fwamba Likunde Li-Botayi stated that removal from the grey list is expected to reduce cross-border transaction costs and support correspondent banking relationships.

Vietnam retained on the grey list

• ▪The Financial Action Task Force retained Vietnam on its anti-money laundering grey list during the October 2026 plenary review, expressing concern over slow reform progress.
• ▪The Financial Action Task Force warned that it will consider next steps if Vietnam fails to make tangible improvements to rectify strategic deficiencies before the next plenary meeting.

FATF High-risk list designations

• ▪The Financial Action Task Force maintained Iran, North Korea, and Myanmar on its high-risk list subject to a call for action during the October 2026 review.
• ▪The Financial Action Task Force continues to call on member jurisdictions to impose effective countermeasures on North Korea.

FATF calls and lobbying regarding Myanmar

• ▪The Financial Action Task Force renewed its call for Myanmar to crack down on widespread fraud and scam operations operating within the country.
• ▪Japan lobbied the Financial Action Task Force prior to the October 2026 review to remove Myanmar from the black list to facilitate business operations.

FATF countermeasures against Iran

• ▪The Financial Action Task Force specified countermeasures requiring jurisdictions to restrict business relationships, limit virtual asset transactions, and prohibit new correspondent banking relationships with Iranian entities.
• ▪The Financial Action Task Force called on member jurisdictions to apply four specific countermeasures against Iran, including prohibiting Iranian financial institutions from establishing overseas branches or representative offices.

FinCEN Guidance for US financial institutions

• ▪On October 30, 2026, FinCEN instructed U.S. financial institutions to update their risk-based policies and correspondent account due diligence programs following the Financial Action Task Force's list updates.
• ▪FinCEN reminded money services businesses of obligations under Interpretive Release 2004-1 to establish anti-money laundering controls commensurate with risks posed by foreign agents and counterparties.
• ▪FinCEN advised U.S. financial institutions that risk-based due diligence requirements should not be used as a basis for wholesale or indiscriminate de-risking of foreign customers.

FinCEN Iranian account prohibitions

• ▪FinCEN regulations prohibit foreign financial institutions from using correspondent accounts at covered U.S. institutions to process transactions involving Iranian financial institutions.
• ▪FinCEN designated Iran as a primary money laundering concern on October 25, 2019, prohibiting U.S. financial institutions from maintaining correspondent accounts for Iranian financial institutions under Section 311 of the USA PATRIOT Act.

U.S. sanctions on Iran

• ▪On February 4, 2025, the U.S. President issued National Security Presidential Memorandum-2 ordering maximum pressure on Iran to end its nuclear program and curtail ballistic missile development.
• ▪Under Executive Order 13599 and federal regulations, property and interests in property of the Iranian government and Iranian financial institutions remain blocked.