Updated FATF Lists: High-Risk and Under-Monitoring Jurisdictions

The Latest High-Risk and Enhanced Surveillance Areas by the FATF – What Are the Implications for Me as an Obligated Entity?

The Financial Action Task Force (FATF), the leading global oversight authority for combating money laundering and terrorism financing, updated its lists of jurisdictions considered high-risk or under enhanced monitoring on 23 February 2024. For professionals and institutions, it is crucial to understand and adjust to these changes to ensure necessary AML compliance.

High-Risk Jurisdictions: A Call for Immediate Action

High-risk jurisdictions are those with significant strategic deficiencies that pose a serious threat to the integrity of the financial system.
The current high-risk jurisdictions (blacklist) include:

• Democratic People's Republic of Korea (DPRK)

• Iran

• Myanmar

Jurisdictions Under Enhanced Surveillance (Greylist)

The FATF also identifies jurisdictions under enhanced surveillance, known as the “Greylist”. These countries have committed to resolving their strategic AML/CFT deficiencies within agreed timelines and are subject to enhanced FATF monitoring.
The jurisdictions currently under enhanced surveillance include:

• Bulgaria

• Burkina Faso

• Cameroon

• Croatia

• Democratic Republic of Congo

• Haiti

• Jamaica

• Mali

• Mozambique

• Nigeria

• Philippines

• Senegal

• South Africa

• South Sudan

• Syria

• Tanzania

• Turkey

• Vietnam

• Yemen

What Are the Implications for Me as an Obligated Entity?

The latest updates from the FATF highlight the ongoing challenges in combatting money laundering and terrorism financing on a global scale. For AML-relevant entities and professionals, it is critical to remain informed and proactively implement effective AML/CFT measures. Annex 1 of the AML Act directly refers to FATF ratings in explaining risk factors for low and high-risk mandates or clients. The Real Estate AML Reporting Regulation (GwGMeldV-Immobilien) also explicitly references these ratings.

A comprehensive risk analysis requires the inclusion of various data sources and the regular updating of underlying ratings for new and existing clients and business relationships. With Legalian, we take these tasks off your hands. We create the risk analysis based on global crime and terrorism indices, sanctions and PEP lists, and FATF criteria for money laundering, saving you from burdensome research work.

You can find the complete “Blacklist” and “Greylist” here: Black and grey lists