The FATF grey list (Jurisdictions Under Increased Monitoring) includes countries with identified AML/CTF deficiencies working with FATF to improve. The FATF blacklist (High-Risk Jurisdictions) currently identifies Iran, North Korea, and Myanmar — countries with serious systemic failures refusing to cooperate.
FATF Grey List vs Blacklist: Key Differences Explained
The Financial Action Task Force (FATF) publishes two lists that profoundly affect international banking, trade finance, and compliance. Understanding the difference between these lists is essential for businesses operating in high-risk jurisdictions or working with counterparties from affected countries. Countries on either list face significant banking restrictions, often overlapping with OFAC sanctions programs.
| Factor | Grey List | Blacklist |
|---|---|---|
| Official name | Jurisdictions Under Increased Monitoring | High-Risk Jurisdictions Subject to Call for Action |
| Countries (2026) | ~24 countries incl. Venezuela, Nigeria, Vietnam | Iran, North Korea, Myanmar |
| Level of risk | Elevated — enhanced due diligence required | Critical — enhanced measures mandatory |
| Banking impact | Correspondent banks apply EDD, possible delays | Transactions often refused outright |
| OFAC overlap | Venezuela, Syria also OFAC-targeted | Iran, North Korea also comprehensively OFAC-sanctioned |
| Exit mechanism | Demonstrate progress on FATF action plan | Full resolution of systemic AML/CTF failures |
The FATF Blacklist (2026): Iran, North Korea, Myanmar
The FATF blacklist — formally the “High-Risk Jurisdictions Subject to a Call for Action” — currently includes Iran, North Korea, and Myanmar. These jurisdictions have systemic AML/CTF deficiencies and have either failed to engage with FATF or refused to implement required reforms. FATF calls on its member states to apply enhanced due diligence and, in the most serious cases, countermeasures that effectively restrict financial transactions.
Critically, Iran and North Korea also face comprehensive OFAC sanctions — meaning businesses encounter dual prohibition: FATF-mandated countermeasures plus U.S. sanctions prohibitions. This makes transactions with these jurisdictions exceptionally high risk.
The FATF Grey List (2026): Jurisdictions Under Increased Monitoring
The grey list currently includes approximately 24 jurisdictions that have committed to resolving identified AML/CTF deficiencies within agreed timeframes. Being grey-listed does not mean transactions are prohibited, but it triggers enhanced due diligence obligations for counterparties and correspondent banks.
Grey-listed jurisdictions in 2026 include Venezuela, Nigeria, Philippines, Vietnam, Yemen, and others. Always verify the current list at fatf-gafi.org — FATF updates its lists three times per year after plenary sessions in February, June, and October.
How FATF Listing Affects Your Business
FATF grey listing creates immediate practical obstacles even where transactions are not prohibited. Correspondent banks apply enhanced due diligence (EDD), often demanding additional documentation, source-of-funds evidence, and transaction explanations. Processing times increase. Some banks restrict or refuse transfers outright, even without a legal obligation to do so.
Trade finance, insurance, and letters of credit involving grey-listed jurisdictions are similarly affected. For businesses operating in or with these countries, understanding your compliance obligations is essential. Our OFAC and sanctions compliance lawyers advise on FATF-related due diligence requirements across 40+ jurisdictions.
FATF Listing and OFAC Sanctions: How They Interact
FATF listing and OFAC sanctions are legally separate regimes administered by different bodies. FATF is an intergovernmental organization; OFAC is a U.S. government agency. However, they frequently converge: Iran and North Korea appear on both the FATF blacklist and face comprehensive OFAC sanctions. Venezuela appears on the FATF grey list and faces targeted OFAC sanctions on PDVSA and government officials.
For businesses, both regimes must be assessed independently. A transaction may be FATF-compliant but OFAC-prohibited, or vice versa. Our international sanctions lawyers provide comprehensive dual-regime analysis. Contact us for a free consultation.