Quick Answer: FATF Grey List & Blacklist Countries (2026)
As of the February 2026 FATF Plenary, the FATF blacklist (High-Risk Jurisdictions subject to a Call for Action) contains 3 countries: Iran, North Korea (DPRK), and Myanmar. The FATF grey list (Jurisdictions under Increased Monitoring) contains 23 countries, with Kuwait and Papua New Guinea newly added in February 2026. These lists are updated three times a year and carry serious consequences for businesses, banks, and individuals conducting international transactions.
What Is the FATF? Organization Overview
The Financial Action Task Force (FATF) is an intergovernmental body founded in 1989 by the G7 Summit in Paris. Originally created to combat money laundering, FATF expanded its mandate after the September 11, 2001 attacks to include counter-terrorism financing (CTF), and in 2012 added counter-proliferation financing (CPF) — targeting the financing of weapons of mass destruction.
Today, FATF has 40 member jurisdictions plus 2 regional organizations, representing the world’s major financial centers. It sets the globally recognized 40 Recommendations — the international standard for anti-money laundering (AML) and counter-terrorism financing frameworks. Compliance with these standards is assessed through mutual evaluations conducted by FATF and FATF-Style Regional Bodies (FSRBs).
FATF publishes its blacklist and grey list following each Plenary session, held approximately three times per year — in February, June, and October. These lists are among the most consequential publications in global finance, directly affecting banking relationships, investment flows, and compliance obligations worldwide.
Critically, FATF itself has no enforcement powers — it cannot impose sanctions or penalties. Instead, it relies on member states and their financial regulators to act on FATF’s findings. The real impact comes from the compliance programs of banks, payment processors, and financial institutions that use FATF lists as the basis for risk assessments and due diligence requirements. Our AML lawyers help clients navigate these compliance requirements at every stage.
FATF Blacklist 2026 — High-Risk Jurisdictions (Call for Action)
The FATF blacklist — officially titled “High-Risk Jurisdictions subject to a Call for Action” — identifies countries with critical, unresolved strategic deficiencies in their AML/CFT/CPF regimes that are failing to cooperate with FATF to address these deficiencies. FATF calls on member states and the global financial community to apply counter-measures — the most severe available financial restrictions — against blacklisted jurisdictions.
As of the February 2026 FATF Plenary, the blacklist contains three countries. There have been no additions or removals since Myanmar was added in 2022:
| Country | On List Since | Key Deficiencies | Response Level |
|---|---|---|---|
| 🇮🇷 Iran | Continuously since 2008 | Failure to criminalize terrorist financing; unresolved CTF risks; non-compliance with UN Security Council resolutions; proliferation financing concerns | Counter-measures required; refuse subsidiaries/branches of Iranian institutions |
| 🇰🇵 North Korea (DPRK) | Continuously | Weapons of mass destruction (WMD) proliferation financing; systematic evasion of international sanctions; no effective AML/CFT regime; state-sponsored cyber theft | Strongest counter-measures; comprehensive financial isolation |
| 🇲🇲 Myanmar (Burma) | October 2022 | Military coup in 2021 dismantled existing AML/CFT framework; failure to address FATF action plan items; deteriorating institutional capacity; narcotics trafficking risks | Counter-measures required; enhanced scrutiny on all transactions |
What Happens When a Country Is on the FATF Blacklist?
Blacklisted countries face the most severe consequences in the international financial system. FATF explicitly calls on members to apply countermeasures — which in practice means:
- Banks are required to apply enhanced due diligence (EDD) or refuse correspondent banking relationships entirely
- Financial institutions must reject or severely restrict transactions involving blacklisted country entities
- Payment processors often block transactions to/from these jurisdictions automatically
- Investment funds typically prohibit any exposure to blacklisted country assets
- Trade finance becomes extremely difficult as banks refuse to issue letters of credit
For Iran and North Korea, FATF listing also overlaps with comprehensive OFAC Iran sanctions and UN Security Council sanctions, creating a compounded compliance burden.
FATF Grey List Countries 2026 — Full List (23 Jurisdictions)
The FATF grey list — officially “Jurisdictions under Increased Monitoring” — identifies countries that have strategic deficiencies in their AML/CFT frameworks but are actively working with FATF to address them under an agreed action plan. Grey-listing triggers mandatory enhanced due diligence (EDD) requirements globally.
As of the February 2026 FATF Plenary, the grey list contains 23 jurisdictions:
| Country / Territory | Date Added | Primary AML/CFT Concerns |
|---|---|---|
| 🇩🇿 Algeria | October 2023 | Deficiencies in AML supervision, beneficial ownership transparency, and financial intelligence unit effectiveness |
| 🇦🇴 Angola | June 2023 | Weak AML framework; limited beneficial ownership reporting; deficiencies in the oil sector-related financial flows |
| 🇧🇴 Bolivia | June 2025 | AML/CFT compliance deficiencies; narcotics trafficking proceeds risks; gaps in financial sector supervision |
| 🇧🇬 Bulgaria | October 2023 | Weaknesses in financial sector AML supervision; organized crime links; insufficient prosecution of high-level money laundering |
| 🇨🇲 Cameroon | June 2023 | Insufficient AML/CFT measures in the financial sector; weak beneficial ownership framework; limited international cooperation |
| 🇨🇮 Côte d’Ivoire | June 2023 | Deficiencies in AML supervision and law enforcement; gaps in cash transaction monitoring |
| 🇨🇩 DR Congo (DRC) | June 2022 | Weak AML/CFT institutional framework; informal economy dominance; conflict minerals and resource extraction financing risks |
| 🇭🇹 Haiti | June 2020 | Political instability severely impairs AML/CFT implementation; gang-related financial flows; limited institutional capacity |
| 🇰🇪 Kenya | February 2024 | Gaps in beneficial ownership, real estate sector AML, and virtual asset regulation; trade-based money laundering risks |
| 🇰🇼 Kuwait 🆕 | February 2026 (NEW) | AML supervision gaps; deficiencies in financial sanctions implementation; delays in asset freezing procedures; weak cash transaction monitoring |
| 🇱🇦 Laos (Lao PDR) | June 2022 | High corruption and narcotics trafficking risks; weak AML regime; casino and special economic zone financial risks |
| 🇱🇧 Lebanon | June 2024 | Banking sector crisis undermining AML enforcement; political deadlock impeding reform; Hezbollah-related financing risks |
| 🇲🇨 Monaco | June 2024 | Deficiencies in supervision of designated non-financial businesses (real estate, lawyers, accountants); high-value asset risks |
| 🇳🇦 Namibia | February 2024 | Emerging virtual asset risks; gaps in AML/CFT supervision in the financial sector; limited beneficial ownership framework |
| 🇳🇵 Nepal | June 2020 | Deficiencies in beneficial ownership transparency; correspondent banking oversight; remittance sector vulnerabilities |
| 🇵🇬 Papua New Guinea 🆕 | February 2026 (NEW) | Poor inter-agency coordination; asset recovery failures from corruption and illegal logging; AML/CFT framework deficiencies; informal sector risks |
| 🇸🇳 Senegal | June 2021 | Gaps in AML supervision, particularly in real estate, gold, and informal sectors; limited prosecutions for money laundering |
| 🇸🇸 South Sudan | June 2021 | Severe AML/CFT weaknesses due to ongoing conflict and institutional fragility; virtually no functioning financial compliance infrastructure |
| 🇸🇾 Syria | February 2010 | Conflict-related collapse of financial oversight institutions; terrorism financing risks; informal value transfer dominance |
| 🇻🇪 Venezuela | February 2020 | Corruption, narco-state financial flows, lack of AML enforcement; gold and cryptocurrency used to evade international sanctions |
| 🇻🇳 Vietnam | June 2023 | Gaps in AML supervision and beneficial ownership transparency; real estate sector risks; limited prosecution track record |
| 🇻🇬 British Virgin Islands | June 2025 | Offshore financial center risks; deficiencies in beneficial ownership registers; shell company abuse vulnerabilities |
| 🇾🇪 Yemen | October 2010 | Houthi-related terrorism financing; AML framework collapse due to ongoing conflict; international financial exclusion |
Countries Added and Removed: 2025–2026 FATF List Changes
FATF list changes reflect the international community’s judgment on whether countries are making genuine progress on AML/CFT reforms. The most recent plenary sessions produced significant changes:
February 2026 — Countries Added to Grey List
- 🇰🇼 Kuwait — Added due to deficiencies in financial sanctions implementation, delays in asset freezing, and inadequate monitoring of cash transactions and remittances.
- 🇵🇬 Papua New Guinea — Added for poor inter-agency coordination in AML/CFT matters, failure to recover assets from corruption and illegal logging proceeds, and underdeveloped compliance infrastructure.
October 2025 — Countries Removed from Grey List
- 🇧🇫 Burkina Faso — Successfully completed its FATF action plan despite significant security challenges in the Sahel region.
- 🇲🇿 Mozambique — Made sufficient progress on AML/CFT reforms, particularly in banking sector supervision and beneficial ownership frameworks.
- 🇳🇬 Nigeria — Africa’s largest economy completed its FATF commitments, improving AML prosecutions and financial intelligence capacity.
- 🇿🇦 South Africa — After significant controversy over its 2023 listing, South Africa successfully reformed its AML framework, leading to removal after approximately two years on the list.
June 2025 — Countries Added
- 🇧🇴 Bolivia — Added for AML/CFT compliance deficiencies and narcotics trafficking-related financial risks.
- 🇻🇬 British Virgin Islands — Added for offshore sector risks and beneficial ownership deficiencies.
June 2025 — Countries Removed
- 🇭🇷 Croatia — Removed after completing reforms to its AML framework and strengthening financial supervision, ahead of its EU membership obligations.
- 🇲🇱 Mali — Removed after completing its action plan commitments.
- 🇹🇿 Tanzania — Removed after demonstrating improved AML/CFT capacity and completing agreed reforms.
Business Impact — What FATF Grey and Black List Status Means for You
For businesses, investors, and individuals operating internationally, FATF list status of a counterparty country creates tangible compliance burdens and financial risks. Understanding these consequences is essential for risk management.
Impact of FATF Blacklist Status
Dealing with entities in blacklisted countries (Iran, North Korea, Myanmar) triggers the most severe compliance and legal consequences:
- Correspondent banking refusals: Major banks will typically refuse to process payments to/from blacklisted jurisdictions, making international transfers effectively impossible through conventional banking channels.
- Trade finance blockages: Letters of credit, documentary collections, and trade guarantees involving blacklisted countries are routinely rejected by international banks.
- Investment exclusions: Institutional investors (pension funds, insurance companies, sovereign wealth funds) maintain absolute exclusions for blacklisted country assets.
- Sanctions overlap: For Iran and North Korea, FATF blacklist status is compounded by comprehensive OFAC sanctions and EU autonomous sanctions, creating multi-jurisdictional legal exposure for any transaction.
- Criminal liability risk: In many jurisdictions, conducting transactions with blacklisted country entities without proper licenses can constitute criminal AML or sanctions offenses.
Impact of FATF Grey List Status
Grey list status creates a more nuanced but still significant set of consequences:
- Mandatory Enhanced Due Diligence (EDD): Financial institutions worldwide are required to apply EDD to transactions involving grey-listed country entities. This means more documentation, longer processing times, and higher fees.
- Correspondent banking de-risking: Some banks proactively exit grey-listed country markets entirely rather than managing the compliance burden — a phenomenon known as “de-risking.”
- Increased transaction delays: Payments to/from grey-listed countries take longer to process as banks conduct enhanced screening and documentation reviews.
- Higher compliance costs: Businesses in grey-listed countries face elevated compliance costs for international operations, including legal fees, due diligence costs, and premium banking fees.
- Reputational risk: Association with grey-listed country entities can create reputational concerns for multinational companies, particularly in regulated industries.
- Investment impact: IMF and World Bank research indicates grey-listing correlates with GDP reductions of 1-3% and significant decreases in foreign direct investment.
FATF vs. OFAC Sanctions — Key Differences
The FATF blacklist and OFAC sanctions are frequently confused, but they are fundamentally different tools with different legal implications. Understanding the distinction is critical for compliance officers and businesses operating internationally.
| Criterion | FATF Blacklist / Grey List | OFAC Sanctions Programs |
|---|---|---|
| Issuing Authority | Intergovernmental body (FATF) — 40 member states | US Treasury Department (OFAC) — unilateral US authority |
| Legal Effect | No direct legal prohibition; triggers compliance obligations in member states | Direct legal prohibition for US persons; violations are criminal offenses |
| Who Is Listed | Countries/jurisdictions only | Countries, individuals, entities, vessels — anyone on the SDN List |
| Geographic Scope | Global — affects all jurisdictions following FATF standards | Primarily US persons and USD transactions; extraterritorial reach via secondary sanctions |
| Response Required | Enhanced Due Diligence (EDD) for grey list; counter-measures for blacklist | Complete prohibition on transactions; asset freezing; reporting to OFAC |
| Overlap | Iran, North Korea are on both FATF blacklist AND OFAC comprehensive sanctions | Many OFAC-sanctioned entities/countries are also subject to FATF-related EDD |
| Penalties for Non-Compliance | Regulatory action by national financial supervisors; loss of banking relationships | Civil penalties up to millions per violation; criminal prosecution; debarment |
| Updates | Three times per year (February, June, October) | Continuously — additions/removals to SDN List occur daily |
Our OFAC lawyers regularly advise clients on navigating both FATF requirements and OFAC sanctions simultaneously — a situation increasingly common for companies doing business in the Middle East, Africa, and Southeast Asia.
How a Sanctions Lawyer Can Help
Whether your business deals with grey-listed or blacklisted countries — or you’ve discovered an unexpected compliance issue — our international sanctions and AML lawyers provide practical, results-oriented counsel across a full range of FATF and sanctions-related matters:
- FATF Compliance Risk Assessments: We evaluate your existing transactions and business relationships against current grey and black lists, identifying exposure before regulators do.
- Enhanced Due Diligence (EDD) Procedures: We design and implement EDD frameworks that satisfy FATF-based requirements while minimizing operational burden. Our OFAC compliance checklist provides a practical starting point for businesses assessing their AML/sanctions exposure.
- OFAC License Applications: For businesses with legitimate dealings in sanctioned/high-risk jurisdictions, we prepare and submit OFAC specific license applications. Our Iran sanctions license practice is particularly active for clients with pre-existing business relationships.
- Sanctions Screening Program Development: We build practical, risk-based screening programs covering FATF lists, OFAC SDN, EU Consolidated List, and UN sanctions.
- Voluntary Self-Disclosure: If a compliance breach has already occurred, early voluntary disclosure to OFAC or the relevant national regulator can significantly reduce penalties. We guide clients through this process.
- Correspondent Banking Issues: We represent clients in disputes with banks that have de-risked based on FATF considerations, including formal complaints and alternative banking solutions.
- AML Internal Investigations: When financial institutions suspect money laundering involving high-risk jurisdictions, we conduct internal investigations and manage regulatory interactions.
⚠️ Is Your Business Exposed to FATF High-Risk Countries?
If you have clients, counterparties, or transactions involving any of the 23 grey-listed countries or 3 blacklisted countries, you need a comprehensive compliance review. Missing EDD requirements or inadvertently violating sanctions can result in regulatory action, loss of banking relationships, and in serious cases, criminal liability.
Frequently Asked Questions (FAQ)
What is the difference between the FATF grey list and the FATF blacklist?
The FATF blacklist (High-Risk Jurisdictions subject to a Call for Action) identifies countries with critical, unresolved AML/CFT deficiencies that are not cooperating with FATF. Currently, these are Iran, North Korea, and Myanmar. FATF calls for counter-measures — the strongest available restrictions — against blacklisted countries.
The FATF grey list (Jurisdictions under Increased Monitoring) identifies countries with significant deficiencies that are actively working with FATF to resolve them under an agreed action plan. Grey list status triggers Enhanced Due Diligence (EDD) requirements but not outright prohibitions. As of February 2026, 23 countries are on the grey list.
Which countries are on the FATF grey list in 2026?
As of the February 2026 FATF Plenary, the 23 countries on the FATF grey list are: Algeria, Angola, Bolivia, Bulgaria, Cameroon, Côte d’Ivoire, DR Congo, Haiti, Kenya, Kuwait (newly added February 2026), Laos, Lebanon, Monaco, Namibia, Nepal, Papua New Guinea (newly added February 2026), Senegal, South Sudan, Syria, Venezuela, Vietnam, British Virgin Islands, and Yemen.
What does FATF grey list status mean for my business?
If you conduct transactions with entities in FATF grey-listed countries, you face several practical consequences: your bank is required to apply Enhanced Due Diligence (EDD) on those transactions, meaning more documentation requests, longer processing times, and potentially higher fees. Some banks engage in “de-risking” and exit grey-listed country markets altogether, making banking services harder to access. Your compliance program must include specific risk assessments and monitoring for grey-listed country counterparties. Failure to apply required EDD can result in regulatory sanctions from your national financial supervisor. Working with an AML compliance lawyer helps you build the right procedures without over-restricting legitimate business.
How often does FATF update its grey list and blacklist?
FATF updates its lists three times per year, following each FATF Plenary session. The three annual update cycles are: February (typically in the second week of February), June (typically late June), and October (typically mid-to-late October). Countries can be added or removed at any plenary based on their progress or lack thereof in implementing the FATF action plan. It is important for compliance teams to review FATF list updates after each plenary and adjust their compliance procedures accordingly.
Are FATF sanctions the same as OFAC sanctions?
For businesses and individuals affected by FATF grey-listing, the practical consequences often extend to commercial screening databases. LSEG’s World-Check and similar tools may flag companies or individuals associated with grey-listed jurisdictions, leading to unexpected banking restrictions or account closures. If your profile has been incorrectly flagged, our team can assist with a World-Check Refinitiv dispute to correct inaccurate entries and restore your banking access.
No — FATF listing and OFAC sanctions are separate and distinct regimes. FATF is an intergovernmental standard-setting body; listing by FATF creates compliance obligations (EDD or counter-measures) but does not by itself constitute a legal prohibition. OFAC sanctions, issued by the US Treasury Department, are direct legal prohibitions for US persons and entities, with severe civil and criminal penalties for violations. Some countries appear on both lists (Iran, North Korea), but many OFAC-sanctioned individuals and entities are not from FATF-listed countries, and many FATF grey-listed countries are not subject to OFAC country-wide sanctions. Businesses need to comply with both frameworks independently. Our OFAC lawyers advise on both simultaneously.