June announcements
Following the FATF’s June 2025 announcement of changes to its Jurisdictions Under Increased Monitoring (also informally known as the “Grey List”), the Financial Crimes Enforcement Network (FinCEN) published updated guidance on the territories identified in the initial FATF publication and provided analyses on several countries classified as High Risk Jurisdictions Subject to a Call for Action (aka the “Black List”). As of 13 June 2025, Croatia, Tanzania, and Mali have officially been removed from the FATF’s grey list, whilst Bolivia and the British Virgin Islands have been added to the list.
What is the FATF?
Founded in 1989 by the Group of 7 (G7), the Financial Action Task Force (FATF) is an intergovernmental task force that functions as an international watchdog for global money laundering and terrorism financing.
The FATF regularly reviews countries with deficiencies in anti-money laundering (AML), financing of terrorism (CFT), and counter-proliferation financing (CPF) and works with them to improve their systems, to ensure they’re in line with and do not present a risk to the international finance system.
What is FinCEN?
The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury tasked with protecting financial systems from illegal activity by collecting and analysing financial data.
Black list and additional guidance
FinCEN’s June update also reiterated its position on several countries included on the black list – namely the Democratic People’s Republic of Korea (DPRK), Iran, and Burma. The update also noted that “Burma remains subject to the application of enhanced due diligence, but not countermeasures”. In addition, FinCEN also released additional guidance pertaining to countries on both lists.
A definition of risk statuses
As part of its statement, FinCEN provided the definitions for both the grey and black lists:
Jurisdictions Under Increased Monitoring (“Grey List”): actively working with the FATF to resolve inadequate counter-money laundering and terrorist and proliferation financing regimes
High-Risk Jurisdictions Subject to a Call for Action (“Black List”): a country with serious deficiencies with regards to countering money laundering and proliferation and terrorist financing.
Statements concerning countries under increased monitoring
In addition to its update concerning its grey and black lists, FinCEN provided further statements and guidance concerning jurisdictions under increased monitoring.
Due diligence: Registered financial institutions must remember their obligations to “comply with the due diligence obligations for foreign financial institutions” under the US Code of Federal Regulations and accompanying regulations and obligations as identified in the United States Code.
Foreign agents and counterparties: Money services businesses (MSBs) were reminded of their requirements as concerns “foreign agents or foreign counterparties” per the guidance presented in FinCEN Interpretive Release 2004-1.
FATF guidance on compliance: Financial institutions were reminded of the importance of referring to interagency guidance when “providing services to foreign embassies, consulates, and missions”.
UN Security Council Resolutions and related provisions: In light of the United Nation’s adoption of several resolutions that implement sanctions, member states were reminded that they are “bound by the provisions of these UN Security Council Resolutions (UNSCR)” and noted that some provisions were “especially relevant to financial institutions”.
Statements concerning high-risk jurisdictions subject to a call for action
The second part of FinCEN’s statement provided guidance and advise pertaining to high-risk jurisdictions subject to a call for action.
Advise for US financial institutions: For US financial institutions engaging with foreign banks in countries that are on the black list, it is recommended that they apply enhanced due diligence and if considering engaging in financial transactions with Burma they ought to “consult existing FinCEN and OFAC guidance”.
Existing prohibitions: US financial institutions are reminded that they must comply with all existing financial restrictions and prohibitions involving Iran and the DPRK.
FATF listing guidance: If a country has been removed from the “FATF listing and monitoring process”, US financial institutions are encouraged to learn the reasons for the FATF’s decisions and assess them against their own risk profiles and existing legal obligations.
Suspicious activity requirements
If a financial institution has determined or has reason to believe that a customer or transaction have involved illegal activities, they must file a suspicious activity report.
Key takeaways
By publishing the status changes of countries on its grey and black lists, the FATF allows financial service providers to update and review their existing obligations, procedures, and risk profiles to ensure they stay in line with the obligations and regulations expected by the FATF, FinCEN, and the wider financial services community.
