Treliant Takeaway…FATF Grey List Update

FATF Grey List Update 

• Source: FATF.org, FinCEN.gov

Takeaway

The Financial Action Task Force (FATF) has updated its Jurisdictions Under Increased Monitoring list (Grey List):

• FATF added Laos and Nepal to its Grey List and removed the Philippines.
• In response, the Financial Crimes Enforcement Network (FinCEN) urged financial institutions (FI) to continue applying countermeasures when transacting with such high-risk countries, such as Iran, North Korea, and Burma.

Treliant helps FIs maintain compliance with international standards by advising on risk mitigation strategies and supporting the implementation of robust anti-money laundering (AML) and counterterrorism financing (CTF) frameworks. Through expert guidance, Treliant helps mitigate the risks tied to international transactions, enabling institutions to effectively navigate the complex and evolving landscape of global financial crimes.

Highlights

FATF updates its Grey List three times per year, to reflect global progress and ongoing deficiencies in anti-money laundering, counter-terrorism financing, and counter-proliferation efforts. On February 21, 2025, FATF updated its Grey List by adding Laos and Nepal, while removing the Philippines. FinCEN issued a press release in response, highlighting FATF’s calls for continued enhanced due diligence and other countermeasures for high-risk countries such as Iran, North Korea, and Burma, with specific sanctions prohibiting U.S. financial institutions from maintaining correspondent accounts with banks from these countries. Additionally, FinCEN noted the requirement for U.S. financial institutions to comply with other regulations, including U.S. sanctions requirements, to effectively mitigate risks related to money laundering and terrorism financing.

These moves highlight FATF’s ongoing evaluation process, where jurisdictions are reassessed based on their progress in addressing strategic risks related to financial crimes. Financial institutions must stay informed of FATF updates to ensure compliance with evolving international standards for AML, CTF, and counter-proliferation financing, minimizing exposure to legal and reputational risks. Additionally, staying abreast of FATF’s triannual updates is crucial for adhering to U.S. sanctions programs under the Bank Secrecy Act (BSA) as well as Office of Foreign Assets Control (OFAC) guidance, which require enhanced due diligence and restrictions on transactions involving high-risk jurisdictions.