FATF GREY LIST AND BLACK LIST COUNTRIES OVERVIEW

PREAMBLE

The FATF was established in 1989 in Paris.

FATF FUNCTIONS

To tackle money laundering, terrorist and proliferation financing to set international standards by its 39 members.

COUNTRIES

More than 200 countries are committed to follow FATF standards.

FATF ASSISTANCE

• 9 FATF Associate members
• IMF
• WORLD BANK

There are 9 FATF style regional bodies

• Asia/Pacific Group on Money Laundering (APG) based in Sydney, Australia;
• Caribbean Financial Action Task Force (CFATF) based in Port of Spain, Trinidad and Tobago;
• Eurasian Group (EAG) based in Moscow, Russia;
• Eastern & Southern Africa Anti-Money Laundering Group (ESAAMLG) based in Dar es Salaam, Tanzania;
• Central Africa Anti-Money Laundering Group (GABAC) based in Libreville, Gabon;
• Latin America Anti-Money Laundering Group (GAFILAT) based in Buenos Aires, Argentina;
• West Africa Money Laundering Group (GIABA) based in Dakar, Senegal;
• Middle East and North Africa Financial Action Task Force (MENAFATF) based in Manama, Bahrain;
• Council of Europe Anti-Money Laundering Group (MONEYVAL) based in Strasbourg, France (Council of Europe).

You Must Know Before Start

• Risk Base Approach AML/CFT
• National Risk Assessment
• Money Laundering
• Terrorist Financing
• Proliferation Financing
• Beneficial Ownership
• Legal Persons
• Sanctions Risk
• Targeted Financial Sanctions
• International Cooperation
• Palermo Convention
• Terrorist Financing Convention
• Politically Exposed Persons(PEPs)
• Non Profit Organisations (NPO)
• Voluntary Tax Compliance (VTC)
• Designated Non Financial Businesses and Professions (DNFBPs)
• FATF 40 Recommendations
• FATF Style Regional Bodies

GREY LIST / BLACKLIST DECISION

The FATF plenary committee meets three times a year to review countries' performance on FATF standards.

If a country repeatedly fails to comply with FATF standards then it  can be named a JURISDICTION UNDER INCREASE MONITORING or HIGH RISK JURISDICTION , that is also called Grey List or Black list.

BLACKLIST COUNTRIES

• Democratic People's Republic of Korea (DPRK)
• IRAN
• MYANMAR

Democratic People's Republic of Korea (DPRK)

FATF CONCERNS

• AML/CFT Deficiencies
• Proliferation of weapons of mass destruction

IMPLEMENTATIONS

All UN,FATF and other AML/CFT regime groups members are advised to cut the correspondent relation with DPRK in this regard to avoid their territories to AML/CFT/CPF risks.

IRAN

FATF CONCERNS

• AML/CFT DEFICIENCIES
• FAIL TO ENACT THE FATF STANDARDS
• FAIL TO ENACT THE PALERMO AND TERRORIST FINANCING CONVENTION

IMPLEMENTATIONS

All UN,FATF and other AML/CFT regime groups members are advised to cut the correspondent relation with IRAN in this regard to avoid their territories to AML/CFT/CPF risks.

MYANMAR

FATF CONCERNS

• ML RISK INVESTIGATION
• SITE / OFF SITE INSPECTION
• REGISTRATION OF HUNDI OPERATORS
• INTERNATIONAL COOPERATION
• TARGETED FINANCIAL SANCTIONS

IMPLEMENTATIONS

• All UN,FATF and other AML/CFT regime groups members are advised to cut the correspondent relation with MYANMAR in this regards to avoid their territories to AML/CFT/CPF risks.

GREYLIST COUNTRIES 

FATF.

TURKIYE

Grey List Since October 2021

FATF CONCERNS

• Politically Exposed Persons EDD
• Risk Based Approach
• Enhance ML and TF investigation by using Financial Institutions
• Apply Targeted Financial Sanctions
• Monitoring on NPO

APG.

PHILIPPINES

Grey List Since JUNE 2021

FATF CONCERN

• DNFBPs
• Mitigate Casino ML Risk
• Increasing Monitoring of ML investigations

Council of Europe.

ALBANIA

GIBRALTAR

ALBANIA

Grey List Since FEB 2020

FATF CONCERNS

• Voluntary Tax Compliance (VTC) Programme
• VTC is an amnesty scheme that should be not used for converting illegal assets into legitimate assets and ensure that VTC has safeguards to prevent AML risk.

GIBRALTAR

Grey List Since June 2022

FATF CONCERNS

Trust and Company Service Providers (TCSP)

Designated Non Financial Businesses and Professions (DNFBPs)

AML / CFT breaches found on TCSP and in DNFBPs required strong AML / CFT regime

CFATF.

• BARBADOS
• CAYMAN ISLAND
• HAITI
• JAMAICA

ESAAMLG.

• MOZAMBIQUE
• SOUTH AFRICA 
• TANZANIA
• UGANDA

MOZAMBIQUE

Grey List Since October 2022

FATF CONCERNS

• Apply Risk Based Approach
• Finalizing NRA
• Mechanism of confiscation of proceeds of crime
• Conducting trainings on AML CFT for all LEA
• Implement of beneficial owner verification mechanism 
• Increasing awareness of Terrorist Financing, Proliferation Financing, and Targeted Financial Sanctions

SOUTH AFRICA

Grey List Since FEB 2023

FATF CONCERNS

• ML/TF investigation to confiscate assets of risk profiles.
• Risk based approach on DNFBPs.
• Beneficial ownership information must be up to date.
• Enhance coordination with Law enforcement agencies.
• Enhance the procedure of identification, seizure and confiscation.
• Apply mechanism on targeted financial sanctions on individuals and entities.

TANZANIA

Grey List Since October 2022

FATF CONCERNS

• Apply risk based approach on F.I and DNFBPs.
• Apply dissuasive sanctions on non compliance.
• Strengthen the LEA to identify, trace, seize and confiscate proceeds to crime.
• Increasing awareness on Terrorist Financing, Proliferation Financing, and Targeted Financial Sanctions.

UGANDA

Grey List Since February 2020

FATF CONCERNS

• Apply risk based approach on F.I and DNFBPs.
• Apply verification mechanism of beneficial owner.
• Reduce technical deficiencies in the legal framework to implement PF related targeted financial sanctions effectively.
• Monitoring of NPO in light of FATF standards

GAFILAT.

PANAMA

Grey List Since June 2019

FATF CONCERNS

• Strategic deficiencies on ML TF risk
• Mechanism for verification of beneficial ownership
• Investigation on foreign tax crime

GIABA.

• BURKINA FASO
• MALI
• NIGERIA
• SENEGAL

BURKINA FASO

Grey List Since since February 2021

FATF CONCERNS

• Revision of NRA.
• Apply risk based approach on F.I and DNFBPs.
• Mechanism for verification of beneficial ownership.
• Quality STR.
• Cross border declaration of currencies mechanism.
• Enhancing LEA strength to confiscate the illegal assets.

MALI

Grey List Since October 2021

FATF CONCERNS

• Apply AML CFT action plan in line with NRA.
• Supervision of F.I and DNFBPs
• Comprehensive assessment of all types of legal persons.
• Enhancing the coordination of FIU and LEA on financial intelligence.
• Give strength to TF cases investigators and related authorities.
• Apply a risk based approach on NPO.

NIGERIA

Grey List Since February 2023

FATF CONCERNS

• Updating NRA 
• Develop international cooperation in line with ML TF risk.
• Risk based supervision of F.I and DNFBPs 
• Legal persons beneficial ownership verification mechanism.
• Apply sanctions for breaches on BO obligations.
• Procedure to disseminate financial intelligence to LEA.
• Detecting violations on currency declarations.
• Apply a risk based approach on NPO.
• Apply TFS on individuals and entities.

SENEGAL

Grey List Since February 2021

FATF CONCERNS

• Apply dissuasive sanctions on non compliant DNFBPs.
• Legal persons beneficiary ownership verification.
• Supervision on NPO by risk based approach.
• Enhancing the capacity of LEA and related authorities to combat Terrorist and Proliferation Financing.

GBAC.

DEMOCRATIC REPUBLIC OF CONGO

Grey List Since October 2022

FATF CONCERNS

• Develop National Risk Assessment Report on ML TF
• Supervise DNFBPs by risk based approach
• Enhance the capacity of FIU to conduct independent analysis
• Implement Target Financial Sanctions effectively

MENAFATF.

• JORDAN
• UAE
• YEMEN

JORDAN

Grey List Since October 2021

FATF CONCERNS

• Targeted Financial Sanctions Applied
• Effective assessment of legal persons
• Apply dissuasive sanctions on non compliance 
• Inspection report of entities including F.I and DNFBPs

UAE

Grey List Since February 2022

FATF CONCERNS

• Monitoring of DNFBPs to mitigate ML TF risk
• Filed quality STR
• Understand the misuse of legal person

YEMEN

Grey List Since February 2010

FATF CONCERNS

• Criminalizing of Money Laundering and Terrorist Offences
• Develop mechanism for freezing of terrorist assets
• Improving CDD and STR reporting
• Develop supervisory capacity for financial sectors

NON MEMBER OF FSRB

• SOUTH SUDAN
• SYRIA

SOUTH SUDAN

Grey List Since June 2021

FATF CONCERNS

• Apply FATF standards
• Implement on 1988 Vienna convention
• Implement on 2000 Palermo convention
• Implement on 1999 Terrorist Financing convention
• Apply risk based approach
• Develop comprehensive framework to verify the beneficial owner of legal persons and implement targeted financial sanctions in the light of UNSC resolution on terrorist financing and WMD proliferation financing.
• Independent FIU
• Monitoring of NPO

SYRIA

Grey List Since February 2010

FATF CONCERNS

• Strategic AML/CFT deficiencies
• Develop procedure for confiscation of assets

FATF MEMBERSHIP SUSPENSION

• FATF suspended membership of the Russian Federation on 24 February 2023.

RELATED LINKS

https://apgml.org/fatf-and-fsrb/page.aspx?p=94065425-e6aa-479f-8701-5ca5d07ccfe8

https://www.cfatf-gafic.org/

https://eurasiangroup.org/en

https://www.esaamlg.org/

https://gabac.org/

https://www.gafilat.org/index.php/es/

https://www.giaba.org/

https://www.menafatf.org/

https://www.coe.int/en/web/moneyval