The FATF black and grey lists are the Financial Action Task Force’s public identification of countries whose defenses against money laundering, terrorism financing, and proliferation financing fall short of international standards. As of the February 2026 plenary, three countries sit on the black list (formally, High-Risk Jurisdictions Subject to a Call for Action) and twenty-two on the grey list (formally, Jurisdictions Under Increased Monitoring).1Financial Action Task Force. High-Risk Jurisdictions Subject to a Call for Action – 13 February 20262Financial Action Task Force. Jurisdictions Under Increased Monitoring – 13 February 2026 A listing is not a sanction, but it drives mandatory enhanced due diligence at banks worldwide, can trigger U.S. Treasury special measures, and often costs listed countries the correspondent banking relationships they need for trade.
How the Two Lists Differ
The black list identifies countries with the most serious strategic failures. For these jurisdictions, the FATF calls on all member countries to apply enhanced due diligence and, in the worst cases, to impose counter-measures that can effectively wall the country off from parts of the global financial system.1Financial Action Task Force. High-Risk Jurisdictions Subject to a Call for Action – 13 February 2026
The grey list covers countries that have acknowledged their shortcomings and committed to fixing them within a specific timeframe. They work with the FATF under an agreed action plan, with progress reviewed at each plenary.2Financial Action Task Force. Jurisdictions Under Increased Monitoring – 13 February 2026 The FATF does not call for enhanced due diligence against grey list countries the way it does for black list ones. It asks members to factor the listing into their own risk analysis. A country that misses its milestones can stay on the grey list indefinitely or be escalated.
Countries Currently Listed
Black List
Three countries are on the black list as of February 2026:1Financial Action Task Force. High-Risk Jurisdictions Subject to a Call for Action – 13 February 2026
- North Korea (DPRK), subject to FATF counter-measures since 2011 over money laundering and proliferation financing risks.
- Iran, subject to counter-measures over persistent deficiencies in its anti-money-laundering framework.
- Myanmar, listed for serious strategic deficiencies in countering money laundering and terrorism financing.
Grey List
Twenty-two jurisdictions are under increased monitoring as of February 2026: Algeria, Angola, Bolivia, Bulgaria, Cameroon, Côte d’Ivoire, Democratic Republic of the Congo, Haiti, Kenya, Kuwait, Lao PDR, Lebanon, Monaco, Namibia, Nepal, Papua New Guinea, South Sudan, Syria, Venezuela, Vietnam, the British Virgin Islands, and Yemen.2Financial Action Task Force. Jurisdictions Under Increased Monitoring – 13 February 2026
Both lists change after each plenary. Countries are added and removed as their compliance improves or deteriorates, so any list is a snapshot rather than a settled roster.
Why Countries Get Flagged
A jurisdiction earns a high-risk designation when its legal and regulatory framework has gaps serious enough to let illicit money move largely unchecked. Common deficiencies include failing to criminalize money laundering or terrorism financing in line with international standards, weak or nonexistent suspicious transaction reporting, and inadequate authority for financial intelligence units to freeze or seize assets tied to illegal activity.3Financial Action Task Force. FATF Recommendations
Beneficial ownership transparency is a recurring problem area. If a country cannot reliably identify who actually owns and controls corporate entities, shell companies become easy tools for laundering. The FATF sets a maximum ownership threshold of 25% for identifying beneficial owners, and countries can set a lower bar based on their own risk assessment.4Financial Action Task Force. Guidance on Beneficial Ownership of Legal Persons Weak cross-border cooperation in criminal investigations, failure to require financial institutions to keep transaction records for at least five years, and insufficient oversight of the banking sector or judiciary also draw scrutiny.3Financial Action Task Force. FATF Recommendations
What a Listing Means for Banks and Businesses
The practical bite of a listing shows up at the bank counter. When a customer, counterparty, or transaction is connected to a flagged jurisdiction, financial institutions have to go beyond routine identity checks. FATF Recommendation 19 requires enhanced due diligence proportionate to the risk, which in practice means collecting detailed documentation on the source of a customer’s wealth and funds, documenting the purpose of the relationship and the reasons behind unusual transactions, getting senior management approval before opening or continuing the relationship, and monitoring the relationship on an ongoing basis rather than only at onboarding.3Financial Action Task Force. FATF Recommendations
These obligations reach beyond banks. FATF standards also cover casinos, real estate agents, dealers in precious metals and stones, lawyers, and accountants. Any of them can act as a conduit for laundered funds if they skip the checks.
Counter-Measures Against Black List Countries
When the FATF calls for counter-measures, it is telling the world to take active protective steps. Recommendation 19 lays out the menu, and countries can stack several:3Financial Action Task Force. FATF Recommendations
- Requiring banks to file systematic reports on all transactions involving the flagged jurisdiction.
- Blocking financial institutions from the listed country from opening subsidiaries or representative offices in member countries.
- Prohibiting domestic financial institutions from establishing branches in the listed country.
- Restricting or capping business relationships and financial transactions with the country or its residents.
- Requiring banks to review and, if necessary, cut off correspondent relationships with banks in that country.
- Imposing heightened examination and external audit requirements on branches or subsidiaries of financial institutions based in the listed country.
Individual countries can also apply counter-measures on their own initiative, without waiting for a formal FATF call. That is where much of the real-world pressure comes from, since national regulators often move faster and harder than the FATF’s collective statements.
De-Risking and Trade Consequences
The knock-on effects reach ordinary commerce. When a country gets listed, its banks often start losing correspondent banking relationships, the bilateral arrangements that let banks in different countries process international payments for each other. Correspondent banks in major financial centers weigh compliance costs and regulatory exposure against the revenue the relationships generate, and for many smaller or riskier jurisdictions the math stops working.
This process, called de-risking, can cut a listed country off from the currencies it needs for international trade. Importers cannot pay for goods, exporters cannot receive payment, and remittances from citizens working abroad slow or stop. The FATF has acknowledged this and states that its standards do not call for blanket de-risking; it expects a risk-based approach and has urged that humanitarian aid, legitimate nonprofit activity, and remittance flows not be disrupted.2Financial Action Task Force. Jurisdictions Under Increased Monitoring – 13 February 2026 That guidance has not stopped widespread de-risking in practice, and the listings function as a powerful economic lever even without formal sanctions.
U.S. Enforcement Layer
In the United States, the Financial Crimes Enforcement Network translates FATF designations into practical guidance for domestic institutions. After each plenary update, FinCEN issues public statements advising U.S. financial institutions to factor the FATF’s findings into their risk-based compliance programs.5Financial Crimes Enforcement Network. Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies FinCEN has been explicit that these advisories should inform due diligence decisions rather than justify cutting off entire categories of customers indiscriminately.
The sharper tool is Section 311 of the USA PATRIOT Act, codified at 31 U.S.C. § 5318A. When Treasury designates a foreign jurisdiction or financial institution as a “primary money laundering concern,” it can impose escalating special measures: enhanced recordkeeping and reporting on transactions involving the targeted jurisdiction, extra steps to identify beneficial owners of accounts opened by foreign persons tied to it, special due diligence on payable-through and correspondent accounts, and in the most severe cases an outright ban on U.S. institutions maintaining any correspondent account for the targeted foreign bank.6Office of the Law Revision Counsel. 31 US Code 5318A – Special Measures for Jurisdictions, Financial Institutions, or International Transactions of Primary Money Laundering Concern These measures are legally binding under U.S. law and carry civil and criminal penalties for non-compliance.7eCFR. Special Measures Under Section 311 of the USA Patriot Act and Law Enforcement Access to Foreign Bank Records
A FATF Listing Is Not an OFAC Sanction
The two are fundamentally different legal tools, and treating them as interchangeable causes real compliance mistakes. The FATF is not a regulator and cannot impose binding legal obligations on any country. Its black and grey lists are recommendations that tell member countries to apply enhanced scrutiny or counter-measures; whether that scrutiny happens depends on each country implementing the recommendations through its own laws.8Financial Action Task Force. High-Risk and Other Monitored Jurisdictions
OFAC sanctions, by contrast, are legally binding prohibitions under U.S. law. When OFAC designates an entity, individual, or country, U.S. persons are generally prohibited from conducting transactions with them, and violations carry their own set of severe penalties. A country can appear on a FATF list without being under OFAC sanctions, and vice versa. North Korea and Iran happen to appear on both, but that overlap is not automatic. Monaco, for example, is on the grey list but faces no OFAC restrictions. Financial institutions have to check both systems independently.
When the Lists Change
The FATF holds three plenary meetings per year, typically in February, June, and October, and publishes updated black and grey lists after each session.9Financial Action Task Force. Events The 2026 schedule has already produced the February plenary, with a June session from June 15–19 and an October session from October 26–30 still ahead. Compliance officers should check for new designations after each of these dates, because a country added between review cycles can immediately change the risk profile of an existing customer relationship.
How Countries Get Off the Lists
Getting off the grey list requires a country to complete all or nearly all of the items in its agreed action plan. Once the FATF determines that progress is sufficient, it arranges an on-site visit to verify that the legal, regulatory, and operational reforms are actually functioning, not just written into law.8Financial Action Task Force. High-Risk and Other Monitored Jurisdictions The FATF also looks for genuine political commitment and the institutional capacity to sustain the changes.
If the on-site visit produces a positive assessment, the FATF removes the country from public identification at its next plenary. Removal does not end oversight; the country continues through the normal follow-up process with the FATF or its regional body. For black list countries, the path is longer and harder, since the deficiencies are more severe and international trust runs deeper in the red. Some countries have spent over a decade on the black list.