Four jurisdictions have now formally exited the increased monitoring regime of the Financial Action Task Force, while a substantial cohort remains under close scrutiny. This article covers each country, beginning with those that successfully completed their action plans and exited the “grey list,” then reviewing those still subject to heightened AML monitoring. The aim is to provide AML/CFT compliance professionals with complete jurisdiction-by-jurisdiction insight, actionable risk-points and implications for correspondent banking, trade finance, and due diligence frameworks.

AML monitoring Status – Countries that exited

Burkina Faso exited the grey-list after completing its action-plan commitments. The jurisdiction had been identified in 2021 for strategic deficiencies in its AML/CFT regime. Key reforms included strengthening beneficial-ownership transparency for legal persons and enforcing risk-based supervision of both financial institutions and designated non-financial businesses and professions (DNFBPs). The FIU increased its staffing and training, suspicious-transaction reporting widened and asset-seizure capacities were enhanced. Although removal from the list reduces international reputational pressure, the country remains in a consolidating phase and compliance programmes should still maintain oversight of travel-and-transaction risks linked to this jurisdiction.

Mozambique achieved grey-list exit following reforms that addressed deficiencies identified in 2022. Mozambique improved inter-agency coordination, expanded the FIU’s human-resource capacity, introduced a risk-based supervision programme and improved collection of accurate beneficial-ownership data for legal persons. Trade-finance exposures tied to Mozambique may now face fewer automatic frictional controls but remain subject to risk-based review given the underlying resource-export and cross-border flow complexities.

Nigeria’s exit marks a major step for one of Africa’s largest economies. Nigeria completed its residual money-laundering/terrorist-financing risk assessment, updated its national AML/CFT strategy in alignment with that risk assessment, enhanced inter-agency cooperation, improved access to beneficial-ownership information and strengthened enforcement including prosecutions and asset-recovery frameworks. For banks and compliance teams, the exit suggests reduced incremental internal risk scoring for Nigerian exposures is plausible, provided internal controls confirm sustained reform and the client or counterparty whose domicile is Nigeria is well-governed.

South Africa also exited the increased monitoring regime. Its reform journey included enhanced supervision of DNFBPs, improved beneficial-ownership accuracy and timeliness, increased mutual-legal-assistance requests, improved financial-intelligence dissemination and greater asset-seizure activity. For multinational financial groups, the delisting may ease correspondent-banking bottlenecks with South-African counterparties but does not eliminate the need for country-risk assessments and periodic reviews of the South-African AML/CFT regime.

The exit of these four jurisdictions demonstrates that multi-year remedial action supported by policy reform and operational implementation can lead to removal from increased monitoring. However, exit is not synonymous with “no-risk” and continuous monitoring remains best practice.

AML monitoring Status – Countries still under increased monitoring

A substantial number of jurisdictions remain under increased monitoring following the latest plenary session. The list includes Algeria; Angola; Bolivia; Bulgaria; Cameroon; Côte d’Ivoire; Democratic Republic of the Congo; Haiti; Kenya; Lao PDR; Lebanon; Monaco; Namibia; Nepal; South Sudan; Syria; Venezuela; Vietnam; Virgin Islands (UK); Yemen.

Each jurisdiction faces its unique mix of strategic deficiencies and compliance-programme implications:

• Algeria made a high-level political commitment in October 2024 to address deficiencies. Key tasks include improving risk-based supervision especially of higher risk sectors, developing an effective framework for beneficial-ownership information and enhancing verification and access, building improved suspicious-transaction-reporting regimes and strengthening oversight of non-profit organisations (NPOs) with exposure to terrorist-financing risk.
• Angola committed to address AML/CFT shortfalls including enhancing risk-based supervision of non-bank financial institutions and DNFBPs, ensuring competent authorities have timely access to beneficial-ownership data, increasing money-laundering investigations and prosecutions, improving terrorist-financing investigation capacity and implementing targeted financial-sanctions effectively.
• Bolivia made a high-level political commitment in June 2025. Outstanding action-plan items include implementing special investigative techniques for ML investigations, applying risk-based supervision of real-estate agents and lawyers, ensuring beneficial-ownership data is accurate and current with sanctions for breaches and increasing ML investigations and prosecutions.
• Bulgaria since October 2023 has passed legislative reforms to strengthen the sanction-regime for AML/CFT breaches and to address technical compliance gaps in the terrorist-financing offence and legal-person-liability frameworks. Remaining tasks include improving investigations and prosecutions of money laundering consistent with risk, enhancing responsibility for legal persons, and demonstrating initial implementation of risk-based supervision of NPOs vulnerable to terrorist-financing.
• Cameroon has introduced improved inter-agency coordination mechanisms for AML/CFT oversight. Yet it must still enhance risk-based supervision of financial institutions and DNFBPs, improve secure information-exchange between the FIU and competent authorities, demonstrate increased dissemination of financial intelligence, and develop stronger rulings on asset seizure and sanctions at the border.
• Côte d’Ivoire has improved international cooperation in ML/TF investigations, improved compliance of AML obligations among financial institutions and DNFBPs, expanded access to beneficial-ownership data and strengthened targeted-financial-sanctions regimes. It remains required to deepen risk-based supervision of financial institutions and DNFBPs, improve utility of financial intelligence and demonstrate sustained increases in investigations and prosecutions across its risk profile.
• Democratic Republic of the Congo (DRC) has provided increased training for law-enforcement agencies involved in terrorist-financing investigations and addressed technical deficiencies in AML/CFT framework elements. Outstanding items include developing and implementing a full risk-based supervision plan, investigating terrorist-financing activities aligned with risk, and strengthening implementation of targeted financial-sanctions and asset-seizure procedures.
• Haiti is operating under severe socio-economic and security constraints yet remains committed to reform. Action-plan tasks include completing its ML/TF risk assessment, implementing risk-based AML supervision for DNFBPs, ensuring reliable beneficial-ownership information, demonstrating increased investigations and prosecutions of ML, enhancing asset-recovery frameworks and conducting risk-based monitoring of NPOs without impeding legitimate humanitarian flows.
• Kenya has taken steps including national-risk assessment guidance publication, FIU dissemination improvements and enhanced border-area cooperation on terrorist-financing investigations. Remaining items include adopting legal framework for licensing and supervising virtual-asset service providers (VASPs), strengthening beneficial-ownership regimes for trusts and legal arrangements, increasing ML/TF investigations and prosecutions consistent with risk, revising the NPO oversight framework to ensure it is risk-based and non-disruptive.
• Lao PDR made a high-level commitment in February 2025 and has begun addressing its terrorist-financing offence reform and oversight of high-risk sectors such as casinos and banks in special economic zones. The outstanding action-items include enhancing understanding of ML/TF risks, supervising casinos and special-economic-zone entities, enhancing financial intelligence analysis and spontaneous dissemination, developing a comprehensive national confiscation policy and demonstrating effective implementation of targeted financial-sanctions and asset-seizure mechanisms.
• Lebanon made a high-level commitment in October 2024 in the context of a severe banking and economic crisis. It has proposed reforms including a circular to banks and financial institutions for dedicated anti-bribery and corruption units and guidance on politically exposed persons (PEPs). Remaining tasks include conducting assessments of specific ML/TF risks in the mutual-evaluation report, enhancing mutual legal assistance and asset recovery, increasing DNFBP risk-understanding and sanctions, ensuring up-to-date beneficial-ownership information, improving FIU-product use by competent authorities, expanding investigations and prosecutions, and enhancing non-profit organisation monitoring without disrupting legitimate activity.
• Monaco made a high-level commitment in June 2024 and has demonstrated increases in outbound requests for asset-identification abroad, completed its FIU-resource programme and increased prosecutor-resources. Remaining tasks include enhancing sanction-regimes for AML/CFT breaches, improving timeliness and quality of suspicious-transaction reporting, and applying effective sanctions for money-laundering.
• Namibia made a commitment in February 2024 and has improved cooperation between its FIU and law-enforcement agencies, strengthened supervision of DNFBPs and implemented more effective sanctions for AML breaches. Outstanding items include demonstrating effective investigations and prosecutions consistent with its risk-profile and ensuring asset-recovery capability is commensurate with high-risk commodity flows.
• Nepal committed in February 2025, with tasks ahead including implementing risk-based supervision of banks, cooperatives, casinos, diamond/precious-metals sectors and real-estate, increasing capacity for investigations, sanctioning materially significant informal money-value-transfer systems (‘hundi’/MVTS), improving beneficial-ownership regimes and implementing terrorist-financing/proliferation-financing-related targeted financial-sanctions.
• South Sudan committed since June 2021 and has created training manuals for supervisory staff but still needs to fully operationalise its FIU, develop beneficial-ownership verification frameworks, establish legal and institutional frameworks for targeted financial-sanctions in compliance with UN Security Council resolutions, and implement risk-based NPO supervision.
• Syria was noted in February 2023 as having technically completed its action-plan but due to ongoing conflict the international body has been unable to conduct an on-site visit to verify sustained implementation. The jurisdiction remains under monitoring pending verification of on-the-ground reform.
• Venezuela committed in June 2024. Its remaining key deficiencies include weak oversight of DNFBPs, inadequate beneficial-ownership access, limited use of financial-intelligence by law-enforcement, insufficient prosecutions of money-laundering and terrorist-financing, and non-risk-based non-profit-organisation supervision. It must improve targeted-financial-sanctions implementation promptly.
• Vietnam made commitments since June 2023 and has taken steps on virtual-asset regulation, beneficial-ownership access and investigating ML/TF activity. Remaining items include full implementation of its action-plan consistent with its risk-profile, improving supervision of virtual assets and DNFBPs, enhancing financial-intelligence analysis and dissemination, and monitoring for proliferation-financing risks.
• Virgin Islands (UK) made a high-level commitment in June 2025 and must now implement risk-based supervision of trust and company service providers (TCSPs), investment businesses, VASPs, improve beneficial-ownership-information availability, enhance the quality of suspicious-activity reporting, increase seizure and confiscation of criminal proceeds, and operationalise a new asset-management framework.
• Yemen completed its action-plan at a technical level many years ago but due to the severe conflict the international body has been unable to conduct an on-site visit to confirm ongoing implementation. Monitoring continues until sustainable reform is verified.

Compliance programmes must ensure that clients, correspondent banks, payment flows and trade-finance counterparties tied to these jurisdictions incorporate enhanced due diligence controls, attend closely to beneficial-ownership transparency, DNFBP supervision, virtual-asset exposure and asset-recovery capabilities.

Strategic implications for compliance functions

The dual movement of exits and continued monitoring sends key signals for AML/CFT compliance functions. Jurisdictions that exit demonstrate that multi-year commitment, legislative reform, operational implementation and enforcement outcomes (such as investigations and asset recovery) can lead to removal from increased monitoring. For compliance teams this means a recalibration opportunity. When a jurisdiction exits the list a lower incremental control burden may be justifiable, provided internal risk-assessment confirms that underlying reforms are living and enforced.

Conversely, jurisdictions that remain under monitoring still present elevated residual risk. Compliance programmes must reflect this via higher base risk ratings, more frequent reviews, enhanced documentation requirements, increased senior-management oversight, tailored transaction-monitoring thresholds and more robust vendor/third-party due-diligence when counterparties are located in or transact through those jurisdictions.

From a correspondent-banking perspective, delisting may ease friction, reduce risk premiums, broaden service offerings and lower onboarding costs for clients tied to the jurisdictions that exited. However, institutions should not treat delisting as a green-light for “business as usual”. A risk-based review remains essential.

On trade-finance and cross-border payments, entities operating in or through jurisdictions under monitoring will face greater scrutiny around source-and-destination of funds, beneficial-ownership chains, sanctions-screening and DNFBP-risk exposures, such as real-estate, trust and company-service-providers, virtual-asset service providers (VASPs) and high-risk free-zones or special-economic-zones.

Furthermore continuous monitoring of list changes is critical. The monitoring status of a jurisdiction may change due to improvements or regression. Therefore internal country-risk frameworks must integrate list updates, regulatory pronouncements, asset-recovery outcomes, mutual-evaluation follow-up reports and enforcement trends.

Ultimately AML monitoring is not static. The landscape of illicit-finance risks evolves quickly, as do typologies involving virtual assets, complex ownership chains, free-zone trade flows, peer-to-peer remittances and humanitarian organisation misuse. Institutional compliance functions that embed real-time jurisdiction-risk tracking, responsive internal policy adaptation and robust audit trails will be better positioned to meet regulatory expectations and safeguard institutional integrity.

---

Related Links

• Jurisdictions under Increased Monitoring – FATF
• Outcomes FATF Plenary, 22-24 October 2025 – FATF
• High-Risk Jurisdictions subject to a Call for Action – FATF
• Black and Grey Lists – FATF

Other FinCrime Central Articles About FATF

• Vietnam’s Costly Battle to Escape the FATF Grey List
• A Consolidated View from FATF Follow-Up AML Reports on West Africa
• Jordan and Egypt Step Up AML Reforms Following MENAFATF Assessment

Source: FATF

Some of FinCrime Central’s articles may have been enriched or edited with the help of AI tools. It may contain unintentional errors.

Want to promote your brand, or need some help selecting the right solution or the right advisory firm? Email us at info@fincrimecentral.com; we probably have the right contact for you.