AML Alert – Update to Financial Action Task Force Grey List   

27 June, 2025

The latest Financial Action Task Force (FATF) meeting took place earlier this month (June 2025).  Following this meeting there have been a number of changes to the countries which are on the FATF “grey list” (those countries that are subject to increased monitoring). 

These changes are: 

• Bolivia and the British Virgin Islands have been added to the list; and 

• Croatia, Mali and Tanzania have been removed from the list. 

It is important to be aware that the UK list of high risk third countries (HRTC) now mirrors the FATF lists (both the “grey” list and the “black” list).  CLC practices must ensure that Enhanced Due Diligence (EDD) is applied when a client is “established” in a HRTC; this means for an individual, being resident in that country (not just having been born there), and for a company/legal person this means being incorporated in or having its principal place of business in that country.  

The EDD that must be carried out if a client is “established” in a HRTC is very specific under the 2017 Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations and includes obtaining additional information on the customer and on the customer’s beneficial owner, obtaining additional information on the intended nature of the business relationship, obtaining the approval of senior management for establishing and continuing the business relationship, conducting enhanced monitoring of the business relationship and other requirements set out under Regulation 33(3A)(a) – (f). 

On inspection the CLC monitoring team will be assessing whether practices’ policies are up to date and whether those practices that maintain active lists of HRTC countries have updated them to reflect the latest developments. Bear in mind the HRTC list is a separate regime from the sanctions regime which prohibits the conduct of business with certain individuals and organisations. 

Supporting AML Compliance   

To support compliance with AML requirements, the CLC publishes extensive resources which practices can find in the AML Toolkit and in those more complex circumstances where further input or guidance is needed, practices are encouraged to contact aml@clc-uk.org.