FATF Removes Bulgaria, Ivory Coast, DRC and Monaco From Grey List

The Financial Action Task Force removed Bulgaria, Ivory Coast, the Democratic Republic of Congo (DRC) and Monaco from its list of jurisdictions under increased monitoring at its plenary in Paris, which ran from October 28 to 30, 2026, cutting the list from 22 to 18.

This FATF grey list removal changes the inputs banks use for country risk ratings, enhanced due diligence triggers and monitoring thresholds. It does not change every obligation at once. The European Commission keeps its own list of high-risk third countries, and that list moves on a separate timetable.

The FATF said each country had completed its action plan, and on-site visits confirmed the reforms. The plenary added no new jurisdictions. Vietnam, grey-listed since June 2023, stayed on the list.

What the FATF grey list removal covers

The FATF grey list names countries that have committed to fix strategic weaknesses in their rules against money laundering, terrorist financing and proliferation financing. Listing carries no formal sanctions. Banks usually apply closer checks to transactions linked to listed countries, which can slow investment and capital flows.

The four exits had been listed for between two and four years. The DRC was listed in October 2022, Bulgaria in October 2023, Monaco in June 2024 and Ivory Coast in October 2024.

The FATF cited specific reforms for each country:

• Bulgaria: a national AML and counter-terrorist financing strategy, a more accurate beneficial ownership register, risk-based supervision of postal money operators, currency exchangers and real estate agents, market entry controls for virtual asset service providers, and better money laundering investigations.
• Ivory Coast: stronger risk-based supervision of financial institutions and designated non-financial businesses and professions, better verification of beneficial ownership, wider law enforcement use of financial intelligence, and a stronger targeted financial sanctions framework.
• DRC: a finished national risk assessment, a national AML strategy, supervisors designated for all non-financial business sectors, a resourced financial intelligence unit, and effective implementation of targeted financial sanctions.
• Monaco: a better understanding of the risks from money laundering and income tax fraud committed abroad, sanctions for AML and beneficial ownership breaches, improved suspicious transaction reporting, and more resources for prosecutors and investigating judges, along with more asset seizures.

Monaco’s route was the longest to read from outside. Its October 2025 status update still listed it under increased monitoring, and the FATF said the final phase was to confirm that reforms were effective and sustainable before removal.

Vietnam stays on the list; black list unchanged

Vietnam did not get the same result. The FATF expressed significant concern about the pace of progress, noting that all of its action plan deadlines expired in May 2025. The FATF said it expects tangible improvements before its next plenary, scheduled for February 22 to 26, 2027, or it will consider further action.

The black list is unchanged. Iran, Myanmar and North Korea remain subject to the FATF’s call for action, its strongest designation, which asks members to apply countermeasures and enhanced scrutiny.

What grey list removal changes for EDD and ratings

Many banks hard-wire FATF status into their country risk models, so FATF grey list removal can drop a country’s score and take it out of the group that triggers enhanced due diligence by default. That does not make a country low risk. The same customer due diligence factors still apply: the customer’s activity, product, delivery channel and beneficial ownership.

Compliance teams will face three practical questions:

• Whether FATF status is the only reason a customer file sits in a high-risk tier, and whether another factor supports the rating.
• Whether a policy exception, a board-approved risk appetite statement or a regulator’s expectation required enhanced measures for these countries.
• Whether the downgrade is documented, so audit and supervisors can trace the reason for the change.

Banks that raised ratings when a country was listed may now need to explain why they are lowering them. Bulgaria, as an EU member state, sat in an unusual position, because EU banks treated it as an internal market jurisdiction with a FATF flag attached.

Correspondent banking after grey list removal

Listing often led banks to cut or restrict correspondent banking links to institutions in the affected country. FATF grey list removal reopens that question. Napier AI chief data scientist Dr Janet Bastiman said the decision would lead banks to reopen relationships they cut during the listing, and that it brings more cross-border traffic to monitor, much of it from jurisdictions with a limited record of effective AML controls.

The commercial case for returning is clearer than the risk case. A bank that exited a respondent relationship during the listing period will need a fresh assessment, not a reinstatement of the old file. That means updated due diligence on the respondent, its ownership, its own AML program and the nature of the flows it would clear.

The FATF’s findings give banks material for that work, including supervisory coverage, beneficial ownership checks and sanctions implementation. They do not replace a bank’s own judgment on a single institution.

Transaction monitoring calibration after removal

Rules that raise alerts on payments to or from listed countries will change once FATF grey list removal updates the country list in the system. Teams that lower thresholds or retire scenarios tied to the four countries should test the effect before go-live, using historic data, so a drop in alerts reflects lower risk and not a gap. The RegTech Post transaction monitoring tuning template pack sets out a documentation structure for threshold changes.

Bastiman warned against relying on the list alone. “Criminal money typically flows through weak points, and as one route is closed, it moves on to the next,” she said, pointing to Vietnam and the scam networks operating out of Myanmar. She cited the Napier AI / AML Index figure of $5.09 trillion laundered globally each year.

Her argument is one practitioner’s view, not a regulatory finding. The FATF did not say in its outcomes that exits create new laundering routes. It did say the four countries had fixed the weaknesses it identified.

Her narrower point is practical. Money laundering trends show up in suspicious transaction data before a country’s rating changes, so a bank relying only on a country-risk rating will see risk later than one that watches its own alerts. The choice between real-time and batch AML monitoring affects how fast a team sees such a shift.

EU high-risk third country list differs from FATF’s

The European Commission maintains its own list of high-risk third countries, adopted by delegated regulation. EU banks must apply enhanced due diligence to business relationships and transactions involving the countries on it. The FATF’s list informs the Commission’s work but does not change the EU list on its own.

Three of the four sit in different positions:

• Monaco and Ivory Coast: Delegated Regulation (EU) 2025/1184, adopted on June 10, 2025, added both to the Commission list, with the update taking effect on August 5, 2025.
• DRC: it was already on the list before that regulation and appears in its annex as an existing entry.
• Bulgaria: it does not appear on the Commission list, so EU banks had no EU-law requirement to apply enhanced measures to it on that basis.

For Monaco, Ivory Coast and the DRC, FATF grey list removal does not by itself remove the EU requirement. Removal needs a new delegated regulation from the Commission, which the European Parliament and Council can scrutinize. The Commission’s 2025 announcement set out how the last update was made.

Until the EU list changes, EU-regulated banks that lowered a rating on the FATF decision alone may still carry a legal obligation for these three countries. Regulation (EU) 2024/1624, the bloc’s single AML rulebook, applies from July 10, 2027 and keeps the link between the Commission’s list and enhanced due diligence.

The same point applies to the other regimes banks follow. Each jurisdiction’s own list, such as the Treasury’s or a national regulator’s, has its own process and timing, and a FATF exit does not move them.

What comes next for compliance teams

The FATF’s next plenary is scheduled for February 22 to 26, 2027, when Vietnam faces the review the FATF flagged. A further test of banks’ models will come when the Commission acts on its own list for Monaco, Ivory Coast and the DRC. No date has been set for that.