FATF - Updated list of high-risk or monitored jurisdictions 24.10.2025 - Monaco supervision update

25/10/2025
At its October 2025 Plenary, the Financial Action Task Force (FATF) announced several key developments regarding countries under increased monitoring, high-risk jurisdictions and updates to its international standards.

The Plenary adopted new guidance to help countries understand and implement recently strengthened FATF Standards on asset recovery, which gave jurisdictions a more robust toolkit to target and confiscate criminal assets.


The new guidance, to be published next month, aims to address low levels of recovery of criminal assets around the world. The FATF recently held a webinar on extended confiscation which is available to view here.

A new ‘Horizon Scan’ agreed by the FATF this week warns of how criminals can exploit generative AI, AI agents and other new technologies to facilitate their illicit activities. For example deepfakes can be developed at scale to enable cyber fraud. The forthcoming Horizon Scan will examine a few case studies for countries and the private sector to consider as they strengthen their safeguards and harness AI responsibly to protect against criminal activity.

Note: The last update to the list dates back to June 2025 – see our dedicated article.


Jurisdictions under Increased Monitoring (Grey List)

Burkina Faso, Mozambique, Nigeria and South Africa have been removed from the list of jurisdictions under increased monitoring following successful on-site assessments. No new countries were added.

Full list: Algeria, Angola, Bolivia, Bulgaria, Cameroon, Côte d’Ivoire, Democratic Republic of Congo, Haiti, Kenya, Lao PDR, Lebanon, Monaco, Namibia, Nepal, South Sudan, Syria, Venezuela, Vietnam, British Virgin Islands, Yemen.


High-Risk Jurisdictions (Blacklist)

Three countries remain subject to FATF’s highest level of monitoring due to strategic deficiencies: The Democratic People’s Republic of Korea (DPRK), Iran and Myanmar.

The FATF calls on its members to apply enhanced due diligence measures, including countermeasures where appropriate.

The FATF acknowledges Iran’s re-engagement with the FATF as Iran aims to address deficiencies in its AML/CFT regime.

In September 2025, Iran provided an update to the FATF on its ratification of the United Nations Convention against Transnational Organized Crime (Palermo). While the FATF takes note of Iran’s submission and engagement, at this time, the FATF assesses that the reservations Iran has made to Palermo are overly broad and that Iran’s domestic compliance with Palermo is not in line with the FATF standards. The FATF also notes Iran has failed to address the majority of its action plan since 2016.

Considering the United Nations Security Council Resolutions related to Iran’s lack of compliance with its nuclear non-proliferation obligations, the FATF reminds all jurisdictions of their obligations under the FATF standards to address proliferation financing risks emanating from Iran. Additionally, given the ongoing terrorist financing and proliferation financing threats emanating from Iran and as Iran’s action plan remains incomplete, the FATF reiterates its call on its members and urges all jurisdictions to apply effective countermeasures on Iran. Iran will remain on the FATF High Risk Jurisdictions Subject to a Call for Action statement until the full Action Plan has been completed.

Lastly, the suspension of the Russian Federation remains in place, as confirmed in FATF’s February 2024 statement.


Focus on certain jurisdictions under enhanced surveillance: Monaco, Cote d’Ivoire, Vietnam

Among the jurisdictions on the enhanced scrutiny list, you will find below a status update on Monaco, Côte d’Ivoire and Vietnam

Monaco

Since June 2024, when Monaco made a high-level political commitment to work with the FATF and MONEYVAL to strengthen the effectiveness of its AML/CFT regime, Monaco has taken steps towards improving its AML/CFT regime on many of its action items, including by demonstrating a sustained increase in outbound requests to identify and seek the seizure of criminal assets abroad, completing its resourcing program for its FIU, enhancing judicial efficiency by increasing resources for prosecutors and increasing the seizure of property suspected to derive from criminal activities.


Monaco should continue to work on implementing its FATF action plan by:

(1) enhancing the application of sanctions for AML/CFT breaches;
(2) strengthening the timeliness of STR reporting; and
(3) applying effective, dissuasive and proportionate sanctions for ML.

Côte d’Ivoire

Since October 2024, when Côte d’Ivoire made a high-level political commitment to work with the FATF and GIABA to strengthen the effectiveness of its AML/CFT regime, Côte d’Ivoire has taken steps to improve its AML/CFT regime by enhancing its use of international cooperation in ML/TF investigations and prosecutions, conducting outreach to improve compliance of AML/CFT obligations, improving the verification and access to beneficial ownership information of legal persons and sanctioning non-compliance, and strengthening the implementation of its targeted financial sanctions regime.

Côte d’Ivoire should continue working on implementing its action plan to address its strategic deficiencies, including by:

(1) improving the implementation of risk-based supervision of financial institutions and designated non-financial businesses and professions;
(2) enhancing the use of financial intelligence by law enforcement authorities and improving disseminations by the FIU; and
(3) demonstrating a sustained increase in the number of investigations and prosecutions of different types of ML and TF offences in line with the country’s risk profile.


Vietnam
Since June 2023, when Vietnam made a high-level political commitment to work with the FATF and APG to strengthen the effectiveness of its AML/CFT regime, Vietnam has taken some steps towards improving its AML/CFT regime.

Vietnam should continue to work on implementing its FATF action plan to address its strategic deficiencies, including:

(1) increasing risk understanding, domestic co-ordination and co-operation to combat ML/TF;
(2) enhancing international co-operation;
(3) implementing effective risk-based supervision for FIs and DNFBPs;
(4) taking action to regulate virtual assets and virtual asset service providers;
(5) addressing technical compliance deficiencies, including with respect to the ML offence, targeted financial sanctions, customer due diligence and suspicious transaction reporting;
(6) conducting outreach activities with the private sector; (
7) establishing a regime that provides competent authorities with adequate, accurate and up-to-date information on beneficial ownership;
(8) enhancing the quality and quantity of financial intelligence analysis and dissemination;
(9) prioritising parallel financial investigations and demonstrating an increase in the number of ML investigations and prosecutions undertaken; and
(10) demonstrating that there is monitoring of FIs and DNFBPs for compliance with PF TFS obligations and that there is co-operation and co-ordination between authorities to prevent PF TFS from being evaded.


The FATF notes Vietnam’s continued progress across its action plan; however, all deadlines have expired in May 2025, and work remains. The FATF encourages Vietnam to continue to implement its action plan to address the above-mentioned strategic deficiencies as soon as possible.

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