Screening Glossary
What is the FATF grey list?
The FATF grey list is the informal name for jurisdictions under increased monitoring: countries with strategic deficiencies in their anti-money-laundering regimes that have committed to resolve them within agreed timeframes and are actively working with FATF.
Updated
FATF publishes two public documents identifying jurisdictions with weak anti-money-laundering and counter-terrorist-financing measures, updated three times a year at its plenary meetings. The grey list covers jurisdictions under increased monitoring; the separate high-risk list, informally the black list, covers those subject to a call for action. Neither is a sanctions list. Grey-listing carries real consequences through correspondent banking and EU high-risk country rules, but it is a signal about a country's system, not about any customer in it.
What this workflow covers
- Feed jurisdiction risk from the FATF lists into the customer risk assessment, where national rules may then trigger enhanced due diligence.
- A company registered in a grey-listed jurisdiction usually moves up a risk tier and picks up extra ownership and source-of-funds work.
- The EU keeps its own list of high-risk third countries, aligned with the FATF lists but not identical, and it is the EU list that sets the mandatory EDD trigger for an EU obliged entity.
- Grey-listing says nothing about any particular person or company in that country.
Compliance glossary
- Jurisdictions under increased monitoring
- FATF's formal term for the grey list: countries actively working with FATF to fix identified strategic deficiencies.
- Call for action
- FATF's strongest public identification, applying to high-risk jurisdictions and asking members to apply enhanced due diligence or countermeasures.
- AMLA
- The EU Anti-Money Laundering Authority, established by Regulation (EU) 2024/1620 to supervise and coordinate AML/CFT across the Union.
Authoritative references
Questions
Frequently asked questions
Grey list or black list: what is the difference?
Grey-listed jurisdictions are under increased monitoring and have committed to fix identified deficiencies with FATF. Black-listed jurisdictions, formally high-risk jurisdictions subject to a call for action, face countermeasures or enhanced due diligence called for by FATF itself.
How often does the list change?
Three times a year, following the FATF plenary meetings, with countries added and removed at those points. Any list quoted in a policy document should carry the date of the plenary it came from, or it will be wrong within months.
Does grey-listing force us into EDD?
Not automatically under FATF itself, which calls for the risk to be taken into account. Mandatory EDD flows from the applicable national or EU high-risk third country rules, so check which list your obligation actually references before rewriting a procedure.
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