01

What changed on 30 October

The Paris Plenary of 28–30 October 2026 removed Bulgaria, Côte d’Ivoire, the Democratic Republic of the Congo and Monaco from FATF increased monitoring. Removal concerns that process: it does not validate every customer or transaction, or automatically amend EU lists.

02

Increased monitoring: the list and its meaning

As at 30 October: Angola, Bolivia, Bosnia and Herzegovina, Cameroon, Haiti, Iraq, Kenya, Kuwait, Laos, Lebanon, Nepal, Papua New Guinea, South Sudan, Syria, Venezuela, Vietnam, British Virgin Islands and Yemen remain listed.

FATF does not call for EDD solely because of increased monitoring; the information feeds risk analysis. Measures required by applicable law still apply. Listing is not an invitation to exclude entire customer categories.

03

High-risk jurisdictions: different responses

DPRK/North Korea and Iran remain subject to calls for countermeasures. For Myanmar the call is for proportionate EDD, not countermeasures; FATF identifies February 2027 as the next possible step if progress is insufficient. Check sanctions regimes separately.

04

FATF, EU, Italy and Malta are not one list

The EU high-risk third-country list has its own legal acts and effective dates. FATF removal does not automatically remove EU or national measures: check the version effective when deciding.

In Italy, apply Legislative Decree 231/2007 and the measures relevant to the entity and relationship. In Malta, FIAU’s 2 November notice refers to PMLFTR regulation 11 and Implementing Procedures chapter 8: regulation 11(10) for increased monitoring and 11(11) for call-for-action jurisdictions. FATF’s general message does not displace these requirements.

05

Virtual assets, fraud and a risk-based approach

FATF is accelerating reviews of jurisdictions with material VA sectors and implementation of VASP standards, with initial results expected in 2027. It approved a report on scam compounds and continues its risk-based approach work. These are international initiatives and standards, not a universal new requirement to buy software or reject crypto customers.

06

An operational review, not an automatic score change

Suggested professional method: identify the actual links between customer, beneficial owner, activity, funds and country; then compare the statement with applicable law and internal policies.

  • CRA and geographic risk: update source, date and rationale; do not downgrade every customer solely because of delisting.
  • CDD/EDD: check legal triggers and missing information; retain measures proportionate to the case.
  • Screening: distinguish country classifications, sanctions, PEP and adverse media; verify how the provider handles updates.
  • Policies and controls: assign an owner, document cases requiring review and preserve the reasoning behind decisions.
07

A practical question for your team

A customer with a Monaco holding company remains opaque about its beneficial owner and receives third-party funds without a clear legal basis. Does delisting resolve that opacity? No: it changes one geographic source, not the ownership and funding evidence. Explain both what changes and what remains unresolved.

Support for firms, CSPs and organisations: review CRA methodology, policies, controls and team exercises while responsibilities and decisions remain with the appointed entity. Updated to 3 November 2026; recheck sources when reviewing a live case.

FROM CONTENT TO REVIEW

Move from the signal to the control.

See the support routes for control design, escalation, review and evidence.

Marco Pace
AUTHORMarco Pace

AML/CFT & Financial Crime professional

Profile and experience