FATF Updates Grey & Blacklists: British Virgin Islands & Bolivia Added, Croatia, Mali & Tanzania Removed

At its June 2025 plenary, the Financial Action Task Force (FATF) issued significant updates to its global anti-financial crime monitoring lists, reinforcing its ongoing efforts to combat money laundering, terrorist financing, and proliferation financing. Of particular note, the FATF has added the British Virgin Islands and Bolivia to its list of Jurisdictions Under Increased Monitoring, commonly referred to as the “greylist”. At the same time, it has removed Croatia, Mali, and Tanzania from this category, recognising improvements in their respective regimes.

The FATF’s High-Risk Jurisdictions Subject to a Call for Action, or “blacklist”, remains unchanged. Iran, North Korea (DPRK), and Burma (Myanmar) continue to be flagged for their strategic deficiencies. Enhanced due diligence and, in the cases of Iran and DPRK, full countermeasures are still urged by the FATF.

This latest update carries regulatory and reputational implications for financial institutions globally, particularly for compliance teams responsible for managing cross-border financial relationships and correspondent banking risks. The Financial Crimes Enforcement Network (FinCEN) has advised United States financial institutions to adjust their risk-based procedures in light of the FATF’s updated lists. This guidance is equally relevant to global banks with US operations, as well as institutions maintaining relationships with foreign financial institutions (FFIs) in the newly listed jurisdictions.

What the FATF Update Means for Financial Institutions

Institutions with exposure to the British Virgin Islands or Bolivia must now reassess the risks associated with those relationships and ensure appropriate controls are in place. Under 31 CFR § 1010.610(a), this includes implementing tailored due diligence programmes for correspondent accounts, ensuring detection and ongoing monitoring for any money laundering activity.

Meanwhile, the continued designation of Iran and North Korea under the FATF’s most severe category means that institutions must adhere to existing US sanctions prohibiting any direct or indirect correspondent banking activity involving these countries. Iran remains a jurisdiction of primary money laundering concern under section 311 of the USA PATRIOT Act, which brings further legal obligations for US financial institutions, beyond the FATF’s own standards.

Burma remains under enhanced due diligence measures, although full countermeasures have not been recommended. FinCEN reiterates the need for institutions to align with existing guidance when engaging with entities based in or connected to Burma.

A Caution Against De-risking

FinCEN has again underscored that these risk-based controls should not result in indiscriminate de-risking. Financial institutions are reminded not to terminate relationships solely based on jurisdictional status. Rather, compliance should be guided by robust, tailored assessments of customer and transactional risk.

Aligning with International Sanctions

Financial institutions must also be aware of relevant United Nations Security Council Resolutions and the parallel sanctions regimes maintained by the US Department of the Treasury’s Office of Foreign Assets Control (OFAC). These frameworks complement FATF’s standards and, in certain cases such as Iran, exceed them.

Looking Ahead

For jurisdictions removed from the FATF’s monitoring process, including Croatia, Mali, and Tanzania, financial institutions should factor in the reasons behind their removal when reassessing risks and updating their internal compliance frameworks.

The FATF’s latest update serves as a timely reminder of the fluid and evolving nature of the global financial crime landscape. For compliance officers, risk managers, and financial institutions operating internationally, vigilance and adaptability remain essential. Regulatory expectations continue to move in the direction of intelligence-led, proportional risk management—not only to comply with evolving standards but also to protect the integrity of the international financial system.

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Read the press release here.