The Financial Action Task Force (FATF) recently concluded its plenary on 21st February 2025. In this plenary, it removed Philippines and added Laos and Nepal from its Grey List. In this Update, we’ll examine these changes in detail.
FATF is an international inter-governmental organisation that seeks to combat financial crimes such as Money Laundering (ML), Terrorism Financing (TF), and Proliferation Financing (PF).
As a part of its duties, it releases a list of “Jurisdictions under Increased Monitoring”, also known as the FATF Grey List. This is a list of countries that have been assessed by the FATF to have strategic deficiencies in its Anti-Money Laundering (AML), Counter Terrorist Financing (CTF), and Counter Proliferation (CPF) regime. These countries are actively working with the FATF to address and remedy these deficiencies.
Let’s have a look at the changes made to the FATF Grey List in February 2025:
– Laos
– Nepal
– Philippines
1. Algeria
2. Angola
3. Bulgaria
4. Burkina Faso
5. Cameroon
6. Côte d’Ivoire
7. Croatia
8. Democratic Republic of Congo
9. Haiti
10. Kenya
11. Laos
12. Lebanon
13. Mali
14. Monaco
15. Mozambique
16. Namibia
17. Nepal
18. Nigeria
19. South Africa
20. South Sudan
21. Syria
22. Tanzania
23. Venezuela
24. Vietnam
25. Yemen
Entities regulated under the AML/CTF/CPF laws of India need to adopt a risk-based approach to ML/TF/PF risk management. When the FATF updates its Grey List, it may result in the need for revision of an entity’s AML/CTF/CPF Program to ensure that the heightened financial crime risks from the FATF Grey Listed countries are given due weightage in its Business Risk Assessment and Customer Due Diligence (CDD) process. For example, while conducting a Customer Risk Assessment (CRA) for a customer from a FATF Grey Listed country, the regulated entity needs to take into consideration the geographic ML/TF/PF risks posed by them and adopt risk-based control measures accordingly.
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