FATF grey/black list

The FATF grey and black lists are lists of countries (jurisdictions) that the FATF assesses as having deficiencies in their systems for combating money laundering and terrorist financing. Unlike sanctions lists, they concern not specific people but states and their control regimes. They are a kind of “rating” of a country’s compliance with global standards.

The “grey list” (officially, jurisdictions under increased monitoring) includes countries that have committed to remedying identified deficiencies and are under observation. The “black list” (high-risk jurisdictions subject to a call for countermeasures) is a far more serious category for countries with significant gaps. The lists are reviewed periodically: countries are added and removed.

There is no direct link here with the client’s personal good standing, but the effect is tangible: a link with a jurisdiction on the grey or black list (citizenship, the origin of money, companies, banks) increases compliance’s attention and requires a more thorough explanation. It is not a verdict but a signal to prepare more thoroughly. We take jurisdictions’ status into account when preparing the file, so that such a link does not become an unexpected obstacle.