At its most recent plenary, the Financial Action Task Force added two jurisdictions to its list of countries under increased monitoring and removed two others that had completed their reform commitments. The list — widely known as the "grey list" — now covers 22 jurisdictions worldwide, spanning several regions rather than any single part of the globe.
For clients who only bank in one country, a change like this can feel remote. For clients structuring accounts, companies, or investments across two or three jurisdictions, it's rarely irrelevant — grey-list status is one of the inputs banks feed into their own country risk scoring, which in turn shapes how much extra documentation, explanation, or time an account relationship requires.
What's worth understanding: grey-list status is not, on its own, a reason for a bank to close or refuse an account — FATF itself discourages blanket de-risking based on the list alone. In practice, though, individual institutions vary widely in how conservatively they apply it. A structure with exposure to a newly listed jurisdiction may see closer questions at one bank and none at all at another.
What this means for clients: when we prepare a multi-jurisdiction banking profile, we now factor the current FATF status of every jurisdiction in scope into how we frame source-of-funds and structure documentation — before a bank asks, not after.