FATF October 2026 Update: Changes to the Grey List and Implications for Notaries
The Financial Action Task Force (FATF) published its latest update on 30 October 2026, following its October Plenary meeting. The update confirms changes to the lists of jurisdictions under increased monitoring (the Grey List), while also updating its statements on jurisdictions subject to a call for action (the Black list).
Changes to the Grey List:
The FATF agreed to remove four jurisdictions from its Grey List following successful progress in addressing identified deficiencies in their anti-money laundering and counter-terrorist financing regimes:
- Bulgaria
- Côte d’Ivoire
- Democratic Republic of the Congo
- Monaco
These jurisdictions have completed their agreed FATF action plans and will no longer be subject to increased monitoring by the FATF.
There were no new additions to the Grey List announced in this October update.
Changes to the Black list:
The FATF updated its public statements concerning the two jurisdictions subject to a call for action
- Iran
- Myanmar
The October update reinforces the FATF’s concerns about Irans Terrorist financing framework and Myanmar’s extensive fraud and scam activities.
No new additions or removals were announced to the Black List.
Notaries should consider the latest changes when undertaking client due diligence and assessing geographical risk. In particular:
- Review and update internal AML country-risk assessments to reflect changes.
- Consider whether existing clients or transactions have connections with the affected jurisdictions.
- Remember that removal from the Grey List does not automatically mean that a client or transaction presents no increased risk.
- Continue to apply enhanced due diligence where required, particularly in relation to jurisdictions subject to a FATF call for action.
Importantly, notaries are to ensure that their AML procedures remain up to date and continue to apply a proportionate risk based approach to client and transaction assessments.