FATF ¦ Outcomes FATF Plenary, 28-30 October 2026

FATF ¦ Outcomes FATF Plenary, 28-30 October 2026

First FATF Plenary under the UK Presidency targets virtual assets, scam compounds and a shorter grey list

The first FATF Plenary under the UK Presidency of Giles Thomson closed in Paris on 30 October 2026 after three days of meetings with delegates from more than 200 jurisdictions and observer organisations. The decisions follow the priorities of the FATF Ministerial Declaration of April 2026. The Plenary agreed faster implementation of the Standards on virtual assets and a global push against fraud and scam compounds, removed four jurisdictions from the grey list, updated its statements on Iran and Myanmar, adopted the mutual evaluations of Mexico and the United States and introduced a more tailored approach for low-capacity countries. Barbados, Namibia and Thailand took part under their own flags for the first time through the FATF Guest Initiative.

Three outcomes have immediate practical effect for anti-financial crime teams. The grey list changes feed directly into country risk assessments, the Myanmar statement ties a black-listed jurisdiction explicitly to fraud and cyber scams, and the virtual asset review puts jurisdictions with large VA sectors on a tighter timetable.

A targeted review for jurisdictions with large virtual asset sectors

Criminal networks use virtual assets for fraud, scams, sanctions evasion, money laundering, terrorist financing and proliferation financing. The Plenary therefore agreed to launch a new targeted review and accelerated follow-up processes for jurisdictions with materially important VA sectors, selected on objective criteria and on the basis of their assessment status. The results will be published in June and October 2027.

The FATF will support the jurisdictions concerned through engagement, training and capacity building. For VASPs and for banks with VASP clients or counterparties, the published results will add a further reference point for counterparty risk assessments, alongside the FATF’s earlier work on offshore VASPs.

Bastian Schwind-Wagner
Bastian Schwind-Wagner

"The first Plenary under the UK Presidency sets a clear direction: fraud and virtual assets now sit at the centre of the FATF agenda. Scam compounds are treated as organised crime with money laundering at its core, and jurisdictions with large virtual asset sectors face a targeted review with public results in 2027.

For compliance teams, the immediate work is practical. Country risk ratings need updating for Bulgaria, Monaco, Côte d’Ivoire and the DR Congo, and Vietnam and Myanmar both face February 2027 as a decisive date. The policy statement on the risk-based approach expected after the Dallas forum in December may matter even more for day-to-day supervision."

Scam compounds become a global FATF priority

The Plenary approved a report on end-to-end illicit financial flows linked to scam compounds, which the FATF counts among the fastest-growing forms of organised crime worldwide and a significant driver of fraud and its proceeds. The report, published on 5 November 2026, draws on operational experience across the Global Network and addresses the integrated criminal business models and the professional crime-as-a-service economy behind these operations.

It is the first output of the FATF’s roadmap on fraud under the UK Presidency, and a wider study with recommendations on using the full FATF toolkit against fraud will follow. Obliged entities that have handled fraud mainly as a consumer protection or operational risk should expect supervisors to treat it increasingly as a predicate offence within the AML/CFT framework.

Four jurisdictions leave the grey list

Following successful on-site visits, Bulgaria, Côte d’Ivoire, the Democratic Republic of the Congo and Monaco are no longer subject to increased monitoring. All four completed their action plans within the agreed timeframes and will keep working with their regional bodies: MONEYVAL for Bulgaria and Monaco, GIABA for Côte d’Ivoire, and GABAC and ESAAMLG for the DR Congo.

Bulgaria, listed in October 2023, implemented its national AML/CFT strategy, introduced initial risk-based supervision of postal money operators, currency exchange providers and real estate agents, set up market entry controls for VASPs and postal money operators, improved the accuracy of its beneficial ownership register, automated the prioritisation of suspicious transaction reports and stepped up money laundering cases linked to high-scale corruption and organised crime. It also made confiscation a policy objective and closed gaps in its targeted financial sanctions framework.

Monaco, listed in June 2024, strengthened its understanding of the risk of laundering the proceeds of income tax fraud committed abroad and increased outbound requests to identify and seize criminal assets abroad. It applied more sanctions for AML/CFT and beneficial ownership breaches, completed the resourcing of its FIU, improved the quality and timeliness of STRs, gave investigating judges and prosecutors more resources and increased seizures of property suspected to derive from crime.

Côte d’Ivoire, listed in October 2024, improved international cooperation, risk-based supervision, access to beneficial ownership information, the use of FIU intelligence and the number of ML and TF cases. The DR Congo, listed in October 2022, completed its national risk assessment and strategy, designated supervisors for all DNFBP sectors, resourced its FIU and demonstrated effective implementation of targeted financial sanctions.

The Monaco decision is the most relevant for Luxembourg institutions with private banking, wealth management or fund distribution links to the Principality. Grey-list status remains one input in a risk-based assessment, and EU requirements follow the EU’s own list of high-risk third countries, which the European Commission updates separately.

Vietnam receives a final warning

The grey list now comprises Angola, Bolivia, Bosnia and Herzegovina, Cameroon, Haiti, Iraq, Kenya, Kuwait, Lao PDR, Lebanon, Nepal, Papua New Guinea, South Sudan, Syria, Venezuela, Vietnam, the Virgin Islands (UK) and Yemen. The outcomes name no new additions.

The sharpest language concerns Vietnam. The FATF expressed significant concern at the pace of progress and at Vietnam’s failure to complete its action plan, whose deadlines all expired in May 2025. Open items include risk understanding, international cooperation, risk-based supervision, the regulation of virtual assets and VASPs, beneficial ownership transparency, parallel financial investigations and the monitoring of proliferation financing sanctions. The FATF expects tangible improvements by February 2027 or will consider next steps.

Deadlines have also expired for Cameroon, Haiti and South Sudan, and for South Sudan the FATF notes limited progress. On Venezuela, it repeats its particular concern about the November 2024 law on non-profit organisations and calls for the law to be re-examined in line with the risk-based approach. The FATF does not call for enhanced due diligence on grey-listed jurisdictions and points out that the Standards do not envisage de-risking; humanitarian flows, legitimate NPO activity and remittances should not be disrupted.

Myanmar and Iran: updated black list statements

The black list itself is unchanged. The DPRK and Iran remain subject to countermeasures and Myanmar to enhanced due diligence, and the FATF reiterates its call for countermeasures given heightened proliferation financing risks.

On Myanmar, the FATF repeats that fraud and cyber scam activities in the country remain extensive and present significant illicit finance risks. Myanmar has taken some steps, including planning a national anti-online scams centre and strengthening regional cooperation, but must act on these risks while having due regard for the victims of trafficking by criminal groups. Its action plan expired in September 2021, and if no further progress is made by February 2027, the FATF will consider countermeasures. The remaining items concern FIU analysis and dissemination and ML investigations in line with risk.

On Iran, the FATF acknowledges re-engagement but finds that the AML/CFT regime still has fundamental deficiencies. Iran’s legal framework does not adequately criminalise terrorist financing or establish a targeted financial sanctions regime in line with the Standards, and its reservations to the Palermo and Terrorist Financing Conventions remain overly broad. The countermeasures stay in place, including restrictions on branches, subsidiaries and correspondent relationships, and they explicitly extend to VASPs and virtual asset transactions.

For the DPRK, the FATF notes growing connectivity with the international financial system, the use of front and shell companies and opaque ownership structures, and the difficulty of assessing proliferation financing risk since the mandate of the UN 1718 Committee Panel of Experts ended.

Mutual evaluations of Mexico and the United States

The Plenary adopted the mutual evaluation reports of Mexico, conducted jointly with GAFILAT, and of the United States, conducted with the APG and CFATF. Both will be published in December 2026 after the quality and consistency review. Under the new assessment round, each country receives a time-bound roadmap of key recommended actions to be completed within three years. Institutions with dollar clearing or correspondent banking exposure will want to read the US findings once published.

Tailored assessments for low-capacity countries and a reset of the risk-based approach

The Plenary concluded a project on the challenges faced by low-capacity countries. The FATF will introduce a more tailored approach to mutual evaluations for a subset of developing countries, improve assessor training to promote a more risk-based approach and encourage dialogue on effective capacity building.

Work on the risk-based approach continues. A Learning and Development Forum in Dallas on 1–2 December 2026 will bring together supervisors, FIUs, law enforcement and financial and non-financial institutions to align on risk assessment and supervisory culture. A policy statement supporting a reinterpretation of how the risk-based approach should be implemented in practice will be published shortly afterwards. It may change what supervisors expect from compliance functions when prioritising resources on the highest risks.

The suspension of the Russian Federation’s FATF membership continues to apply.

What compliance teams should do now

Country risk models should reflect the removal of Bulgaria, Côte d’Ivoire, the DR Congo and Monaco, keeping in mind that EU obligations depend on the EU list. Exposures to Vietnam deserve attention ahead of February 2027, as do those to Myanmar, where countermeasures may follow on the same date. Fraud and scam typologies, particularly those involving Southeast Asia, mule accounts and stablecoins, belong in transaction monitoring and STR practice in line with the new scam compounds report. VASP counterparty assessments should anticipate the targeted review results in 2027, and the Dallas policy statement on the risk-based approach is likely to shape supervisory dialogue in the coming year.

The information in this article is of a general nature and is provided for informational purposes only. If you need legal advice for your individual situation, you should seek the advice of a qualified lawyer.
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Dive deeper
  • FATF ¦ Outcomes FATF Plenary, 28-30 October 2026 ¦ Link
  • FATF ¦ Jurisdictions under Increased Monitoring – 30 October 2026 ¦ Link
  • FATF ¦ High-Risk Jurisdictions subject to a Call for Action – 30 October 2026 ¦ Link
Bastian Schwind-Wagner
Bastian Schwind-Wagner Bastian is a recognized expert in anti-money laundering (AML), countering the financing of terrorism (CFT), compliance, data protection, risk management, and whistleblowing. He has worked for fund management companies for more than 24 years, where he has held senior positions in these areas.