2025 Update on “Increased Monitoring” Jurisdictions
On 24 October 2025, the Financial Action Task Force (FATF) published its latest report identifying jurisdictions placed under the category of “increased monitoring”—also widely known as the “grey list.” FATF This designation signals that the listed countries are working with the FATF to address strategic deficiencies in their regimes for combating money-laundering (ML), terrorist-financing (TF) and proliferation financing (PF), but that key reforms are still outstanding.
What Does “Increased Monitoring” Mean?
Being added to the increased-monitoring list means a country has committed to implementing an agreed action plan but is not yet fully compliant with the FATF Standards. According to the October 2025 statement, the FATF emphasises that the risk-based approach remains the correct response by financial institutions—not wholesale exclusion of business with listed jurisdictions. FATF Specifically, the FATF states:
“The FATF Standards do not envisage de-risking, or cutting off entire classes of customers, but call for the application of a risk-based approach.”
Key Implications for Financial Institutions and DNFBPs
Institutions with exposure to customers, transactions or correspondent relationships linked to jurisdictions on the list should take the following steps:
- Review whether relationships involve the listed jurisdiction and assess whether there is material risk.
- Apply enhanced due-diligence (EDD) rather than automatic exclusion. For example, increased scrutiny of beneficial ownership, expected transaction behaviour, and the effectiveness of the correspondent’s AML/CFT controls.
- Consider the business continuity and reputational implications, particularly if the entity relies on the jurisdiction for operational or client flows.
- Monitor developments in the listed jurisdiction, including whether it progresses with its action plan, or risks being moved to the “call for action” (black-list) category.
Highlighted Jurisdictions in October 2025
The update lists several countries across Africa, Latin America, the Middle East and Asia as currently under increased monitoring, including Algeria, Angola, Bulgaria, Cameroon, Côte d’Ivoire, Kenya, Lao PDR, Lebanon, Monaco, Namibia, Nepal, South Sudan, Syria, Venezuela, Vietnam and the Virgin Islands (UK). FATF Some jurisdictions no longer subject to increased monitoring—such as Burkina Faso, Mozambique, Nigeria and South Africa—have been removed following progress, further highlighting the benefit of reform.
Why This Matters in 2025-26
With regulatory, compliance and audit regimes tightening globally, even a grey-list listing can trigger heightened scrutiny by banks, third-party service providers and correspondents. Firms operating in fintech, virtual assets, corporate finance, or cross-border services should take note:
- Correspondent banks may revise risk ratings for clients with exposure to these jurisdictions.
- Due-diligence and onboarding procedures may need updating to reflect the elevated risk.
- Any engagement where the listed jurisdiction is involved must be documented, justified and monitored for changing control frameworks.
- Firms should maintain ongoing awareness of the jurisdiction’s progress under the FATF action plan so that risk strategies remain current.
Final Thoughts
The October 2025 FATF update reinforces that jurisdictions under increased monitoring are not automatically treated as banned, but rather warrant heightened vigilance. For regulated entities and compliance officers, this is not just another list—it is a prompt to review whether the firm’s risk-framework is aligned with evolving global standards. Taking proactive steps now will position firms for regulatory resilience, stronger governance and sustainable growth in the evolving AML/CFT landscape.
How Andria Papageorgiou Law Firm Can Assist You
The recent FATF update places additional pressure on regulated entities to reassess their exposure, compliance controls, and risk-management frameworks. Our firm provides comprehensive support to help you navigate these obligations efficiently and confidently.
We can begin by reviewing your current AML/CFT policies, client-onboarding procedures, and risk-assessment methodologies to ensure they reflect the heightened risks associated with jurisdictions under increased monitoring. Where necessary, we update your internal manuals, matrices, and procedural documents to align with FATF expectations and Cypriot regulatory standards.
If your business engages with clients, partners, or service providers connected to the newly listed jurisdictions, we can perform a jurisdiction-specific risk analysis, identify vulnerabilities, and recommend appropriate enhanced due-diligence measures. This includes advising on beneficial-ownership verification, transaction-monitoring adjustments, and documentation practices that withstand supervisory scrutiny.
We also assist by conducting training sessions for staff and management, explaining the practical implications of the FATF grey list and guiding teams on how to apply a risk-based approach rather than resorting to de-risking practices.
For firms in financial services, fintech, investment, forex, corporate services, or other regulated sectors, we can support you in updating your regulatory reporting, internal controls, and audit preparation, ensuring that your systems remain both compliant and robust.
If needed, we liaise directly with supervisory authorities, such as CySEC or the ICPAC-appointed AML supervisors, to address regulatory queries and support you during inspections or reviews.
By working with our office, you gain a partner who understands both the legal framework and the practical realities of compliance. Our aim is to help you mitigate risk, maintain strong governance, and continue operating confidently in a rapidly evolving AML landscape.
Feel free to contact us for further professional assistance.
Disclaimer: The information contained in this article is provided for informational purposes only, and should not be construed as legal advice on any matter. Andria Papageorgiou Law Firm is not responsible for any actions (or lack thereof) taken as a result of relying on or in any way using information contained in this article and in no event shall be liable for any damages resulting from reliance on or use of this information.
