The Financial Crimes Enforcement Network (FinCEN) is advising U.S. financial institutions to take the Financial Action Task Force (FATF) jurisdiction lists into account when reviewing their risk-based policies and procedures. In a notice on the updated lists, FinCEN reports that the FATF, the intergovernmental body that sets global standards for combating money laundering and terrorist financing, removed Bulgaria, Côte d'Ivoire, the Democratic Republic of the Congo, and Monaco from its list of Jurisdictions Under Increased Monitoring on October 30, 2026. The separate list of High-Risk Jurisdictions Subject to a Call for Action was left unchanged.

Iran, the Democratic People's Republic of Korea (DPRK), and Burma remain on the high-risk list. The FATF continues to call for countermeasures against Iran and the DPRK, while Burma remains subject to enhanced due diligence only. FinCEN says U.S. institutions should weigh the FATF's positions as they assess their obligations and risk-based controls.

Two FATF Lists, Two Levels of Response

The FATF issues two public statements covering jurisdictions with differing degrees of strategic deficiencies. Its Jurisdictions Under Increased Monitoring list, often referred to as the “grey list,” identifies countries that are working with the organization, under an agreed timeline, to resolve identified weaknesses. Its High-Risk Jurisdictions Subject to a Call for Action statement flags significant strategic deficiencies and calls for enhanced due diligence, with countermeasures applied in the most serious cases.

For jurisdictions under increased monitoring, FinCEN reminds covered financial institutions to satisfy the due diligence requirements applicable to foreign financial institutions under 31 C.F.R. § 1010.610(a). These requirements operate alongside institutions' general anti-money laundering program obligations under 31 U.S.C. § 5318(h) and its implementing regulations.

Correspondent account programs should incorporate specific, risk-based policies, procedures, and controls. According to FinCEN, those controls should enable institutions to detect and report known or suspected money laundering conducted through accounts maintained in the United States for foreign financial institutions. Where warranted, programs should include enhanced controls and ongoing monitoring.

Money services businesses face parallel obligations concerning foreign agents or counterparties. FinCEN refers readers to its 2004 interpretive release and its guidance on agent monitoring for further detail. The notice also cautions that risk-based due diligence should not serve as justification for wholesale or indiscriminate de-risking of an entire customer class or category of financial institution.

Iran, DPRK, and Burma Retain Distinct Measures

For Burma, the FATF calls for enhanced due diligence proportionate to risk, and FinCEN advises U.S. institutions to consult existing guidance covering financial transactions involving Burma. The DPRK and Iran remain subject to calls for countermeasures. FinCEN states that U.S. institutions must comply with U.S. restrictions barring them from opening or maintaining correspondent accounts, directly or indirectly, for North Korean or Iranian financial institutions.

The notice outlines additional U.S. measures tied to Iran. It notes that the Government of Iran and Iranian financial institutions remain subject to blocked-property rules under Executive Order 13599 and the Iranian Transactions and Sanctions Regulations. It further states that U.S. persons are broadly prohibited from transactions or dealings with Iran, its government, and Iranian financial institutions under those regulations.

Separately, FinCEN says its 2019 section 311 rule prohibits covered U.S. financial institutions from opening or maintaining correspondent accounts for, or on behalf of, an Iranian financial institution. The rule also bars the use of foreign financial institutions' correspondent accounts at covered U.S. institutions to process transactions involving Iranian financial institutions.

FinCEN adds that institutions should consider the FATF's stated reasons when assessing jurisdictions that have been removed from its lists. Institutions must file a Suspicious Activity Report when they know, suspect, or have reason to suspect that a transaction involves illegally derived funds, money laundering, terrorist financing, or a violation of any other federal law or regulation. The notice directs institutions to continue applying applicable FinCEN and sanctions guidance.