Maintaining the integrity of the global financial system is dependent on stringent efforts against money laundering, terrorist financing, and proliferation financing. The FATF plays a crucial role in this fight, issuing periodic public lists, such as the infamous black list and grey list, to mobilize international action.
In June 2025, the FATF highlighted three jurisdictions under its most serious warning category and flagged 25 others for intensified monitoring.
The FATF Black List
The FATF places jurisdictions on its High‑Risk Jurisdictions subject to a Call for Action list when there are severe strategic deficiencies in AML/CFT/CPF frameworks. This black list indicates two demands:
- Enhanced due diligence by all FATF members
- In case of extreme cases, the application of countermeasures signaled at isolating the financial system from risks originating in these countries.
June 2025 High-Risk Jurisdictions
As of 13 June 2025, the FATF highlighted three countries:
- Democratic People’s Republic of Korea (DPRK)
- Iran
- Myanmar
DPRK: Illegal Finance Amidst Sanctions
The DPRK has been on the FATF’s black list for more than a decade due to explicit AML/CFT loopholes and major PF threats tied to proliferation. The FATF mandates the following countermeasures:
- Closure of correspondent banking relationships with DPRK institutions
- Shutting down DPRK bank branches or subsidiaries established abroad
- Severely restricting dealings with DPRK-affiliated individuals or entities
Despite these measures, cross-border financial channels are still there, raising the stakes, specifically given the opaque use of front firms and shell corporations. The FATF has underscored the importance of implementing UNSC sanctions and future national AML regimes before the next evaluation of proliferation financing.
Iran: Revived Call Following Action-Plan Deficiencies
Iran entered the black list in June 2016, initiated an action plan, but failed to deliver remarkable progress, specifically on authorizing the Palermo and Terrorist Financing Conventions. Following stalled updates through 2024, the FATF reactivated countermeasures as of June 2025. These measures include:
- Improved regulatory scrutiny of Iranian banks abroad
- Systematic monitoring and auditing of Iran-related financial flows
- Effective implementation of Recommendation 19 on countermeasure tools
The FATF has mentioned that Iran will remain in this category until it entirely ratifies the relevant conventions and addresses all previously flagged shortcomings.
Myanmar: On the Edge of Increased Restriction
Myanmar’s action plan, launched in February 2020 and due in September 2021, remains largely incomplete. The June 2025 update reiterates that, while Myanmar is not yet face-to-face with full countermeasures, should progress remain stalled after October 2025, heightened penalties may follow. Current expectations include:
- Increased AML/CFT supervisory standards
- Focused investigations into ML and TF
- Stronger asset seizure and confiscation mechanisms
- Sustained financial intelligence efforts by the FIU
Importantly, the FATF cautioned institutions to differentiate between illicit flows and vital humanitarian aid—especially in light of recent disasters.
June 2025 Grey List – Jurisdictions
The included nations are:
Algeria, Angola, Bolivia, Bulgaria, Burkina Faso, Cameroon, Côte d’Ivoire, Democratic Republic of Congo, Haiti, Kenya, Lao PDR, Lebanon, Monaco, Mozambique, Namibia, Nepal, Nigeria, South Africa, South Sudan, Syria, Venezuela, Vietnam, Virgin Islands (UK), Yemen.
Noteworthy Developments
- Bolivia and UK Virgin Islands joined the grey list in June 2025 .
- Croatia, Mali, and Tanzania have exited the list, demonstrating successful compliance.
For each grey-listed country, FATF highlighted targeted areas of improvement, that typically span enhanced supervision, beneficial ownership transparency, ML or TF investigations, sanctions execution, and protective measures for NGOs and remittances.
Rationale for Escalation
The FATF’s strategic listing process relies on severity:
- Persistent AML/CFT/CPF failures
- Threats to global financial integrity
- Repeat non-compliance or regression
The black list covering DPRK, Iran, and Myanmar portrays high-risk, filled with deficiencies.
Grey list members, by contrast, have displayed willingness to reform, though still face full mutual evaluations and follow-ups.
Impact of Countermeasures
FATF countermeasures are ideal and potent instruments. They include:
- Tightened correspondent banking restrictions
- Bans on foreign banks and subsidiary branches
- Regulatory audits and supervision
- Visa and transactional scrutiny
Experience shows that these measures disrupt illegal capital flows and incentivize reform.
Achievements & Challenges Ahead
Grey List Successes
- Croatia: now removed in June 2025
- Mali and Tanzania: exited grey list as they followed compliance
This demonstrates that strategic engagement, backed by structured and robust action plans, can give tangible results.
Black List Enigma
- DPRK: deeply embedded in illegal operations, compounding enforcement hurdles
- Iran: political reluctance to ratify potential conventions stalls recovery
- Myanmar: despite key, ongoing political instability undermines reforms
The Way Forward
The FATF will review, on a rolling schedule, all listed jurisdictions. Key developments to monitor:
- Iran’s Fulfillment of Conventions (Palermo, TF)
- Myanmar’s progress by October 2025
- DPRK’s adherence to UNSC financial sanctions
- Reform progress in grey‑listed countries like Angola, Kenya, and Vietnam
The FATF’s upcoming meetings in October 2025 and February 2026 will be crucial in reassessing each country.
The June 2025 FATF statements present a clear hierarchy of risk and response. The black list nations—DPRK, Iran, Myanmar—face increasing countermeasures designed to sever illegal financial channels. Meanwhile, the grey list countries remain under scrutiny but are actively progressing toward compliance.
With respect to the financial institutions, regulators, and global civil society, this indicates an unfolding era of heightened vigilance, partnership, and reform-driven compliance.
For black list updates, navigate to the official website here.
For grey list updates, navigate to the official website here.
