On November 21, 2025, the Financial Crimes Enforcement Network (FinCEN) announced that the Financial Action Task Force (FATF) updated its listings of jurisdictions under increased monitoring (the grey list) in October 2025 by removing Burkina Faso, Mozambique, Nigeria, and South Africa. The FATF’s listing of high-risk jurisdictions subject to a call for action (the black list) remains unchanged.
These lists alert financial institutions about jurisdictions with strategic deficiencies in their anti-money laundering (AML), countering the financing of terrorism (CFT), and countering the financing of proliferation of weapons of mass destruction (CPF) standards.
Grey-listed jurisdictions are under increased monitoring and have committed to, or are actively working with, the FATF to address deficiencies under agreed-upon timelines. Black-listed jurisdictions are deemed to have significant strategic deficiencies in their AML/CFT/CPF regimes. FATF members should apply enhanced due diligence and, for the most serious risks, countermeasures to protect the international financial system.
FinCEN noted that the FATF reaffirmed that the three black-listed countries are Myanmar, Iran, and the Democratic People’s Republic of Korea (DPRK). Myanmar remains subject only to enhanced due diligence measures, whereas Iran and the DPRK remain subject to countermeasures.
The FATF continues to urge jurisdictions to apply two key countermeasures on Iran:
- Restrict foreign institutions: Refuse or scrutinize the establishment of subsidiaries, branches, or representative offices of financial institutions from countries lacking adequate AML/CFT systems.
- Restrict domestic expansion into high-risk countries: Prohibit financial institutions from opening branches or representative offices in countries without adequate AML/CFT systems or otherwise account for that heightened risk.
Implications for Investment Advisers
The relatively minor changes involved in this FATF release will probably not require managers to make substantive updates to their fund documents. However, investment advisers are encouraged to review and, where appropriate, update their subscription agreements and administrative agreements to reflect the latest FATF developments, especially for ongoing capital raises and upcoming fund launches.
- Subscription Agreements: Subscription agreements that identify grey-listed and/or black-listed jurisdictions in bank-wiring instructions, AML certifications, letters of reference, etc., should be updated to reflect the jurisdictions on the October 2025 grey and black lists.
- Administrative Agreements: Administrative agreements that (1) delegate services to third parties and/or affiliates and (2) identify grey-listed and/or black-listed jurisdictions that may not be delegated such services and/or are limited in the delegation of such services should be updated to reflect the jurisdictions on the October 2025 grey and black lists.
Alternatively, investment advisers whose subscription agreements or administrative agreements list FATF-member jurisdictions should ensure that those jurisdictions listed reflect the most up-to-date list of FATF members.
If you have any questions, or would like additional information, please contact one of the attorneys on our Investment Funds team.
You can subscribe to future advisories and other Alston & Bird publications by completing our publications subscription form.