Following the FATF plenary in June 2025, VinciWorks has released its updated guide for all of the high risk jurisdictions for money laundering. This guide includes all of the jurisdictions subject to increased FATF monitoring, alongside countries on the EU’s High Risk Third Countries.
This guide also includes those jurisdictions which have recently been removed from international lists. For a comprehensive approach to money laundering compliance, it is advisable to factor in decisions of international bodies when conducting due diligence.
In the plenary, Croatia, Mali and Tanzania were all removed from the FATF Grey List. Bolivia and the British Virgin Islands were added.
The FATF also noted the positive progress of South Africa, and will undertake an on-site visit to the country which is the final step towards its expected removal from the Grey List in the near future.
Additionally, after over a year of delay, the EU have finally updated their own list of High Risk Jurisdictions, bringing Europe back into line with the FATF following disagreements over the UAE, which the EU Parliament maintained as high risk despite its removal from the FATF.
Countries added to the EU list:
Algeria, Angola, Côte d’Ivoire, Kenya, Laos, Lebanon, Monaco, Namibia, Nepal and Venezuela.
Countries removed from the EU list:
Barbados, Gibraltar, Jamaica, Panama, the Philippines, Senegal, Uganda and the United Arab Emirates.
What countries were added to the FATF Grey List?
Bolivia
In June 2025, Bolivia was Grey Listed following its Mutual Evaluation Report (MER) in December 2023. This decision came after FATF determined that Bolivia still faces strategic deficiencies in its anti‑money laundering and counter‑terrorism financing regime, despite political commitments to improve.
The FATF acknowledged some progress in areas such as enhanced ML/TF risk assessments, improved financial intelligence dissemination, better asset seizure and forfeiture, and stronger frameworks for investigating terrorist financing, there are still significant gaps. Core issues flagged include:
- Insufficient use of special investigative techniques in ML investigations
- Lack of risk-based supervision for designated non‑financial businesses and professions (DNFBPs) like real estate agents, lawyers, and accountants
- Inadequate mechanisms to collect and maintain accurate beneficial ownership information, and to sanction breaches
- Need for a sustained increase in money laundering investigations and prosecutions
The grey list placement means Bolivia is now subject to enhanced monitoring, requiring regular reporting on reforms, exposing it to potential reputational and financial risks in global markets.
Bolivia’s inclusion stems from FATF’s recognition that, although its government has signaled commitment and achieved technical improvements post‑2023 MER, it still must close strategic regulatory and enforcement gaps.
British Virgin Islands
In June 2025, the Financial Action Task Force added the British Virgin Islands to the Grey List due to persistent strategic deficiencies in BVI’s AML/CFT. Although BVI has taken legislative steps including improving transparency and establishing beneficial‑ownership registers, key gaps remain. The FATF plenary highlighted major issues still to be addressed:
Beneficial ownership transparency: The FATF flagged shortcomings in BVI’s publicly accessible register. The jurisdiction hasn’t fully implemented access-for-legitimate-interest provisions, missing the April 2025 UK-driven deadline.
Effectiveness of supervision: Risk-based oversight of corporate service providers (TCSPs), investment firms, and virtual asset service providers remains inadequate.
Enforcement and intelligence: FATF pointed to insufficient suspicious-activity reporting, weak usage of financial intelligence, limited asset seizure, and a lack of consistent money laundering investigations and prosecutions.
In response, BVI authorities committed to implementing an Action Plan prioritising: risk-based supervision, accessible and accurate beneficial-ownership data, improved STR quality, stepped-up enforcement, enhanced asset seizure regimes, and operationalising new asset management frameworks. They have targeted two years for completion, which is a tight timescale. This Grey Listing now places heightened scrutiny on BVI’s financial ecosystem, and requires enhanced due diligence for transactions involving the BVI.
Download the full guide to every country considered high risk for money laundering.
