The Financial Crimes Enforcement Network says U.S. financial institutions should consider the FATF jurisdiction lists when reviewing risk-based policies and procedures. Its notice on the updated lists reports that the FATF removed Bulgaria, Cote d’Ivoire, Democratic Republic of the Congo, and Monaco from Jurisdictions Under Increased Monitoring on October 30, 2026. The separate High-Risk Jurisdictions Subject to a Call for Action list did not change.
Iran, the Democratic People’s Republic of Korea (DPRK), and Burma remain on that high-risk list. The FATF continues to call for countermeasures on Iran and the DPRK, while Burma remains subject to enhanced due diligence but not countermeasures. FinCEN says U.S. institutions should consider the FATF’s positions as they assess obligations and risk-based controls.
FATF Jurisdiction Lists Set Different Responses
The FATF uses two public statements for jurisdictions with different levels of strategic deficiencies. Its Jurisdictions Under Increased Monitoring list identifies places working with the organization to address deficiencies under an agreed timeline. Its High-Risk Jurisdictions Subject to a Call for Action statement identifies significant strategic deficiencies and calls for enhanced due diligence, with countermeasures in the most serious cases.
For jurisdictions under increased monitoring, FinCEN reminds covered financial institutions to meet due diligence requirements for foreign financial institutions under 31 C.F.R. § 1010.610(a). Those requirements sit alongside institutions’ general anti-money laundering program obligations under 31 U.S.C. § 5318(h) and its implementing regulations.
Correspondent-account programs should use specific, risk-based policies, procedures, and controls. FinCEN says those controls should help institutions detect and report known or suspected money laundering through accounts maintained for foreign financial institutions in the United States. Where necessary, programs should include enhanced controls and ongoing monitoring.
Money services businesses have parallel obligations involving foreign agents or counterparties. FinCEN points to its 2004 interpretive release and guidance on agent monitoring for more detail. The notice also cautions that risk-based due diligence should not be used to justify wholesale or indiscriminate de-risking of a customer or financial institution class.
Iran, DPRK, and Burma Keep Distinct Measures
For Burma, the FATF calls for enhanced due diligence proportionate to risk, and FinCEN advises U.S. institutions to consult existing guidance on financial transactions involving Burma. The DPRK and Iran remain subject to calls for countermeasures. FinCEN says U.S. institutions must comply with U.S. restrictions against opening or maintaining correspondent accounts, directly or indirectly, for North Korean or Iranian financial institutions.
The notice describes additional U.S. measures involving Iran. It says 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 also 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 using foreign financial institutions’ correspondent accounts at covered U.S. institutions to process transactions involving Iranian financial institutions.
Financial institutions should consider the FATF’s reasons when assessing jurisdictions removed from its lists. FinCEN says institutions must file a Suspicious Activity Report when they know, suspect, or have reason to suspect a transaction involves illegally derived funds, money laundering, terrorist financing, or another federal law or regulation violation. Its notice directs institutions to continue using applicable FinCEN and sanctions guidance.
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