The Financial Action Task Force’s (“FATF”) Plenary concluded on 25 October 2024, with the announcement of changes to its list of Jurisdictions under Increased Monitoring (“Grey List”).

The changes to the Grey List are as follows:

• Senegal is no longer subject to increased monitoring by the FATF, following a successful on-site visit. The removal was due to “significant progress” in addressing the strategic anti-money laundering (“AML”), counter-terrorism financing (“CTF”) and counter-proliferation financing (“CPF”) deficiencies previously identified during its mutual evaluation. Senegal will continue to work with the FATF and the Inter Governmental Action Group against Money Laundering in West Africa to continue improving its AML/CTF/CPF regimes.

• The FATF has added Algeria, Angola, Côte d’Ivoire and Lebanon to the Grey List. These jurisdictions will now work with the FATF to address the strategic deficiencies in their AML/CTF/CPF regimes and have each committed to implement an action plan to resolve swiftly the identified strategic deficiencies within agreed timeframes.

The FATF again made no changes to its list of High-Risk Jurisdictions subject to a Call for Action (“Black List”), which at the time of writing includes the Democratic People’s Republic of Korea (“DPRK”), Iran and Myanmar.

A full list of high-risk third counties on the FATF’s Grey and Black Lists can be found on its website.

Holders of casino operating licences issued by the Gambling Commission are required by regulation 33(3)(a) of The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 to conduct enhanced customer due diligence and enhanced ongoing monitoring in any business relationship with a person established in a jurisdiction named on the Grey or Black Lists (a ‘high-risk third country’).

Next steps

We recommend that all licensees review their AML/CTF/CPF policies, procedures and controls, including business risk assessments, to ensure that they reflect the changes to the Grey and Black Lists.

In addition, licensees should diarise the dates of the next FATF Plenary meeting, so they can check if there are further updates. The FATF’s next meeting will take place between 17 – 21 February 2025.

Please get in contact with us if you require assistance reviewing your AML/CTF/CPF policies, procedures or risk assessments or with any other AML/CTF/CPF compliance matters.