FATF Grey List October 2026: What the Changes Mean for Governance, Risk and Compliance in the UAE

The FATF updated its grey list on 30 October 2026, removing DRC, Monaco, Bulgaria, and Côte d’Ivoire and adding no new jurisdictions. For UAE organisations, the update is more than an AML task. Country risk runs through customer onboarding, supplier selection, correspondent relationships and the risk reports that reach the board.

What changed at the October 2026 FATF Plenary

  • Added to increased monitoring: None
  • Removed: DRC, Monaco, Bulgaria, and Côte d’Ivoire
  • Grey list total: 18 jurisdictions
  • Call-for-action list: No change

FATF grey list as of 30 October 2026

  1. Angola
  2. Bolivia
  3. Bosnia and Herzegovina
  4. Cameroon
  5. Haiti
  6. Iraq
  7. Kenya
  8. Kuwait
  9. Lao People’s Democratic Republic
  10. Lebanon
  11. Nepal
  12. Papua New Guinea
  13. South Sudan
  14. Syria
  15. Venezuela
  16. Vietnam
  17. Virgin Islands (UK)
  18. Yemen

FATF call-for-action list as of 30 October 2026

  • Iran and DPRK: the FATF calls on members to apply countermeasures.
  • Myanmar: the FATF calls for enhanced due diligence proportionate to the risk, without disrupting humanitarian aid or remittance flows.

Why a grey list change is a governance issue

Supervisors expect senior management to own the institution’s risk appetite. When the FATF moves a country onto or off its lists, three questions belong at board or risk committee level:

  • Should our risk appetite change for the delisted jurisdictions, and do our conditions for the jurisdictions that remain listed still hold?
  • How much exposure do we have, across customers, suppliers, distributors, banking partners and group entities?
  • Can we evidence our response, with dated policy changes, re-assessments and management information?

Where the update touches your risk framework

AreaWhat to review
AML/CFT complianceEWRA geographic risk, customer risk methodology, EDD triggers, screening and monitoring rules
Enterprise risk managementCountry risk in the risk register; key risk indicators for exposure to listed jurisdictions
Third-party risk managementDue diligence on vendors, agents and distributors based in or paying through listed countries
Treasury and bankingCorrespondent and payment corridors that may face more scrutiny or delays
Internal auditTest that changes were made on time and consistently across systems
Board reportingBrief summary of exposure, decisions taken and residual risk

Regulatory expectations in the UAE

Federal Decree-Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025 require financial institutions, DNFBPs and VASPs to identify, assess and mitigate their risks, including geographic risk, and to keep those assessments current. Grey-listing calls for a risk-based response; for call-for-action jurisdictions, enhanced measures and goAML high-risk country reporting (HRC/HRCA) apply.

A 30-day response plan

  • Week 1: update the high-risk country list, screening tables and the risk register.
  • Week 2: run an exposure analysis across customers and third parties linked to DRC, Monaco, Bulgaria, and Côte d’Ivoire, and review whether enhanced measures are still justified.
  • Week 3: complete re-assessments and EDD; decide on any relationships outside risk appetite.
  • Week 4: report to the board or risk committee; schedule an internal audit check.

FAQs on the FATF grey list update, October 2026

Which countries were added to the FATF grey list in October 2026?

None. No countries were added to the FATF grey list at the Plenary that concluded on 30 October 2026.

DRC, Monaco, Bulgaria, and Côte d’Ivoire were removed after completing their action plans and passing on-site visits.

Yes, where the organisation has material exposure. Boards own risk appetite, and supervisors expect evidence of senior management oversight.

It can. Third parties based in or paying through listed jurisdictions carry higher financial crime risk and should be covered by third-party due diligence.

No. Grey-listing is a risk indicator. Sanctions are legal restrictions screened separately.

Turn the FATF update into a documented risk decision

GRC Advisors helps UAE organisations update AML, enterprise and third-party risk frameworks and report clearly to their boards.
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