Algeria, Angola, Côte d’Ivoire and Lebanon added to FATF Grey List

Following last week’s conclusion of its October 2024 plenary session, the FATF has updated the list of jurisdictions under increased monitoring. The changes to the list include the addition of Algeria, Angola, Côte d’Ivoire, and Lebanon to the grey list and the removal of Senegal.

Background Information

In our article on the Financial Action Task Force (FATF), we explained the important role that this inter-governmental organisation has in the world-wide fight against money laundering and terrorist financing. We highlighted the importance of tracking updates published by the FATF, and how changes to the list of high-risk countries maintained by the FATF may mandate changes to the type of due diligence you apply to your clients.

The FATF maintains two lists of high-risk countries – a “blacklist” and a “grey list”. The blacklist, officially known as “High-Risk Jurisdictions Subject to a Call for Action” includes countries that are considered to be non-cooperative in the global fight against money laundering and terrorist financing. The “grey list”, officially known as “Jurisdictions under Increased Monitoring” includes countries that are identified by the FATF to have strategic deficiencies in their AML/CFT regimes but are making significant efforts to improve and are working with the FATF to resolve these issues within the agreed timeframes.

These lists are usually updated every four months at the end of the FATF’s plenary session, a meeting open to delegations from all 200+ FATF member countries.

Latest FATF Lists

Added to the Grey List

Algeria has been added to the list of jurisdictions under increased monitoring. While the FATF noted some improvements the country has made since its mutual evaluation report in May 2023, a renewed commitment has now been made to address strategic deficiencies in its AML regime. These include:

• improving risk-based supervision;
• developing an effective framework for basic and beneficial ownership information;
• enhancing its regime for suspicious transactions reports;
• establishing an effective legal and institutional framework for targeted financial sanctions for terrorism financing
• implementing a risk-based approach to oversight of non-profit organisations.

Angola has also been added to the Grey List, despite progress made after the adoption of the MER’s recommendations in June 2023. Further actions include:

• enhancing its understanding of ML/TF risks;
• improving risk-based supervision of non-financial banking entities and DNFBPs;
• ensuring competent authorities have adequate, accurate and timely access to beneficial ownership information and that breaches to obligations are adequately addressed;
• demonstrating an increase in ML investigations and prosecutions;
• demonstrating the ability to identify, investigate and prosecute TF;
• demonstrating an effective process to implement targeted financial sanctions without delay.

Côte d’Ivoire has made significant improvements since following the recommendations from MER as of June 2023, but it has still been placed under increased monitoring. The country has made a high-level political commitment to work with the FATF to implement its action plan, which consists of:

• enhancing its use of international cooperation in ML/TF investigations and prosecutions;
• improving the implementation of risk-based supervision of financial institutions and designated non-financial businesses and professions, and conducting outreach campaigns to improve compliance;
• improving the verification and access of basic and beneficial ownership information of legal persons and applying sanctions in case of violation;
• enhancing the use of financial intelligence by law enforcement authorities and improving disseminations by the FIU;
• demonstrating a sustained increase in the number of ML and TF investigations and prosecutions of different types in line with the country’s risk profile and strengthening the targeted financial sanctions framework.

Lastly, the FATF has added Lebanon to the grey list. Following the mutual evaluation report in May 2023, Lebanon has made progress on several MER’s recommendations. Nonetheless, further improvements are needed in terms of:

• conducting assessments of specific terrorist financing and money laundering risks identified in the MER and ensuring that policies and measures are in place to mitigate these risks;
• enhancing mechanisms to ensure the timely and effective execution of requests for mutual legal assistance, extradition and asset recovery;
• enhancing DNFBPs’ risk understanding and applying effective, proportionate and dissuasive sanctions for breaches of AML/CFT obligations;
• ensuring beneficial ownership information is up-to-date and that there are adequate sanctions and risk-mitigating in place for legal persons;
• enhancing competent authorities’ use of products of the FIU and financial intelligence; demonstrating a sustained increase in investigations, prosecutions and court rulings for types of ML in line with the risk;
• improving its approach to asset recovery and identifying and seizing illicit cross-border movements of currency and precious metals and stones;
• pursuing TF investigations and sharing information with foreign partners related to investigations of TF as called for in the MER;
• enhancing the implementation of targeted financial sanctions without delay, particularly at DNFBPs and certain non-banking financial institutions; and undertaking targeted and risk-based monitoring of high-risk NPOs, without disrupting or discouraging legitimate NPO activities.

Countries taken off the Grey List

Senegal has been removed from the FATF Grey List, as they met the commitments stated in the action plan they had been following since February 2021.