The Paris-based watchdog is expected to consider the three jurisdictions at its plenary meeting from October 26 to 30, after determining in June that each had substantially completed the action plan required to address strategic deficiencies in its anti-money-laundering and counter-terrorist-financing systems.
A final decision remains subject to the FATF confirming that the reforms are being implemented effectively, are sustainable and continue to have high-level political backing. The organisation does not automatically remove a jurisdiction once an action plan is completed; an on-site assessment is normally required before the plenary decides whether increased monitoring can end.
Monaco entered the grey list in June 2024 following concerns identified by the FATF and the Council of Europe’s MONEYVAL monitoring body. The principality committed to improve its understanding of money-laundering risks, including those linked to foreign tax fraud, strengthen sanctions for compliance breaches, improve suspicious-transaction reporting and increase the seizure of suspected criminal assets.
The FATF said in June that Monaco had strengthened its risk assessment, increased outbound requests to identify and seize criminal assets abroad, improved sanctions for anti-money-laundering and beneficial-ownership breaches and completed a programme to bolster staffing at its financial intelligence unit.
It also credited Monaco with improving judicial efficiency through additional resources for investigating judges and prosecutors, applying stronger penalties for money laundering and increasing the seizure of property suspected to derive from criminal activity. Those measures cleared the way for the on-site review now feeding into the October decision.
Removal would carry particular significance for Monaco because of the central role played by private banking, wealth management, property and other services catering to international clients. Grey-list status does not amount to a call for sanctions, but it can heighten scrutiny by banks, investors and regulators assessing cross-border financial risk.
The FATF stresses that jurisdictions under increased monitoring are working actively with the organisation to resolve identified weaknesses and that its standards do not require blanket enhanced due diligence or the cutting-off of entire customer groups. Institutions are instead expected to apply a risk-based approach.
Bulgaria, placed under increased monitoring in October 2023, has also undergone an on-site assessment after the FATF found in June that it had substantially completed its action plan. Sofia said this month that government representatives met FATF and MONEYVAL assessors to review the durability of measures introduced against money laundering and terrorist financing.
The watchdog has cited Bulgaria’s progress in implementing its national strategy, improving beneficial-ownership data, strengthening supervision of higher-risk sectors, improving money-laundering investigations and prosecutions and addressing gaps in targeted financial sanctions. It has also highlighted steps to make confiscation a policy objective and strengthen monitoring of non-profit organisations vulnerable to terrorist-financing abuse.
Côte d’Ivoire, which entered the grey list in October 2024, has likewise been judged to have substantially completed its action plan. The FATF has pointed to stronger international cooperation, improved risk-based supervision of financial institutions and designated non-financial businesses, better access to beneficial-ownership information and greater use of financial intelligence by law-enforcement agencies.
It also cited a sustained increase in money-laundering and terrorist-financing investigations and prosecutions and improvements to the country’s targeted financial-sanctions framework. Côte d’Ivoire’s progress was separately reviewed this year by the Inter-Governmental Action Group against Money Laundering in West Africa.
The Democratic Republic of the Congo was also judged in June to have substantially completed its action plan and to warrant an on-site assessment, although the FATF said the timing would depend on whether such a visit could take place safely given the country’s public-health situation.
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