On 30 October 2026 the FATF Plenary concluded in Paris, the first under the presidency of Giles Thomson (United Kingdom). The FATF removed Bulgaria, Côte d’Ivoire, the Democratic Republic of the Congo and Monaco from its list of jurisdictions under increased monitoring, known as the grey list. The British Virgin Islands stayed on the list: the FATF noted the steps completed and named five action-plan items still to be closed. Below we look at what changed, how banks in the EU and the UK read the list, and what the owner of a company in the BVI or another offshore jurisdiction should check before the end of 2026.
What the FATF Plenary decided on 28–30 October 2026
- Four jurisdictions left the grey list. Bulgaria, Côte d’Ivoire, DR Congo and Monaco completed their action plans, and after successful on-site visits the FATF ended their increased monitoring (FATF Plenary outcomes, 30 October 2026).
- No new jurisdictions were added. As of 30 October 2026, 18 jurisdictions remain under increased monitoring (FATF statement on jurisdictions under increased monitoring).
- Vietnam received a warning. The FATF expressed significant concern with Vietnam’s pace of progress and will consider next steps if there are no tangible improvements by the next Plenary.
- The black list is unchanged in composition: DPRK, Iran and Myanmar. The FATF updated its statements on Myanmar (fraud and scam activity) and Iran (criminalising terrorist financing, targeted financial sanctions) (statement on high-risk jurisdictions subject to a call for action).
- Virtual assets. The Plenary agreed to accelerate implementation of the FATF Standards on virtual assets in jurisdictions with materially important sectors and launched a targeted review; the results will be published in June and October 2027.
- Scam compounds. A report on the illicit financial flows linked to scam compounds was approved, the first output of the FATF roadmap on combatting fraud.
- Mutual evaluations. The reports on Mexico and the United States were adopted under the new round; publication is planned for December 2026.
The FATF grey list as of 30 October 2026: 18 jurisdictions
Angola, Bolivia, Bosnia and Herzegovina, Cameroon, Haiti, Iraq, Kenya, Kuwait, Lao PDR, Lebanon, Nepal, Papua New Guinea, South Sudan, Syria, Venezuela, Vietnam, Virgin Islands (UK), Yemen.
The FATF states that the grey list means a jurisdiction has committed to resolve its strategic deficiencies within agreed timeframes; the FATF does not call for enhanced due diligence towards these jurisdictions and asks members to take the list into account in their risk analysis, without cutting off entire classes of customers. By contrast, for the black list the FATF calls on all countries to apply enhanced due diligence and, in the most serious cases, counter-measures.
British Virgin Islands: what is done and what remains
The BVI has been under increased monitoring since June 2025, when it made a high-level political commitment to work with the FATF and CFATF. The statement of 30 October 2026 records both the progress and the remaining items.
| Completed (as assessed by the FATF) | Remaining action-plan items |
|---|---|
| Accurate and up-to-date beneficial ownership information is available to competent authorities | 1. Risk-based supervision of trust and company service providers (TCSPs), investment businesses and VASPs |
| Quality of suspicious activity reports improved, reporting in line with risk | 2. Sanctions for breaches of beneficial ownership obligations |
| Human resources of law enforcement authorities increased | 3. Dissemination of financial intelligence in international cases |
| 4. Systematic money-laundering investigations and prosecutions in line with risk | |
| 5. Increased seizure and confiscation of criminal proceeds |
The first two items concern the registered agents through which a BVI offshore company is formed: supervision of agents and penalties for errors in beneficial ownership data will only tighten. In practice this means more detailed questionnaires at incorporation and at each annual renewal, and prompt requests from the agent whenever an owner or director changes.
How banks read the list: FATF, EU and UK
- FATF. The grey list is an input to risk analysis; enhanced due diligence is mandatory only for the black list.
- European Union. The European Commission keeps its own list of high-risk third countries. Since 29 January 2026 it includes the BVI (Delegated Regulation (EU) 2026/83), and EU obliged entities apply enhanced customer due diligence to such customers under Article 18a of Directive (EU) 2015/849. That list changes by separate regulations; the FATF decision of 30 October does not amend it by itself.
- United Kingdom. Since 30 June 2026 mandatory enhanced due diligence under the UK money laundering regulations is tied only to FATF call-for-action countries (SI 2026/621, regulation 19); UK banks weigh the grey list through their own risk assessment. The FATF lists are updated on the final day of each FATF Plenary, in February, June and October (Money Laundering Advisory Notice).
For a BVI company this means: an account in an EU bank brings enhanced due diligence by regulation, while an account in the UK is checked under the bank’s own risk policy. The questions a bank asks and how to prepare the answers are covered in our article on choosing a bank for a foreign company.
What an offshore company owner should do before the end of 2026
- Check your company’s jurisdiction against the list. Of the offshore jurisdictions we work with, only the BVI is on the grey list as of 30 October 2026; Belize, Panama, the Cayman Islands, St Kitts and Nevis, Hong Kong, Singapore, the UAE and the United Kingdom are not on it, and Monaco has just left it.
- Update the company file. A current register of beneficial owners, proof of source of funds, a description of the business and the place of management. These are the first questions an agent and a bank will ask.
- Ask your bank which list it applies. An EU bank follows the Commission list; others follow their own rules.
- Keep a back-up account. A second bank or payment institution in another country removes the risk of a pause in settlements while the first bank completes its review.
- Choose a new company by task. For trading and holding structures, compare BVI and Belize and the other options in our guide “How to choose an offshore jurisdiction in 2026”.
The next review of the FATF lists takes place at the Plenary in February 2027. The FATF gives no forecast of when the BVI will leave the grey list: all five items must be completed and confirmed by an on-site visit. How long a bank review takes depends on the bank and on the completeness of the documents.
Frequently asked questions
What does the FATF grey list mean for a BVI company?
The FATF does not require enhanced due diligence for grey-list jurisdictions and asks that the list be taken into account in risk analysis. Enhanced due diligence for the BVI is mandatory in the EU, because since 29 January 2026 the BVI has been on the European Commission’s list of high-risk third countries.
Who did the FATF remove from the grey list on 30 October 2026?
Bulgaria, Côte d’Ivoire, the Democratic Republic of the Congo and Monaco: they completed their action plans, and on-site visits confirmed this.
Were any new countries added to the grey list?
No. The list of 30 October 2026 contains 18 jurisdictions. On Vietnam the FATF expressed significant concern with the pace of progress.
When can the BVI leave the grey list?
After completing the five remaining action-plan items and an FATF on-site visit. The lists are reviewed three times a year: in February, June and October. The FATF gives no specific date for the BVI.
Do you hold a BVI company or need an account for an offshore structure? Describe the business, the owners’ country of residence and the main payment flows in the form below. We will select a bank with the FATF and EU lists in mind and prepare the file for its review. About the service: banking support for an offshore company.
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