Latest FATF Plenary Outcomes: Updates to the “Grey List” – February 2025 Update

Overview of the FATF “Grey List”

The Financial Action Task Force (FATF) maintains a “grey list” of jurisdictions under increased monitoring due to strategic deficiencies in their anti-money laundering and counter-terrorist financing (AML/CFT) measures. Countries on this list have committed to addressing these issues promptly within agreed timeframes.

Recent FATF Plenary Outcomes

During the most recent FATF plenary in February 2025, key updates to the grey list were announced:

  • New Additions: Laos and Nepal were added to the grey list, signalling the identification of strategic gaps in their AML/CFT frameworks.
  • Removal: The Philippines was removed from the grey list after demonstrating significant improvements in its AML/CFT controls.

Implications for Art Market Participants and Property Professionals
 These updates have specific consequences for AMPs and property professionals:

  • Enhanced Due Diligence: AMPs and property professionals conducting transactions involving clients or funds linked to newly grey-listed countries like Laos and Nepal will need to apply enhanced due diligence measures. This includes more rigorous verification processes and closer monitoring of transactions.
  • Transaction Risks: Engaging with clients from grey-listed jurisdictions may increase the risk of financial crime exposure, requiring firms to reassess their risk management frameworks.
  • Reputational and Regulatory Compliance: Firms must stay updated on FATF changes to remain compliant with AML regulations and protect their reputation from being associated with high-risk markets.

Staying informed about FATF updates is essential for ensuring compliance and managing risk effectively within the art and property markets.