Analysis: what the FATF's October plenary could mean for emerging-market grey listings

The Financial Action Task Force (FATF) meets in plenary in Paris from 26 to 30 October, according to its calendar. It is the first test of the decisions taken in June, when the FATF added Bosnia and Herzegovina and Iraq to its list of jurisdictions under increased monitoring, the so-called grey list, and removed Algeria and Namibia, its outcomes statement shows. That left 22 jurisdictions on the list. For banks and companies dealing with them, the October outcome matters less for what the FATF itself demands than for what follows from correspondent banks and from the EU.

Four candidates to leave, two of them emerging markets

In June the FATF made "the initial determination" that four jurisdictions had "substantially completed" their action plans and warranted an on-site assessment: Bulgaria, Côte d'Ivoire, the Democratic Republic of the Congo and Monaco, according to its June statement on jurisdictions under increased monitoring. The visit is meant to verify that reforms have begun, are being sustained and retain political backing. Removal follows only once the plenary accepts that verification.

Three of the four are expected to go. Bloomberg reported that Bulgaria, Monaco and Côte d'Ivoire are likely to be removed, with a final decision due on 30 October and no decision yet taken, the Bulgarian news agency BTA reported on 16 September. Changes need consensus among members. Côte d'Ivoire's listed reforms include greater use of international cooperation in money laundering and terrorist financing cases, risk-based supervision of financial institutions and non-financial businesses, and better access to beneficial ownership information, the FATF statement says.

The DRC is the exception. The FATF said that "given the current public health situation in the DRC", it would monitor developments to ensure any on-site assessment can take place under safe conditions, which Sumsub read as making delisting unlikely in October.

Where the deadlines have run out

The same statement is blunter about others. For Cameroon and Haiti the FATF notes continued progress, and for South Sudan limited progress, but it says all their deadlines have expired and work remains. On Vietnam it goes further: the FATF "strongly urges" it to implement its action plan as soon as possible "as all deadlines expired in May 2025". Syria and Yemen remain listed without on-site visits because of the security situation, and Kuwait and Papua New Guinea chose to defer reporting in June, so their earlier statements stand, according to a copy of the statement circulated by the Securities Commission of The Bahamas.

Expired deadlines are not a listing decision in themselves. The separate call-for-action list, covering North Korea, Iran and Myanmar, was unchanged in June, New Zealand's Department of Internal Affairs noted. But the wording tells counterparties that an exit is not close.

Iraq's first round, and the EU lag

Iraq enters the October plenary with a nine-point action plan agreed in June, including better detection of informal money or value transfer services, a legislative framework for virtual asset service providers and stronger enforcement of targeted financial sanctions, the FATF statement shows. The more immediate pressure on Iraqi banks comes from Washington: on 15 October the US Treasury designated Iraq's International Development Bank for Investment and Finance, saying it gave Iran access to US dollars (Treasury).

The FATF says it does not call for enhanced due diligence on grey-listed jurisdictions, and that its standards "do not envisage derisking, or cutting-off entire classes of customers". The EU list does carry legal weight, because the EU Anti-Money Laundering Directive requires obliged entities to apply enhanced due diligence to business relationships and transactions involving listed high-risk third countries (Article 18a), and it moves later. The Commission's Delegated Regulation (EU) 2026/83, published on 9 January 2026, removed Burkina Faso, Mali, Mozambique, Nigeria, South Africa and Tanzania and added Bolivia and the British Virgin Islands, while Delegated Regulation 2026/46 created a separate category for Russia, Malta's financial intelligence unit noted. On that pattern, any jurisdiction delisted on 30 October would remain on the EU list until the Commission amends it.

What to watch on 30 October: whether Côte d'Ivoire's exit is confirmed, whether the FATF sets new deadlines for Vietnam and Cameroon, and what it says, if anything, about Iraq's first months.

Correction, 24 October 2026: An earlier version said BTA reported the expected delistings on 16 October; it reported them on 16 September. It also said the FATF notes continued progress by South Sudan, where the FATF says its progress is limited, and left Myanmar out of the call-for-action list, which covers North Korea, Iran and Myanmar. Two source dates in the list below have also been corrected.