Zurich, 27 October 2025 – The Swiss Financial Market Supervisory Authority (FINMA) has issued a statement urging financial intermediaries in Switzerland to incorporate the latest updates from the Financial Action Task Force (FATF) into their risk management strategies. This follows the FATF’s plenary meeting in Paris from 22-24 October 2025, where the intergovernmental body revised its lists of high-risk jurisdictions subject to a call for action (commonly known as the “black list”) and jurisdictions under increased monitoring (the “grey list”).
As a FATF member, Switzerland aligns with these international standards to combat money laundering (ML), terrorist financing (TF), and proliferation financing (PF). FINMA has also requested that recognized self-regulatory organizations inform their members of these developments.
High-Risk Jurisdictions: Call for Enhanced Measures and Countermeasures
The FATF identifies high-risk jurisdictions with significant strategic deficiencies in their AML/CFT/PF regimes. For these countries, the FATF calls on all members and urges jurisdictions worldwide to apply enhanced due diligence. In the most severe cases, countermeasures are recommended to safeguard the global financial system.
The current high-risk jurisdictions remain unchanged from previous statements:
- Democratic People’s Republic of Korea (DPRK): The FATF expresses ongoing concern over DPRK’s failure to address AML/CFT deficiencies and its proliferation threats. Countries are urged to implement countermeasures, including terminating correspondent relationships with DPRK banks, closing DPRK bank branches or subsidiaries, and limiting business with DPRK persons. The FATF highlights increased financial connectivity by DPRK, elevating PF risks, and calls for heightened vigilance against front companies and opaque structures.
- Iran: Despite Iran’s recent re-engagement with the FATF and submission of updates on ratifying the Palermo Convention, the FATF deems its reservations overly broad and non-compliant with standards. Iran has failed to complete most of its 2016 action plan. The FATF reiterates calls for countermeasures, such as refusing establishment of Iranian financial institution subsidiaries or branches, prohibiting setup of branches in Iran, and applying enhanced supervisory examinations, reporting mechanisms, and audit requirements. Iran must urgently address remaining items, including criminalizing TF without exemptions, freezing terrorist assets, and ensuring customer due diligence.
- Myanmar: Myanmar’s action plan expired in 2021, with slow progress noted. The FATF calls for enhanced due diligence proportionate to risks, including increased monitoring of business relationships. If no further progress by February 2026, countermeasures may be considered. Myanmar has advanced in managing seized assets but must enhance ML investigations, use of financial intelligence, and international cooperation. The FATF emphasizes not disrupting humanitarian aid, NPO activities, or remittances, particularly for earthquake relief.
These jurisdictions pose ongoing ML/TF/PF risks, and the FATF urges robust implementation of UN Security Council Resolutions.
Jurisdictions Under Increased Monitoring: Progress and Commitments
Jurisdictions on the “grey list” are actively collaborating with the FATF or FATF-style regional bodies (FSRBs) to remedy strategic deficiencies within agreed timelines. The FATF does not mandate enhanced due diligence but encourages risk-based consideration of this information. It stresses avoiding de-risking and ensuring humanitarian, NPO, and remittance flows remain uninterrupted, in line with UNSCR 2761 (2024).
Key updates from the October 2025 review include:
- Countries with Updated Statements (Progress Reviewed Since June 2025): Algeria, Angola, Bulgaria, Cameroon, Côte d’Ivoire, Democratic Republic of the Congo (DRC), Kenya, Lao PDR, Monaco, Namibia, Nepal, South Sudan, Syria, Venezuela, and Vietnam. Highlights include:
- Algeria: Advanced risk-based supervision and NPO oversight but needs to improve sanctions and STR regimes.
- Bulgaria: Enhanced sanctioning and legislative reforms but must boost ML prosecutions and NPO monitoring.
- Cameroon: Improved interagency coordination; pending enhancements in supervision, FIU disseminations, and confiscations.
- Côte d’Ivoire: Boosted international cooperation and BO access; focus on risk-based supervision and ML/TF prosecutions.
- DRC: Addressed some technical deficiencies; remaining work on supervision and TF investigations.
- Kenya: Increased FIU disseminations; needs VASP regulation and BO framework.
- Lao PDR: Fixed TF offense; must enhance risk understanding and ML prosecutions.
- South Sudan: Developed supervision framework; pending BO collection and FIU operationalization.
- Venezuela: Committed to risk assessments; concerns over NPO law potentially misaligning with risk-based approaches.
- Vietnam: Some progress; all deadlines expired, with work on supervision, VASPs, and ML investigations.
- Deferred Reporting: Bolivia, Haiti, Lebanon, Virgin Islands (UK), and Yemen. Their prior statements apply, reflecting ongoing commitments amid challenges like security issues in Syria and Yemen.
- Jurisdictions No Longer Subject to Monitoring: Burkina Faso, Mozambique, Nigeria, and South Africa have completed their action plans and strengthened AML/CFT regimes. They will continue sustaining improvements with their respective FSRBs (GIABA for Burkina Faso and Nigeria; ESAAMLG for Mozambique and South Africa).
The FATF continues identifying new jurisdictions with deficiencies and notes some unreviewed countries.
Implications for Switzerland and Global Finance
FINMA emphasizes that Swiss financial intermediaries must integrate FATF information into risk strategies to mitigate ML/TF/PF threats. This aligns with Switzerland’s role in promoting international standards.
The FATF’s October plenary, under Mexico’s presidency, underscored depriving criminals of illicit gains, with outcomes including these list updates.
Sources: FINMA Statement (27 October 2025); FATF High-Risk Jurisdictions Subject to a Call for Action (24 October 2025); FATF Jurisdictions under Increased Monitoring (24 October 2025). Full details: https://www.finma.ch/en/news/2025/10/20251027-fatf-statement/; https://www.fatf-gafi.org/content/fatf-gafi/en/publications/High-risk-and-other-monitored-jurisdictions/Call-for-action-october-2025.html; https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-october-2025.html
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