Every Country on the FATF Grey List Right Now: Why They Are Listed and What It Means for Your Business
Introduction
As of 13 February 2026, the FATF Grey List includes 22 jurisdictions: Algeria, Angola, Bolivia, Bulgaria, Cameroon, Côte d’Ivoire, Democratic Republic of the Congo, Haiti, Kenya, Kuwait, Lao PDR, Lebanon, Monaco, Namibia, Nepal, Papua New Guinea, South Sudan, Syria, Venezuela, Vietnam, Virgin Islands (UK), and Yemen.
For every compliance officer, risk manager, and business operating in or from the UAE and Kuwait, this list is not background information. It is an active operational input that must be woven into customer risk scoring, transaction monitoring, EDD procedures, and enterprise-wide risk assessments. Every entity linked to any of these 22 jurisdictions requires heightened scrutiny.
The right governance risk and compliance software in Dubai makes this process systematic, documented, and defensible. This blog breaks down every greylisted country, why it was listed, what is required to fix it, and how First Compliance Solution equips your organization to manage the exposure.
What Greylisting Means in Practice
Grey-listed jurisdictions are not subject to FATF calls for enhanced due diligence or countermeasures. Instead, they are placed under increased monitoring, meaning they must demonstrate measurable progress in implementing FATF recommendations.
Despite the absence of mandatory countermeasures, greylisting has real consequences for businesses dealing with these countries:
| Business Impact | What It Requires From You |
|---|---|
| Country risk ratings must be elevated | Update your Enterprise-Wide Risk Assessment immediately |
| Customer risk scoring recalibrated | Flag customers and counterparties from greylisted jurisdictions as higher risk |
| Enhanced Due Diligence required | Obtain source of funds, source of wealth, transaction purpose, and senior approval |
| Transaction monitoring intensified | Increase scrutiny of frequency, size, and patterns of transactions |
| STR obligations heightened | Any unexplained transactions involving greylisted countries must be reported via goAML |
| Correspondent banking reviews | International banks may apply restrictions on payments to/from these jurisdictions |
The Five Most Significant Changes Explained
1. Proliferation Financing as a Standalone Offence
Perhaps the most consequential change in the new law is the introduction of proliferation financing (PF) as a distinct criminal offence, separate from broader counter-terrorism financing obligations. Under the 2018 framework, PF controls were embedded within general CTF provisions and were often treated as an extension of sanctions screening. The 2025 law demands a fundamentally different approach.
Businesses must now:
- ● Conduct a specific Proliferation Financing Risk Assessment (PFRA) that is separate from their general Business Risk Assessment
● Implement targeted financial sanctions (TFS) controls specifically designed to detect and prevent PF activity
● Document their PF risk exposure and the controls applied to mitigate it
● Train staff on PF typologies, red flags, and reporting obligations
This change alone will require most regulated entities to revisit their existing risk assessment frameworks from the ground up.
2. Tax Evasion as a Predicate Offence
Key Stats to Know
Key Stats to Know
Key Stats to Know
The explicit inclusion of tax evasion as a predicate offence to money laundering carries significant practical implications, particularly for businesses that serve high-net-worth individuals, corporate clients with complex cross-border structures, or customers operating in multiple jurisdictions.
Where previously tax matters were largely treated as a separate regulatory concern, compliance teams must now consider tax risk as part of their AML customer due diligence process. Enhanced due diligence for clients with opaque tax structures, offshore holdings, or exposure to high-risk jurisdictions is now an expectation, not a discretionary measure.
3. Virtual Assets and VASPs
The UAE has become one of the most active virtual asset markets in the world, and the 2025 law reflects that reality. Virtual Asset Service Providers are now explicitly brought within the scope of the AML framework, with obligations that mirror those applied to traditional financial institutions.
Key requirements for VASPs and entities transacting in virtual assets include:
- ● Full compliance with the Travel Rule for virtual asset transfers above threshold values
● Risk-based CDD on virtual asset customers, including source of funds verification
● Real-time sanctions screening against all relevant lists including OFAC, UN, and UAE local lists
● Suspicious Transaction Reporting for anomalous virtual asset activity
● Licensing verification of counterparty VASPs before processing transactions
4. Strengthened Beneficial Ownership Requirements
Beneficial ownership transparency has been a persistent weakness in the UAE’s AML framework, and the 2025 law addresses it directly. Regulated entities are now required to verify beneficial ownership information more rigorously at onboarding, review it more frequently throughout the relationship, and maintain records in a format that is accessible and auditable.
The practical implications are significant:
- Ownership structures with multiple layers or complex corporate chains require deeper investigation
- Passive reliance on customer-provided documentation is no longer sufficient
- Ongoing monitoring must flag changes in ownership structure that could indicate emerging risk
- Records must be maintained in a format that can be produced quickly to supervisory authorities
5. Enhanced Penalties and Supervisory Powers
5. Enhanced Penalties and Supervisory Powers
The 2025 law grants supervisory authorities, including the Central Bank, CBUAE, SCA, VARA, and DFSA within their respective jurisdictions, significantly broader powers to investigate, sanction, and prosecute non-compliance. Penalties have been enhanced across the board, with fines reaching into the tens of millions of dirhams for serious or repeated breaches.
The Central Bank has already signaled the direction of travel, issuing approximately AED 350 million in AML-related fines in recent months. Under the new law, that enforcement posture is backed by an even stronger legal foundation.
Who Is Affected: Regulated Entities Under the New Law
The following categories of business fall within the scope of Federal Decree-Law No. 10 of 2025:
● Banks, exchange houses, and financial institutions
● Insurance companies and brokers
● Investment firms and asset managers
● Real estate agents and brokers
● Lawyers, notaries, and independent legal professionals
● Accountants and auditors
● Company formation agents and corporate service providers
● Dealers in precious metals and stones
● Virtual Asset Service Providers (VASPs)
● Free zone entities engaged in financial or designated non-financial activities
If your business falls into any of the above categories and you have not yet conducted a gap analysis against the new law, that process should begin immediately.
What Businesses Must Do Now: A Compliance Action Plan
| Business Impact | What It Requires From You |
|---|---|
| Country risk ratings must be elevated | Update your Enterprise-Wide Risk Assessment immediately |
| Customer risk scoring recalibrated | Flag customers and counterparties from greylisted jurisdictions as higher risk |
| Enhanced Due Diligence required | Obtain the source of funds, the source of wealth, the transaction purpose, and senior approval |
| Transaction monitoring intensified | Increase scrutiny of frequency, size, and patterns of transactions |
| STR obligations heightened | Any unexplained transactions involving greylisted countries must be reported via goAML |
| Correspondent banking reviews | International banks may apply restrictions on payments to/from these jurisdictions |
Grey-listing often triggers internal compliance changes, including EDD thresholds, transaction monitoring calibration, periodic review frequency, and approvals for higher-risk relationships.
The Complete FATF Grey List: All 22 Countries Explained
1. Algeria
Listed: October 2024
Regional Body: MENAFATF
Algeria was added to the grey list with an action plan specifying improvements around implementing risk-based supervision, establishing a framework for basic and beneficial ownership information, enhancing its suspicious transaction reporting procedures, applying financial sanctions for terrorism financing, and conducting oversight of the country’s non-profit sector.
Progress note: At the February 2026 Plenary, FATF made the initial determination that Algeria has substantially completed its action plan and warrants an on-site assessment to verify that the implementation of AML/CFT reforms has begun and is being sustained. Algeria is one of the closest countries to exiting the list.
2. Angola
Listed: October 2024
Regional Body: ESAAMLG
After the June 2023 adoption of its mutual evaluation report, Angola made progress on some of its recommended actions. However, the FATF identified deficiencies in the country’s AML/CFT regime, including its understanding of ML/TF risks, supervision of non-financial entities, low prosecution rates for criminal offences, and delays in implementing sanctions.
Remaining action plan items:
- Enhance understanding of ML/TF risks
- Improve risk-based supervision of non-banking entities and DNFBPs
- Ensure competent authorities have accurate, timely access to beneficial ownership information
- Demonstrate increased ML investigations and prosecutions
- Demonstrate ability to identify, investigate, and prosecute terrorist financing
- Implement targeted financial sanctions without delay
3. Bolivia
Listed: June 2025
Regional Body: GAFILAT
Since its last mutual evaluation report in 2023, Bolivia has made some progress on its recommended actions, including improving its understanding of ML/TF risks, strengthening its financial intelligence networks, and increasing its ability to investigate terrorist financing. However, this was not enough to prevent greylisting in June 2025.
Remaining action plan items:
- Implement risk-based supervision of DNFBPs
- Ensure beneficial ownership information is accurate and current
- Increase ML investigations and prosecutions
4. Bulgaria
Listed: October 2023
Regional Body: MONEYVAL
Bulgaria’s greylisting was notable as it became the first EU member state placed on the FATF Grey List in over a decade. The deficiencies identified relate to the effectiveness of AML/CFT measures, including gaps in supervising higher-risk sectors, the quality of suspicious transaction reporting, and the effectiveness of prosecutions for complex money laundering cases.
Compliance note for UAE businesses: Bulgaria is an EU member state, and its greylisting has triggered specific EDD obligations for Bulgarian-connected transactions under UAE AML/CFT regulations.
5. Cameroon
Listed: October 2023
Regional Body: GABAC / FATF
Cameroon was identified as having strategic deficiencies across multiple dimensions of its AML/CFT/CPF framework, including gaps in financial sector supervision, limited effectiveness of suspicious transaction reporting, and weaknesses in beneficial ownership transparency across corporate structures. The country has been working through an action plan, but progress has been slower than the timeframe requires.
6. Côte d'Ivoire (Ivory Coast)
Listed: October 2024
Regional Body: GIABA
Despite making progress on some of its June 2023 MER’s recommendations, such as strengthening its legal AML/CFT framework, Côte d’Ivoire was added to the grey list in October 2024. The country will continue to work with FATF to implement its action plan, including by demonstrating a sustained increase in ML/TF prosecutions, strengthening its sanctions framework, and improving its measures to verify beneficial ownership information.
7. Democratic Republic of the Congo (DRC)
Listed: June 2024
Regional Body: GABAC / ESAAMLG
The DRC was greylisted due to systemic weaknesses in its AML/CFT framework. The key deficiencies identified include inadequate risk-based supervision of financial institutions and DNFBPs, very low volumes of suspicious transaction reporting, weak beneficial ownership transparency, and limited capacity to investigate and prosecute money laundering related to the country’s significant extractive industries and informal economy.
8. Haiti
Listed: June 2020
Regional Body: CFATF
Haiti has been on the grey list since 2020, making it one of the longest-running greylisted jurisdictions. Haiti chose to defer reporting at the February 2026 Plenary, meaning the statement issued previously for that jurisdiction is included in FATF’s publication but may not necessarily reflect the most recent status of its AML/CFT regime. Ongoing political instability, governance challenges, and gang-related criminal economies have made sustained AML/CFT reform deeply difficult.
9. Kenya
Listed: February 2024
Regional Body: ESAAMLG
Kenya was greylisted in February 2024 following its mutual evaluation, which identified persistent gaps in risk-based supervision of financial institutions and DNFBPs, weaknesses in beneficial ownership data quality, and insufficient prosecution of complex money laundering cases. Kenya is a significant regional financial hub, making its greylisting particularly impactful for businesses with East Africa exposure.
Progress note: At its February 2026 Plenary, FATF made the initial determination that Namibia has substantially completed its action plan and warrants an on-site assessment. Kenya is also progressing toward completion of its action plan, but has not yet reached the on-site assessment stage.
10. Kuwait
Listed: February 2026
Regional Body: MENAFATF
Kuwait is the most recently added jurisdiction of direct relevance to UAE-based businesses. After its initial 2015 removal, Kuwait was re-listed in February 2026 following the country’s 2024 MER. Critical shortcomings were highlighted with its AML/CFT framework, including an inadequate understanding of TF risks and a lack of investigations into complex ML cases. The country is also tasked with improving the implementation of targeted financial sanctions to ensure assets linked to terrorism can be promptly frozen.
Remaining action plan items:
- Enhance outreach to real estate agents and Dealers in Precious Metals and Stones on STR reporting
- Ensure beneficial ownership registry information is accurate, complete, and current
- Increase ML investigations and prosecutions tied to cross-border currency movements
- Improve understanding of terrorist financing risks across relevant authorities
11. Lao PDR (Laos)
Listed: February 2025
Regional Body: APG
Despite Laos’ steps to address recommendations from its 2023 MER, such as bolstering financial intelligence unit resources and eliminating bearer shares, the FATF found significant challenges remained regarding the country’s risk assessment process, regulatory oversight, and law enforcement effectiveness.
Remaining action plan items:
- Improve national risk assessment processes
- Strengthen regulatory oversight of financial institutions and DNFBPs
- Improve law enforcement’s capacity to investigate and prosecute ML cases
12. Lebanon
Listed: October 2024
Regional Body: MENAFATF
The FATF placed Lebanon on the grey list in October 2024, citing the country’s AML/CFT risk assessments, its approach to asset recovery, and its lack of up-to-date beneficial ownership information as areas for improvement. The FATF has acknowledged the social, economic, and security-related difficulties Lebanon has faced since its invasion by Israel in October 2024, and has not recommended that enhanced due diligence or countermeasures be applied to the country.
Lebanon’s position is particularly sensitive given its deep integration with regional banking networks and the significant Lebanese diaspora with business connections across the Gulf.
13. Monaco
Listed: June 2024
Regional Body: MONEYVAL
Monaco, which has the highest concentration of millionaires and billionaires in the world, was added to the grey list in June 2024 due to insufficient progress in combating illicit financial flows. This decision follows a January 2023 review by MONEYVAL, which found that while Monaco had made some progress in identifying ML/TF threats, significant gaps remained in its investigative and prosecutorial capabilities.
Monaco’s greylisting is particularly significant for wealth management firms, private banking operations, and luxury real estate professionals in Dubai who manage clients with Monaco-connected assets or residency.
14. Namibia
Listed: February 2025
Regional Body: ESAAMLG
Namibia was added to the grey list in February 2025 following identified weaknesses in its AML/CFT framework, including gaps in risk-based supervision, low beneficial ownership transparency, and insufficient prosecution activity. At the February 2026 Plenary, FATF made the initial determination that Namibia has substantially completed its action plan and warrants an on-site assessment. Namibia is among the most advanced countries in working toward removal.
15. Nepal
Listed: February 2025
Regional Body: APG
While Nepal made legislative amendments in 2024 to align with FATF standards, the country has struggled with implementation and enforcement, particularly in financial sector oversight, prosecutorial effectiveness, and regulatory compliance. The Asia/Pacific Group on Money Laundering had previously flagged Nepal’s slow response to key recommendations from its 2022 MER, which highlighted persistent gaps in monitoring high-risk sectors and financial crime enforcement.
Nepal’s large remittance economy and close financial ties with Gulf countries, including the UAE, make its greylisting relevant to exchange houses and payment service providers operating across the Gulf.
16. Papua New Guinea (PNG)
Listed: February 2026
Regional Body: APG
Papua New Guinea was added to the grey list in February 2026, a decade after its 2016 removal. Although the country made technical improvements following its first listing in 2014, its 2024 mutual evaluation revealed significant systemic AML/CFT failures. The FATF identified significant deficiencies in criminal prosecutions for ML and in the supervision of high-risk sectors, including DNFBPs.
PNG will work with FATF to implement its action plan by improving its understanding of ML risks and endorsing the National AML/CFT/CPF Strategic Plan, proactively seeking outbound international cooperation to identify and trace criminal property abroad, improving risk-based supervision of banks, MVTS and FX dealers, and higher-risk DNFBPs, and demonstrating an increase in ML investigations, prosecutions, and confiscation of criminal proceeds.
17. South Sudan
Listed: October 2021
Regional Body: ESAAMLG
South Sudan has been on the grey list since October 2021, with deficiencies spanning nearly every dimension of AML/CFT compliance, including national risk assessment, financial sector supervision, beneficial ownership transparency, STR reporting, and international cooperation. Ongoing conflict, political instability, and weak institutional infrastructure have made reform progress slow.
18. Syria
Listed: October 2010
Regional Body: MENAFATF
Syria has been on the FATF Grey List since 2010, making it one of the longest-standing entries in the list’s history. Syria chose to defer reporting at the February 2026 Plenary, and the statement issued previously for that jurisdiction may not necessarily reflect the most recent status of its AML/CFT regime. The country’s prolonged conflict, near-total institutional collapse, and severe sanctions exposure make it effectively a no-go zone for regulated businesses.
19. Venezuela
Listed: June 2024
Regional Body: GAFILAT
In early 2022, an assessment team visited Venezuela to prepare the country’s MER. The team raised concerns about ML risks associated with the nation’s large informal economy, including illegal mining. They also highlighted terrorist financing threats linked to the close economic alliance between Caracas and Tehran. Consequently, Venezuela was added to the grey list in June 2024.
Venezuela also remains subject to significant international sanctions from the US, EU, and UK, which compound the compliance obligations associated with Venezuelan-linked transactions.
20. Vietnam
Listed: June 2023
Regional Body: APG
Vietnam was greylisted in June 2023 following a mutual evaluation that identified deficiencies in risk-based supervision, beneficial ownership transparency, and effectiveness of AML/CFT controls across its rapidly growing financial services and real estate sectors. Vietnam’s integration into global trade and manufacturing supply chains makes it an active area of compliance concern for UAE trade finance and corporate service businesses.
21. Virgin Islands (UK)
Listed: June 2025
Regional Body: CFATF
In June 2025, the FATF tasked the British Virgin Islands with enhancing risk-based supervision of investment firms, virtual asset service providers, and trust or company service providers, ensuring beneficial ownership information is available to the authorities, and systematically pursuing ML investigations. The jurisdiction has made some progress since its most recent MER, such as increasing requests for international cooperation and risk-assessing its non-profit sector.
The BVI’s greylisting is of direct relevance to UAE corporate service providers, law firms, and wealth management businesses that frequently incorporate structures using BVI entities.
22. Yemen
Listed: February 2010
Regional Body: MENAFATF
Yemen has been on the grey list since 2010. In June 2014, the FATF determined that Yemen had substantially addressed its action plan at a technical level, but due to the security situation, FATF has been unable to conduct an on-site visit to confirm whether the process of implementing the required reforms has begun and is being sustained. The FATF will conduct an on-site visit at the earliest possible date. Over a decade later, Yemen’s security situation has not permitted that visit, making it effectively a permanent entry on the list under current conditions.
Summary Table: All 22 Grey List Countries at a Glance
| Country | Region | Date Listed | Primary Deficiencies | Status |
|---|---|---|---|---|
| Algeria | MENA | Oct 2024 | Supervision, beneficial ownership, STR, TF sanctions | Near on-site assessment |
| Angola | Africa | Oct 2024 | ML/TF risk understanding, supervision, prosecutions | Active action plan |
| Bolivia | Latin America | Jun 2025 | DNFBP supervision, beneficial ownership, ML prosecutions | Active action plan |
| Bulgaria | Europe (EU) | Oct 2023 | Supervision, STR quality, complex ML prosecutions | Active action plan |
| Cameroon | Africa | Oct 2023 | Financial sector supervision, STR, beneficial ownership | Active action plan |
| Côte d'Ivoire | Africa | Oct 2024 | ML/TF prosecutions, sanctions, beneficial ownership | Active action plan |
| DR Congo | Africa | Jun 2024 | Supervision, STR, beneficial ownership, extractive sector | Active action plan |
| Haiti | Caribbean | Jun 2020 | Governance, supervision, all areas | Deferred reporting |
| Kenya | Africa | Feb 2024 | DNFBP supervision, beneficial ownership, complex ML | Active action plan |
| Kuwait | MENA | Feb 2026 | TF risk understanding, complex ML, DNFBP STR, beneficial ownership | New listing |
| Lao PDR | Asia | Feb 2025 | Risk assessment, regulatory oversight, law enforcement | Active action plan |
| Lebanon | MENA | Oct 2024 | Risk assessments, asset recovery, beneficial ownership | Active action plan |
| Monaco | Europe | Jun 2024 | Investigations, prosecutions, illicit financial flows | Active action plan |
| Namibia | Africa | Feb 2025 | Supervision, beneficial ownership, prosecutions | Near on-site assessment |
| Nepal | Asia | Feb 2025 | Supervision, enforcement, sector monitoring | Active action plan |
| Papua New Guinea | Pacific | Feb 2026 | ML risk understanding, supervision, prosecutions, confiscation | New listing |
| South Sudan | Africa | Oct 2021 | National risk assessment, supervision, STR, all areas | Active action plan |
| Syria | MENA | Oct 2010 | All areas; conflict-affected | Deferred reporting |
| Venezuela | Latin America | Jun 2024 | Informal economy ML, TF, illegal mining | Active action plan |
| Vietnam | Asia | Jun 2023 | Supervision, beneficial ownership, real estate sector | Active action plan |
| Virgin Islands (UK) | Caribbean | Jun 2025 | VASP supervision, beneficial ownership, ML investigations | Active action plan |
| Yemen | MENA | Feb 2010 | All areas; conflict-affected; on-site not possible | Awaiting on-site visit |
Recent Removals: Countries That Exited the Grey List
Understanding which countries successfully exited the Grey List is just as important for risk management. These removals demonstrate what full action plan implementation looks like in practice:
| Country | Removed | Key Reforms That Secured Removal |
|---|---|---|
| South Africa | Oct 2025 | Improved STR quality, increased ML prosecutions, stronger DNFBP supervision |
| Nigeria | Oct 2025 | Completed ML/TF risk assessment, enhanced high-risk sector controls, improved beneficial ownership |
| Mozambique | Oct 2025 | Inter-agency coordination, TF risk assessment, AML/CFT strategy implementation |
| Burkina Faso | Oct 2025 | Risk-based supervision, beneficial ownership maintenance, TF law enforcement |
| Philippines | Feb 2025 | Casino sector reform, TF prosecution capacity, international cooperation |
| Croatia | Jun 2025 | TF detection, non-profit sector oversight, UN financial sanctions implementation |
| Tanzania | Jun 2025 | Risk-based supervision, prosecutorial effectiveness, FIU capability |
| UAE | Feb 2024 | Comprehensive legislative overhaul, VARA establishment, STR surge, DNFBP crackdown |
The Common Threads: Why Countries Keep Getting Listed
Across all 22 greylisted jurisdictions, several deficiency types appear repeatedly. These are the areas where global AML/CFT frameworks most commonly break down:
Beneficial Ownership Transparency: Appearing in the action plans of Algeria, Angola, Bolivia, Côte d’Ivoire, Kenya, Kuwait, Lebanon, Namibia, the Virgin Islands, and others. The ability to identify who ultimately owns and controls a company is foundational to AML/CFT, and it remains the most widespread weakness globally.
Risk-Based Supervision: Effective supervision requires regulators to allocate their resources to the highest-risk entities and sectors. Most greylisted countries apply a rule-based approach that treats all entities the same, leaving high-risk areas under-supervised.
STR Reporting Quality and Volume: Suspicious Transaction Reports are the primary intelligence tool of financial intelligence units. In most greylisted countries, STR volumes are too low, the quality of analysis is insufficient, or DNFBPs are largely not filing at all.
ML/TF Prosecutorial Effectiveness: Having criminalisation laws on paper is not enough. FATF requires demonstrated prosecutions, particularly for complex cases. Most greylisted countries prosecute only simple, low-value ML cases while complex predicate offences go uninvestigated.
Targeted Financial Sanctions Implementation: The ability to freeze assets linked to designated terrorist individuals and entities without delay is a core FATF requirement. Many greylisted countries have the legal framework but fail to act swiftly in practice.
What UAE and Kuwait Businesses Must Do Right Now
Given that two MENA-region countries are now on the Grey List and multiple others maintain links to Gulf financial flows, regulated entities in the UAE and Kuwait face a specific and immediate compliance obligation:
- Review your customer base and identify any clients with connections to all 22 greylisted jurisdictions, not just Kuwait
- Update Enterprise-Wide Risk Assessments to reflect the February 2026 Grey List
- Apply or intensify EDD for customers from Monaco (wealth management), BVI (corporate structures), Lebanon (banking), and Bulgaria (EU-based entities) as well as Kuwait and PNG
- Recalibrate transaction monitoring thresholds and typology libraries for greylisted country exposure
- Review beneficial ownership information for any corporate clients incorporated in or connected to greylisted jurisdictions
- File STRs for any transactions that cannot be risk-justified post-EDD review
- Update internal policies, procedure manuals, and staff training materials
How First Compliance Solution Helps You Manage Grey List Exposure
Managing 22 greylisted jurisdictions, each with different risk profiles, regional contexts, and compliance triggers, is a task that cannot be done manually at scale. This is where purpose-built governance risk and compliance software in Dubai becomes the critical infrastructure of your compliance programme.
First Compliance Solution is a comprehensive, AI-powered platform that brings together every module your team needs to manage grey list exposure across your entire customer base.
How the Platform Addresses Each Grey List Challenge
Sanctions and Jurisdiction Screening: First Compliance integrates with hundreds of global sanctions lists, PEP databases, and watchlists. When FATF updates the Grey List in February, June, or October, your screening configuration reflects the change. Every customer and counterparty linked to a greylisted jurisdiction is flagged automatically. No manual list management. No gaps.
Risk-Based Customer Scoring: The platform’s Risk Management module allows you to configure country-level risk weighting into your customer risk scoring model. A customer from Kuwait or Lebanon automatically scores higher and triggers an EDD workflow, regardless of which compliance officer is handling the case.
Automated EDD Workflows: EDD for greylisted country customers requires collecting additional information, including source of funds, source of wealth, transaction purpose, and senior management approval. First Compliance’s Compliance Case Management module structures this workflow, ensures it is completed, and creates a full, documented audit trail for every case.
Transaction Monitoring With Grey List Calibration: The Transaction Monitoring module screens transactions in real time, with configurable rules and thresholds that can be set differently for customers from greylisted jurisdictions. A transaction that is unremarkable for a low-risk customer becomes a priority alert when the counterparty is based in a greylisted country.
Regulatory Reporting: When a transaction cannot be risk-justified and must be reported as an STR to the UAE FIU via go AML, First Compliance’s Regulatory Reporting module supports the full preparation, review, and submission workflow.
As the most comprehensive governance risk and compliance software in Dubai for regulated entities managing multi-jurisdictional exposure, First Compliance Solution turns the February 2026 FATF update from a reactive scramble into a systematic, automated response.
Platform Modules Mapped to Grey List Management Obligations
| Compliance Obligation | First Compliance Solution Module |
|---|---|
| Grey list jurisdiction screening at onboarding | Sanction Screening |
| Customer risk scoring with country risk weighting | Risk Management |
| EDD workflows for greylisted country customers | Onboarding and Due Diligence |
| Beneficial ownership capture and verification | E-KYC with real-time face verification |
| Transaction monitoring for greylisted country exposure | Transaction Monitoring |
| Case management and EDD documentation | Compliance Case Management |
| STR preparation and goAML submission | Regulatory Reporting |
| Policy and procedure document management | Document Management |
| MLRO dashboards and risk reporting | Dashboard and Analytics |
| Regulatory deadline alerts | Alerts and Notifications |
For UAE businesses managing exposure to all 22 greylisted jurisdictions simultaneously, and for Kuwait-based entities now building their AML/CFT infrastructure under increased FATF scrutiny, the platform provides the end-to-end operational backbone that manual compliance simply cannot replicate.
Investing in robust governance risk and compliance software in Dubai is no longer a choice reserved for large financial institutions. Every regulated DNFBP, exchange house, law firm, real estate broker, and VASP faces the same Grey List obligations, and every one of them needs a system that keeps pace with every FATF update.
Contact us to request a demo and see how the platform can be configured to your sector’s specific obligations under the UAE and Kuwait AML/CFT law.
Conclusion
The FATF Grey List is a living, changing document. In the past twelve months alone, eight countries were removed, and four were added. The February 2026 update brought Kuwait and Papua New Guinea onto the list, leaving 22 jurisdictions under increased monitoring. At the June 2026 Plenary, the list will change again.
For businesses in the UAE and Kuwait, keeping pace with every Grey List update is a legal obligation, not an optional best practice. The countries on this list represent real exposure in your customer base, your transaction flows, and your correspondent relationships.
With governance risk and compliance software in Dubai from First Compliance Solution, every Grey List update becomes an automated system trigger rather than a manual compliance crisis. Your risk scores update, your EDD workflows activate, and your audit trail documents every decision, all without your team having to start from scratch each time the FATF meets.
Contact us to find out how the platform can be configured for your specific sector, customer base, and regulatory obligations.
Trusted Global Compliance Partner
Advanced Screening & Reporting Tools
Scalable Solutions for Growing Businesses
Trusted Global Compliance Partner
Advanced Screening & Reporting Tools
Scalable Solutions for Growing Businesses
First Compliance is a comprehensive compliance and due diligence software platform designed to meet the rigorous standards of global regulations. Developed by a team of experts in law, compliance, and anti-financial crime, our tool leverages advanced technology to streamline investigations and ensure thorough due diligence.
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First Compliance is a comprehensive compliance and due diligence software platform designed to meet the rigorous standards of global regulations. Developed by a team of experts in law, compliance, and anti-financial crime, our tool leverages advanced technology to streamline investigations and ensure thorough due diligence.
