FATF warning lists

High-Risk Jurisdictions subject to a Call for Action (the “black list”)

This list includes countries that have significant deficiencies in their AML/CFT regimes. These deficiencies may pose a major risk to the international financial system. Moreover, the countries on the black list have not committed themselves to an action plan to address the deficiencies identified.

The FATF expects its members to ensure that financial institutions conduct enhanced customer due diligence with regard to business relationships and transactions related to countries on this list. In the most serious cases, the FATF also calls on its members to take countermeasures against countries on this list in order to protect the international financial system.

The Black list consists of the following countries: Iran, North Korea and Myanmar.

Iran

In February 2026, the FATF renewed its call for countermeasures on Iran, saying it had not completed its action plan to address the serious deficiencies in its AML/CFT regime. FATF remains particularly concerned about Iran's high risk of terrorist and proliferation financing and the threat this entails to the international financial system.

Against this background, DNB and the Ministry of Finance urge financial institutions to continue to comply with the tighter measures with respect to transactions and business relations in connection with Iran. Based on the FATF recommendations, this could include, for example:

• ex ante collection of additional information about the purpose and intended nature of the transactions or business relationships;
  

• enhanced monitoring by increasing the number of checks performed on transactions, business relationships and virtual asset transactions, and the risk-based limitation thereof;
  

• selecting transaction patterns for further investigation.
  

• risk based review of existing correspondent relationships and preventing the establishment of new correspondent relationships, as well as not establishing branches or representative offices in the country. 

FATF also calls for:

• Refusing the establishment of subsidiaries or branches or representative offices of financial institutions and virtual asset service providers from the country concerned or otherwise taking into account the fact that the relevant financial institution or virtual asset service provider is from a country that does not have adequate AML/CFT systems.

When applying countermeasures the FATF calls for a risk based approach to financial flows involving humanitarian assistance, food and health supplies, diplomatic operating costs, and personal remittance considering the risks and international obligations.

DNB and the Ministry of Finance also reiterate the need to promptly report all unusual transactions with Iran to FIU-NL.

Institutions must consider, among other factors, geographic risk factors when establishing whether transactions qualify as unusual. This also includes the involvement in transactions of parties from countries without effective AML/CFT systems, such as Iran.

North Korea

The FATF remains concerned about North Korea's failure to address the significant deficiencies in its AML/CFT regime, and the serious threat this poses to the integrity of the international financial system. The FATF also has serious concerns with the threat posed by North Korea's nuclear proliferation and its financing. DNB and the Ministry of Finance emphasise that institutions must comply with the tighter measures regarding business relationships with North Korean residents and transactions to/from this country, also with a view to the restrictions following from the UN and EU sanctions.

Myanmar

In February 2020, Myanmar committed to address its strategic deficiencies in its AML/CFT regime.
Given the continued lack of progress and the fact that the majority of its action items have still not been addressed after the expiry of the action plan deadline, the FATF called on its members to apply enhanced due diligence measures proportionate to the risk arising from Myanmar. When applying enhanced due diligence measures, countries should ensure that flows of funds for humanitarian assistance, legitimate NPO activity and remittances are not disrupted.

The FATF urges Myanmar to work to fully address its AML/CFT deficiencies. Myanmar will remain on the list of countries subject to a call for action until its full action plan is completed.

Jurisdictions under Increased Monitoring (the “grey list”)

Jurisdictions under Increased Monitoring are countries that have serious deficiencies in their AML/CFT regimes but have expressed their commitment to address these. The FATF encourages its members to consider the specific circumstances of these countries in their AML/CFT risk assessments and measures. For each country on the list, the FATF explains the deficiencies identified and the actions that the country has committed to for addressing these deficiencies. After each plenary session, the FATF updates its statements according to the country's progress on these actions.

This list includes the following jurisdictions:

• Angola

• Bolivia

• Bosnia & Herzegowina

• British Virgin Islands

• Cameroon

• Haiti

• Iraq

• Kenya

• Kuwait

• Lao People’s Democratic Republic

• Lebanon

• Nepal

• Philippines

• Papua New Guinea

• South Sudan

• Syria

• Venezuela

• Vietnam

• Yemen

In addition to the FATF-list the European Commission added as high-risk third countries:

• the Russian Federation (from 29 January 2026)

Financial institutions are expected take the specific circumstances regarding these countries into account when taking AML/CFT measures.