FATF EU Grey List Countries Compared and Why is Russia not yet Included on either

For those keeping track of countries listed by FATF & the EU both institutions have updated their lists recently with the FATF on 24th February and the EU on 20 December 2022 (see below for the current status – which for the EU came into force for newly added countries just this week on 16th March, 2023).

FATF removed Morocco, Cambodia and added Nigeria and South Africa. The EU added The Democratic Republic of the Congo, Gibraltar, Mozambique & the UAE and removed Nicaragua, Pakistan and Zimbabwe. Of added interest, the EU list doesn’t include Albania & Türkiye (both on the FATF list) and has yet to delist Cambodia and Morocco or add Nigeria and South Africa but these are likely to happen over the next 12 months. Afghanistan and Vanuatu remain on the EU list but not on the FATF list.

Not on either list is Russia, though FATF formally suspended its FATF Membership, but did not list it on either its black or grey lists. The EU cant yet be convinced Russia meets the test for listing – the EU test is essentially a country presents an important ML threat to the EU and the country’s has certain strategic ML deficiencies. Still this is curious because the purpose and consequences of listing means EU obliged entities, including Banks and other FI’s have to apply Enhanced Due Diligence when dealing with or processing transactions related to listed countries. Certainly due to the extensive sanctions applied against Russia by the EU it is hard to imagine any EU Bank or FIs not already applying EDD against Russian customers or related transactions, but that is not yet legally required, though it will be for Gibraltan’s and Emirati’s and many others. This is a gap that should be closed.

The UK also doesn’t yet include Russia on its high risk third country list, but it had named Russia as one of a handful of countries in its NRA 2020 which will trigger UK Banks & FIs to apply EDD to Russia.

For justification that Russia should be included See: See: HERE. For the Russia Financial Crime Dashboard see HERE. For the Russia Threat Assessment See HERE.

For the EU List see HERE:

For the FATF Lists see HERE.

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