FATF removes Monaco and Bulgaria from the grey list: which list still counts for your account

On 30 October 2026 the Financial Action Task Force (FATF) removed four countries from its grey list: Bulgaria, Côte d'Ivoire, the Democratic Republic of the Congo and Monaco. The statement names no new additions. That is confirmed by the US authority FinCEN, which informs American banks of the changes after every FATF meeting, in its notice of 30 October 2026. The black list, officially the list of high-risk jurisdictions subject to a call for action, remains unchanged with Iran, North Korea and Myanmar.

For Monaco, this ends its time under increased monitoring by the FATF. Anyone who holds an account there, or wants to open one, might now assume the checks will get easier. For readers in the Nordics that is not true for the time being, and the reason is a second list that hardly anyone talks about. For readers in the UK, the effect is more direct, because British law takes its lead from the FATF.

What the FATF decided

The FATF is the intergovernmental body that sets the global standards against money laundering and terrorist financing. After its plenary meetings it updates two lists.

• The grey list, officially "Jurisdictions under Increased Monitoring", names countries with strategic deficiencies in their anti-money laundering regimes that have committed to resolving them within an agreed timeframe and are actively working with the FATF. That is how FinCEN describes it in the notice.
• The black list, "High-Risk Jurisdictions Subject to a Call for Action", names countries with significant deficiencies. Here the FATF calls on all members to apply enhanced due diligence and, in the most serious cases, countermeasures.

After the October 2026 meeting, according to FinCEN, effective countermeasures should continue to be applied against Iran and North Korea. For Iran, the FATF names four specific measures, such as a ban on new correspondent banking relationships. Myanmar remains subject to enhanced due diligence, but without countermeasures.

Removal from the grey list means the FATF considers the agreed deficiencies resolved. It is an assessment of a country's defence system, not of its banks, and certainly not of your account.

Why the EU list counts in the Nordics

Here is the point the headlines leave out. Banks in the EU do not align their duties directly with the FATF list. What is legally binding is the EU list of high-risk third countries, which the European Commission keeps in its own delegated regulation.

The Commission describes the consequence like this: obliged entities such as banks must carefully examine business relationships and transactions involving high-risk countries, applying the enhanced checks of Article 18a of the Anti-Money Laundering Directive. Sweden, Denmark and Finland apply that through their own anti-money laundering legislation. Norway is outside the EU, but it takes the list over through the EEA Agreement: under section 4-10 of the Norwegian Anti-Money Laundering Regulations, the Commission's delegated regulation applies as Norwegian regulation, including its amendments up to (EU) 2026/83. What matters, therefore, is the Commission's list, not the FATF's.

The Commission does not take over FATF decisions automatically. It changes its list through its own delegated regulations, and that takes time. On 1 November 2026, the Commission's overview page names Delegated Regulations (EU) 2026/46 and 2026/83 of 3 and 4 December 2025 as the latest state. Monaco is still on that list, in force since 5 August 2025. So are Côte d'Ivoire (since 5 August 2025) and the Democratic Republic of the Congo (since 16 March 2023). Bulgaria cannot be on the EU list at all, because it covers only third countries and Bulgaria is an EU member.

For an account in Monaco this means: until the Commission amends its regulation, the legal position for clients resident in Sweden, Denmark, Finland or Norway stays exactly what it was before 30 October.

What enhanced due diligence means in practice

Article 18a(1) of the directive sets out what a bank must do at a minimum when a high-risk third country on the EU list is involved. It must:

1. obtain additional information about you as the customer, about the beneficial owner and about the intended nature of the business relationship,
2. establish the source of funds and the source of wealth, that is, not only where this particular money comes from, but how your wealth as a whole came about,
3. ask for the reasons for the transaction,
4. obtain the approval of senior management before the business relationship begins or continues, and
5. monitor the business relationship more closely, with more frequent and more intensive checks.

Under Article 18a(2), member states must also require further mitigating measures where applicable, which can go as far as enhanced or systematic reporting of transactions or limiting business relationships and transactions.

In practice you notice this in two places. First at your bank at home: if you transfer larger sums to Monaco, it can ask for evidence of where the money comes from and what it is for. Second at the bank in Monaco itself, which checks under its own law and knows that its correspondent banks in the EU look closely. How strictly private banks proceed anyway is described in Why banks reject non-residents.

For readers in the UK and the Nordics

United Kingdom. The UK is not bound by the EU list. British law refers to the FATF directly. From 23 January 2024, a "high-risk third country" under the Money Laundering Regulations 2017 was any country on either FATF list, the call for action list or the grey list, so Monaco triggered mandatory enhanced checks at UK banks while it was grey-listed. Since 30 June 2026 the rule is narrower: under regulation 33, mandatory enhanced due diligence attaches to a "FATF call for action country", the black list only. The FATF's assessments remain a geographical risk factor that every bank must weigh under regulation 33(6). With Monaco's removal from the grey list, that factor falls away as well. For a UK reader, the FATF decision of 30 October therefore takes effect without waiting for Brussels, although each bank still assesses its own risk.

Sweden, Denmark and Finland. The duty follows from Article 18a of the directive as written into national law and is tied to the EU list. As long as Monaco is on it, the FATF decision changes nothing about your bank's minimum duties.

Norway. The same applies through section 4-10 of the Anti-Money Laundering Regulations: the EU list, as incorporated into the EEA Agreement, decides, not the FATF's.

Two more countries on the EU list that account holders should know

A look at the full EU list is worthwhile, because it contains countries that play a role in banking abroad and are on no FATF list. For Nordic readers they trigger the enhanced checks; for UK readers they do not, because neither is a FATF call for action country.

Vanuatu has been on the EU list since 23 September 2016, according to the Commission's overview. For an account there, that has meant for years: transfers from the EU go through enhanced checks. What the country offers nonetheless, and where its limits lie, is described in Open a bank account in Vanuatu.

The British Virgin Islands have been on the EU list since 29 January 2026. That affects company structures more than personal accounts: for a bank in Stockholm, Copenhagen, Helsinki or Oslo, a company seated in the British Virgin Islands counts as established in a high-risk third country. Anyone who runs or wants to open a business account for such a company should expect exactly the evidence required under Article 18a. How opening a company account abroad works, and why banks check harder there, is described in Open a business account abroad.

According to the Commission, the full list comprises 26 countries on 1 November 2026, including the Russian Federation and Bolivia (both since 29 January 2026).

And Bulgaria?

Bulgaria is a different case. As an EU member, it was never on the Commission's list, because that list covers only third countries. The enhanced duties for high-risk third countries therefore never applied automatically to transfers to Bulgaria from the Nordics.

That does not mean a bank waves Bulgarian connections through. Under Article 18(1) of the directive, it must apply enhanced due diligence whenever it identifies a higher risk in an individual case or in its own risk assessment, taking into account the risk factors in Annex III of the directive; UK banks do the same under regulation 33(6). The FATF grey list was one factor in such assessments. With the removal, it falls away. For account holders in Bulgaria and for entrepreneurs with Bulgarian business partners, the decision of 30 October is therefore more noticeable than for Monaco: there is no second, legally binding list that delays the effect. How quickly a single bank adjusts its internal ratings, however, it decides for itself.

What happens now and what does not

Whether and when the Commission removes Monaco from its list is not settled. The Commission works to its own methodology, which takes FATF listings into account but does not adopt them automatically. A delegated regulation also enters into force only if Parliament and Council raise no objection within their deadline. No date can therefore be given seriously.

With the new EU Anti-Money Laundering Regulation, the framework for customer due diligence changes as a whole for EU residents; what that means for opening an account is described in Opening an account from 2027: new EU customer due diligence rules.

What does not change, regardless of any list:

• Monaco is and remains a place for substantial wealth. Minimum deposits, the personal visit and the depth of the source of wealth check depend on the bank, not on the FATF. The key figures are in Open a bank account in Monaco.
• Monaco reports under the CRS. For readers in the UK and the Nordics, an account there is not an account outside the automatic exchange of information.
• An account abroad is legal, including in a country on the EU list. The list prohibits nothing; it tightens the checks. Income remains taxable in your country of residence.

Your checklist if you move money to Monaco

1. Prepare evidence of origin before you transfer: sale contracts, tax assessments, proof of salary or profits. Your bank at home may ask for it and will do so for larger sums.
2. Document the purpose. A short, verifiable reason for the transfer saves follow-up questions.
3. Plan for both sides. The bank in Monaco checks independently of your bank at home, and both may ask for documents in different forms.
4. Leave a time buffer. Enhanced checks cost days, sometimes weeks. Anyone with a fixed date, such as a property purchase, should allow for that.
5. Watch the list that applies to you, not the FATF headlines. In the Nordics, only a change to the delegated regulation changes your bank's duties; in the UK, the FATF lists themselves are the reference.

The FATF decision of 30 October is a good sign for Monaco and is likely to influence the EU assessment in the medium term. For a Nordic account holder, what counts until then is what stands in Brussels. Whether Monaco is the right place for your wealth and your residence at all, or whether Switzerland, Liechtenstein or Singapore fit better, is what we clarify in the free consultation. You receive a written assessment within 48 hours.