3 November 2026: Country Lists updated following October 2026 FATF Plenary
The GSC would like to make operators aware that the Isle of Man Department of Home Affairs (DHA) has made amendments to the Country Lists following the October 2026 FATF Plenary.
In particular, the GSC wishes to highlight that as of 30 October 2026:
- Bulgaria, Côte d'Ivoire (Ivory Coast), Dem. Republic of the Congo and Monaco have been removed from List B(i)
- Côte d'Ivoire (Ivory Coast) has been removed from List B(ii).
- Bulgaria, Côte d'Ivoire (Ivory Coast) and Monaco have been added to List C.
- Bulgaria, Côte d'Ivoire (Ivory Coast) and Monaco have been added to List D.
Both clean and tracked changes versions of the list updates can be found on the DHA website here:
What Should You Do?
When the DHA country lists are updated, operators should consider the changes within their existing risk assessment framework and identify whether they affect relevant customers, business relationships or activity. A change to the lists does not necessarily mean that every affected customer or business relationship must automatically be reclassified, except where the requirements relating to List A apply.
List B is a risk indicator that may indicate a higher risk of ML/TF and should be considered alongside other relevant risk factors as part of the operator’s holistic customer risk assessment. Where that assessment results in a customer being identified as high risk, the enhanced CDD requirements of the Code apply.
Country list updates are also shared to support operators’ horizon scanning and ongoing understanding of jurisdictional risk. To be used effectively, they shouldn't be treated as a tick-box exercise or considered in isolation. The GSC has issued further guidance on the appropriate use of country lists in - 28 August 2026: Country Lists: A Quick Guide