FATF October 2025 Grey List Update: What UAE-Based Businesses Need to Consider

The Financial Action Task Force (FATF) has published its October 2025 update to the list of jurisdictions under increased monitoring, commonly referred to as the “grey list”. While often perceived as a technical development, these updates have practical consequences for businesses subject to Anti-Money Laundering, Counter-Terrorist Financing and Counter-Proliferation Financing (AML/CTF/CPF) obligations.

For companies operating in or through the UAE, FATF updates form a key reference point in how risk is identified, assessed and managed.

Practical impact on AML frameworks

Changes to the FATF grey list influence how organisations approach country risk classification, enhanced due diligence and transaction monitoring. Under UAE regulations, entities subject to AML/CTF/CPF obligations are expected to remain alert to such developments and reflect them in their internal compliance frameworks. This includes updating Business Risk Assessments, adjusting client risk profiling where relevant, and ensuring ongoing monitoring processes remain aligned with the evolving risk landscape.

Regulatory expectations in the UAE

The UAE AML framework is grounded in a risk-based approach. This places responsibility on regulated and designated non-financial businesses and professions to demonstrate awareness of international risk developments and to document how those developments are incorporated into policies, procedures and controls. In practice, this means that staying informed of FATF updates is not sufficient on its own. Businesses must be able to evidence how such information is assessed and operationalised within their governance and compliance structures.

Supporting risk-based compliance

Experts at Swiss Group assist clients in interpreting FATF and regional AML developments within their specific business context. Support includes assessing the relevance of grey-list updates, maintaining alignment with UAE and global regulatory standards, and embedding a proactive compliance culture.

Advisory services are led by Michael Lane, Head of Legal, and Raffaele Delorenzi, Head of Compliance, who bring extensive experience in AML governance, regulatory compliance and cross-border risk management.

Governance and resilience

In an environment of increasing regulatory scrutiny, the ability to respond promptly to international AML developments is a key component of sound governance.

Organisations that regularly review their risk frameworks and maintain alignment with FATF guidance are better positioned to manage regulatory expectations and operational risk.

The FATF October 2025 update on jurisdictions under increased monitoring is available here: 👉 https://lnkd.in/eXvfenks