Increased monitoring
A jurisdiction under increased monitoring works with FATF to resolve identified weaknesses under an action plan. This is often called the grey list. FATF does not call for enhanced due diligence solely because a jurisdiction is under increased monitoring.
Use a risk-based approach to the relevant information. Increased monitoring is not a direction to stop serving every customer connected with that jurisdiction.
Source: FATF: 19 June 2026 statement: introductory policy on increased monitoring.
A call for action
For high-risk jurisdictions subject to a call for action, FATF calls for enhanced due diligence. In the most serious cases, it calls for countermeasures. Read the measures in the current statement.
These statements change. A copied country list can become outdated. Neither label is itself an Australian sanctions designation.
Source: FATF: High-risk jurisdictions subject to a call for action.
- Increased monitoring
Action plan. No FATF call for enhanced CDD solely from this status.
- Call for action
Enhanced due diligence. Read any stated countermeasures.
- Australian duty
Apply the exact legal trigger to the relevant person.
FATF increased monitoring and calls for action
The two FATF processes have different implications. Australian duties require a separate legal assessment.
Separate evidence questions. An answer to one does not settle the others.
Apply the Australian condition
Section 32(d) of the AML/CTF Act links enhanced CDD to a high-risk jurisdiction for which FATF has called for enhanced due diligence. It covers the customer, beneficial owners, persons receiving the service through the customer and persons acting for the customer.
For an individual, the condition is physical presence in that jurisdiction. For a body corporate or legal arrangement, the condition is formation there. Other enhanced CDD triggers can apply even if this condition does not.
Source: Federal Register of Legislation: Section 32(d), read with the opening words of section 32.
Example: record the exact reason
In a fictional review, an analyst finds that a customer has a connection with an increased-monitoring jurisdiction. They record the current FATF statement and assess the connection. They also examine the separate Australian enhanced CDD triggers and sanctions duties.
They do not replace those decisions with a software label that says grey list.
Sources: FATF: Increased monitoring policy; Federal Register of Legislation: Section 32.