BVI STAYS ON FATF GREY LIST: Congo, three others escape increased monitoring

The British Virgin Islands has failed to secure removal from the Financial Action Task Force (FATF) grey list following the organisation's latest review in Paris, while the Democratic Republic of the Congo, Bulgaria, Côte d'Ivoire and Monaco have all been cleared of increased monitoring.

The FATF Plenary, held from October 28 to 30, 2026, announced the removals but left the BVI among jurisdictions still required to address deficiencies in combating money laundering, terrorist financing and proliferation financing.

The decision carries weight for a territory whose economy depends heavily on international financial services. Although grey-list status differs from FATF's blacklist, it can prompt international banks and investors to impose additional scrutiny, demand more extensive due diligence and increase compliance costs. FATF emphasises that grey-listing does not automatically trigger enhanced due diligence across entire customer classes, but rather calls for risk-based assessment by financial institutions.

FATF acknowledged in its October 30 update that the BVI has made progress since committing to work with FATF and the Caribbean Financial Action Task Force in June 2025. Improvements included ensuring accurate beneficial ownership information is available to authorities, improving suspicious activity reports, aligning reporting with risk and strengthening law enforcement resources.

However, five areas remain unresolved: enhancing risk-based supervision of trust and company service providers, investment businesses and virtual asset service providers; ensuring breaches of beneficial ownership obligations are sanctioned; improving financial intelligence sharing in international cases; systematically pursuing money laundering investigations and prosecutions; and increasing seizure and confiscation of criminal proceeds.

The removals of other jurisdictions illustrate what FATF expects. The Democratic Republic of the Congo, first flagged in October 2022, completed a national risk assessment, adopted an anti-money laundering strategy, designated supervisory authorities, developed risk-based supervision, strengthened its Financial Intelligence Unit and improved investigative and prosecutorial capacity. Côte d'Ivoire improved international cooperation, supervision, beneficial ownership verification and financial sanctions enforcement. Bulgaria and Monaco similarly completed their action plans across regulatory, investigative and enforcement systems.

For the BVI, the challenge is no longer introducing reforms but demonstrating they are producing measurable results. The Territory's international reputation and competitiveness depend on confidence in its regulatory framework.