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FATF grey list

Also written Grey list · FATF greylist · Jurisdictions under increased monitoring

The informal name for FATF's list of jurisdictions under increased monitoring — countries working with FATF that have committed to fix identified strategic deficiencies swiftly within agreed timeframes.

In plain language

The grey list is FATF's middle category. A country on it has problems in its defences against money laundering, terrorist financing and proliferation financing — but it has admitted them and agreed to fix them.

The workbook describes it as the part of FATF's statement identifying countries actively working with the FATF to address strategic deficiencies in their regimes. When FATF places a jurisdiction under increased monitoring, it means the country has committed to resolve swiftly the identified strategic deficiencies within agreed timeframes and is subject to increased monitoring. That list is often externally referred to as the grey list.

The distinction that matters for the exam is the direction of travel. A black-list country is being warned about; a grey-list country is being watched while it repairs itself.

How it works

Publication. Like the black list, the grey list comes out of the two FATF public documents or statements issued three times a year in which FATF identifies jurisdictions with weak AML/CFT measures.

The three elements of a grey listing, in the workbook's words:

  1. the country is actively working with the FATF to address strategic deficiencies
  2. it has committed to resolve swiftly the identified strategic deficiencies within agreed timeframes
  3. it is subject to increased monitoring

What the workbook does and does not prescribe. For black-listed, high-risk countries the workbook records FATF's call for enhanced due diligence and, in serious cases, counter-measures. It attaches no equivalent call to the grey list. What the SEBI framework does require is that geography be assessed:

  • Rule 9(13) requires the risk assessment to cover countries or geographic areas.
  • SEBI's client acceptance policy makes the client's location — registered office, correspondence address and any other relevant address — a defined risk factor for classifying clients as low, medium or high risk.
  • The risk assessment must take into account country specific information circulated by the Government of India and SEBI.

So a grey listing is an input to that judgement, not an automatic rule.

Why it matters to India. Chapter 1 records that India became a member of FATF in 2010 and is also a member of two FATF-style regional bodies, the Asia Pacific Group (APG) and the Eurasian Group (EAG) — the network through which mutual evaluations of member jurisdictions are carried out.

A worked example

Illustrative. "Country Y" stands for any jurisdiction under increased monitoring; the workbook names none.

Nirmal Securities Ltd reviews its client base after an FATF statement adds Country Y to the list of jurisdictions under increased monitoring. It has 140 clients with a registered or correspondence address in Country Y, holding Rs 86 crore between them.

What it does not do. It does not close the 140 accounts, and it does not reclassify all of them as high risk overnight. Nothing in the workbook requires either.

What it does.

ActionBasis
Updates its documented risk assessment to reflect the listingRule 9(13): geography is a mandatory factor; the assessment must be kept up to date
Re-runs client risk classification for the 140, using location as one factor alongside business, turnover and payment modeSEBI client acceptance policy, section 6.2.2(b)
Moves 12 clients whose funds also arrive from unrelated third parties into high riskLocation plus other risk factors
Leaves 128 salaried NRIs with modest, consistent activity in their existing category, with monitoring aligned to itExtent of monitoring aligned with risk category

Check: 12 + 128 = 140.

If Country Y later moves to the black list, the analysis changes: clients in high-risk countries are Clients of Special Category, and enhanced due diligence applies to all of them.

Why NISM asks about it

Chapter 5 (AML, CFT and PF Guidelines), section 5.2.4, defines the grey list next to the black list, and the chapter's own sample question asks which list holds the countries subject to increased monitoring. Chapter 1, section 1.3.2, supplies India's FATF membership and the FSRBs, and Chapter 6, sections 6.2.2 and 6.2.5, supply the geography factor in client classification and risk assessment.

Common exam traps

  • Increased monitoring = grey. High risk with serious strategic deficiencies = black. The workbook's sample question is exactly this.
  • A grey-list country is cooperating. It is actively working with FATF and has committed to fix its deficiencies within agreed timeframes.
  • "Swiftly within agreed timeframes" — the commitment is time-bound, not open-ended.
  • The workbook attaches the enhanced-due-diligence and counter-measures call to high-risk (black-list) countries, not to the grey list. Do not import counter-measures into a grey-list answer.
  • "Grey list" is an external label, like "black list" — neither is FATF's formal name in the workbook.
  • India joined FATF in 2010, and its FSRBs are APG and EAG.

Where this is taught

Free preparation for NISM Series XXIV

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