FATF Plenary Updates: How Firms Should Use Them
In brief: FATF plenary updates can change country-risk signals, so firms should use them to review affected client risk ratings and enhanced due diligence triggers.
Key points
- FATF plenary updates are risk signals, not automatic client decisions.
- Country-list changes should trigger review for affected clients or matters.
- Record what changed, which clients were reviewed, and what decision followed.
What is a FATF plenary update?
FATF plenary meetings can update monitored jurisdictions, high-risk jurisdictions, standards, guidance, and public statements. These updates can affect how firms think about country risk and enhanced due diligence.
Use FATF's official publications and high-risk jurisdiction pages for current information.
What firms should do after an update
- Check whether any client, beneficial owner, counterparty, or source of funds connects to an affected jurisdiction.
- Review risk ratings where relevant.
- Decide whether enhanced due diligence or senior approval is needed.
- Update screening or country-risk notes.
- Record the review outcome.
Common mistake
The common mistake is reading a headline and making broad assumptions. FATF updates should feed a controlled review process.
Always check current official sources before deciding. UK firms should start with the UK sanctions list, the OFSI consolidated financial sanctions list, and the relevant GOV.UK regime pages.