FATF Grey & Black Lists: What Merchants Need to Know About AML Compliance

As your business grows across borders or handles international payments, you may face more questions - and sometimes more delays - around how and where your money moves. Some of this comes down to global financial rules that affect everyone, including UK merchants. One of the key players behind those rules is the Financial Action Task Force (FATF).

The FATF doesn’t just set the rules — it also publishes public lists of countries that haven’t done enough to stop money laundering or terrorism financing. These are known as the Grey List and Black List. If your customers, suppliers, or payments touch one of these countries, your payment provider or EMI may need to conduct additional checks. It’s not personal — it’s international compliance.

This guide explains what those lists mean, why they matter, and how you can stay ahead of delays or documentation requests as a UK-based business.

The Size of the Problem: Why These Rules Exist

Every year, it’s estimated that 2–5% of global GDP — about $800 billion to $2 trillion — is laundered through global financial systems. Shockingly, only 0.1% of those funds are ever recovered, meaning most illicit money stays hidden or undetected.  In total, financial crime — including money laundering, fraud, and other unlawful activities — is thought to exceed $3.1 trillion annually. 

With this context in mind, let’s look at who drives these stricter standards — and how they impact your business.

What Is the FATF and What Does It Do?

The Financial Action Task Force (FATF) is a global standards-setting body that evaluates countries on their efforts to prevent money laundering and terrorist financing. It publishes two public lists:

• The Grey List: Countries under close monitoring that are working to improve their systems.
• The Black List: Countries that haven’t made enough progress and are considered high-risk.

Put simply, these lists impact compliance steps for banks and EMIs — explaining how your payment process might change, depending on which countries are involved. Next, let’s examine exactly what the Grey and Black Lists mean for you.

How the FATF Grey List Affects Your Business

From a business perspective, being linked to a Grey Listed country can trigger several operational and financial considerations:

• Banks often classify entities from Grey Listed countries as higher risk and apply additional checks.
• Payment providers may slow down or flag transactions for further verification.
• Investors and partners may perceive increased compliance costs or reputational risk.

Research shows that grey listing can directly affect economic activity. For instance, SWIFT data analysis found that grey listing may correlate with up to a 10% decline in inbound payment volumes and a 16% reduction in cross-border liabilities — reflecting decreased confidence among international counterparties.

If your customer or supplier is based in a Grey Listed country — such as Algeria, Lebanon, or Cameroon — your financial institution may need to apply extra checks before approving the transaction. This might include:

• Verifying the origin or purpose of funds
• Requesting contracts or invoices
• Delaying or rerouting the transaction for review

In short, these checks reflect the system functioning as intended — to identify, assess, and mitigate financial risk.

Example: You’re a UK-based retailer paying a supplier in Cameroon for cocoa beans. Before proceeding, it’s important to check whether your bank or EMI supports payments to Cameroon — not all financial institutions process transactions involving Grey Listed countries. Even if the transaction is fully legitimate, your bank or EMI may still request supporting documents such as an invoice or a clear explanation of the payment’s purpose before releasing the funds.

How the FATF Black List Impacts Your Business

Countries on the Black List — such as Iran, the Democratic People's Republic of Korea, or Myanmar — are classified as having serious and ongoing strategic deficiencies in their AML/CFT frameworks. These jurisdictions are subject to a Call for Action from the FATF, and are considered the highest risk from a compliance perspective.

From a business standpoint, this means significantly stricter restrictions and elevated scrutiny:

• Banks and EMIs may be prohibited or unwilling to process payments involving these jurisdictions.
• Transactions may be blocked or rejected altogether, regardless of legitimacy.
• Extensive documentation may be required, including:
  • Full business justifications
  • Identity or ownership verification for all involved parties
  • Alternative payment routes or intermediaries

In many cases, even attempting a payment involving a Black Listed country can trigger compliance alerts, reporting obligations, or reputational concerns.

Example: A customer in Iran attempts to send a payment to your UK-based business. Despite the transaction being commercial in nature, your EMI or bank is likely to decline the transfer due to regulatory prohibitions and FATF risk guidance.

What to Do If Your Business Interacts with Grey or Black Listed Countries 

Even if you don’t directly operate in one of these countries, things like receiving a payment from a client there or sending money to a supplier can trigger compliance steps.

Banks and EMIs follow FATF’s rules and must do extra checks in these cases. It’s not about blocking your business — it’s about making sure the payment isn’t linked to fraud, crime, or hidden risks.

What You Can Do:

• Let your EMI or bank know early if you’re working with clients or suppliers in the listed countries.
• Keep clear records: invoices, contracts, and payment purposes help speed things up.
• Understand that a short delay now can prevent bigger problems later.
• Respond quickly if asked for documents.

These small steps protect both your business and the wider financial system.

Quick Checklist for UK Businesses

Before sending or receiving payments involving countries on the FATF Grey List, make sure you:

• Have the invoice or contract ready.
• Know the purpose of payment.
• Confirm the recipient's or sender’s name and business details.
• Be ready to respond promptly to documentation requests.
• Inform your EMI or bank early if large or unusual amounts are expected.

These simple actions help reduce delays and ensure your payments are processed smoothly and securely.

Key Takeaways for UK Merchants on FATF Grey & Black Lists and AML Compliance

• Stay aware of which countries are on the FATF lists (these change several times a year)
• Build flexibility into your payment processes — some delays are expected.
• Keep your records ready—they’re your best ally in clearing compliance checks.
• Don’t panic: most of this is standard and can be solved with quick communication.

When you treat compliance as a small but essential part of doing global business, you stay in control, avoid surprises, and protect your business from bigger risks.

Need a Smarter EMI Partner?

At Amaiz, we help UK merchants handle international payments with clarity, compliance, and confidence.

Apply for your business account today at www.amaiz.com.