ROAD TOWN, Tortola - The British Virgin Islands remains on the Financial Action Task Force (FATF) list of jurisdictions under increased monitoring, commonly referred to as the grey list, following the organisation’s latest review, while four other jurisdictions, including the Democratic Republic of the Congo, have successfully secured their removal.

The decision was announced following the FATF Plenary held in Paris from October 28–30, 2026, where the global financial crime watchdog agreed to remove Bulgaria, Côte d’Ivoire, the Democratic Republic of the Congo and Monaco from increased monitoring.

The BVI, however, remains among the jurisdictions required to continue addressing identified deficiencies in their systems for combating money laundering, terrorist financing and proliferation financing.

The latest development raises renewed questions about the pace of the Territory’s progress and what remains necessary to secure its removal from a listing that has implications for its international financial services industry.

What is keeping the BVI on the list?

In its October 30 update, FATF acknowledged that the Virgin Islands has made progress since making a high-level political commitment to work with FATF and the Caribbean Financial Action Task Force (CFATF) in June 2025.

Among the improvements recognised were ensuring that accurate and up-to-date beneficial ownership information is available to competent authorities, improving the quality of suspicious activity reports (SARs), ensuring reporting is aligned with risk and increasing human resources within law enforcement authorities.

Despite those developments, FATF identified five areas where further work is required:

1. Enhancing risk-based supervision of trust and company service providers (TCSPs), investment businesses and virtual asset service providers (VASPs).
2. Ensuring that breaches of beneficial ownership obligations are appropriately sanctioned.
3. Improving the dissemination of financial intelligence in international cases.
4. Systematically pursuing money laundering investigations and prosecutions in line with identified risks.
5. Increasing the seizure and confiscation of criminal proceeds.

These requirements indicate that the remaining work extends beyond introducing legislation or establishing regulatory frameworks. FATF is looking for evidence that the systems are operating effectively and producing results.

Congo’s removal offers a point of comparison

The removal of the Democratic Republic of the Congo is particularly noteworthy because FATF identified a number of concrete improvements that allowed the country to complete its action plan.

The DRC was first identified with strategic deficiencies in October 2022. Its subsequent reforms included completing a national risk assessment covering money laundering and terrorist financing, adopting a national anti-money laundering and counter-terrorist financing strategy, and designating supervisory authorities across all designated non-financial businesses and professions.

It also developed and implemented a risk-based supervision plan, strengthened the resources and analytical capacity of its Financial Intelligence Unit, improved the capabilities of authorities responsible for investigating and prosecuting money laundering and terrorist financing, and demonstrated effective implementation of targeted financial sanctions relating to terrorist financing and proliferation financing.

FATF said the DRC had made significant progress and fulfilled the commitments in its action plan.

Côte d’Ivoire’s removal followed improvements in international cooperation, risk-based supervision, beneficial ownership verification, financial intelligence sharing, money laundering and terrorist financing investigations and prosecutions, and targeted financial sanctions.

Bulgaria and Monaco also completed their respective action plans, with FATF recognising improvements across their regulatory, investigative and enforcement systems.

The implications for the BVI

For the BVI, remaining on the grey list is particularly significant because international financial services are a central part of the Territory’s economy.

Although grey-list status is not the same as being placed on FATF’s blacklist, it can influence how international banks, financial institutions, investors and business partners assess a jurisdiction’s financial crime risks.

The consequences can include additional scrutiny, more extensive due diligence, increased compliance costs and challenges in maintaining international banking relationships.

FATF itself makes an important distinction: grey-listing does not automatically require enhanced due diligence or the cutting off of entire classes of customers. It calls for a risk-based approach by financial institutions.

Nevertheless, the commercial implications of remaining under increased monitoring cannot be ignored by a jurisdiction whose international reputation and competitiveness depend heavily on confidence in its regulatory framework.

The BVI has been recognised for progress, but the latest FATF statement makes clear that work remains in supervision, enforcement, international financial intelligence cooperation and asset recovery.

With the DRC and three other jurisdictions now removed, attention will inevitably turn to whether the BVI can demonstrate the sustained and measurable results required to complete its own action plan.

For the Territory, the central issue is no longer simply what reforms have been introduced, but whether those reforms are translating into demonstrable effectiveness.