With the addition of Turkey (as well as, through separate actions, Jordan and Mali), the international anti-money laundering body’s Gray List now includes 23 countries that FATF has determined to have ‘strategic deficiencies’ in their anti-money laundering (AML) and counter-terrorism financing (CFT) laws and regulations compared to international best practices and the standards maintained by FATF.
While inclusion on the Gray List does not have any direct legal prohibitions or legal effects on the ability of individuals and entities to engage in transactions in or with Gray List jurisdictions, many national AML/CFT regulators and international financial institutions view transactions in or involving Gray List jurisdictions as being higher risk and, as a result, in the case of financial institutions, may seek to reduce their exposure to Gray List jurisdictions due to AML/CFT concerns or subject transactions involving such jurisdictions to heightened due diligence.
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