Geographic risk starts from three public lists, and they are not the same list. The FATF black list (call for action): 3 jurisdictions — Iran, North Korea, Myanmar — enhanced due diligence and, in the most serious cases, counter-measures. The FATF grey list (increased monitoring): 22 jurisdictions working through agreed action plans — a factor your business-wide risk assessment must weigh. The EU high-risk third-country list (Regulation (EU) 2016/1675, as amended): 25 jurisdictions where enhanced due diligence is mandatory for EU obliged entities, not discretionary.
They overlap without coinciding: Monaco sits on the grey and EU lists; Russia is on the EU list but on neither FATF list. Treating the three as one list either over-screens or under-screens.
FIRMCY applies all three to every screening automatically as a geographic-risk check, and the current membership of each is maintained on one page: firm.cy/fatf-high-risk-countries
Membership counts as of the July 2026 synchronisation. Not legal advice. Verify against the primary source before acting.
FIRMCY screens names against all of the lists above — plus a worldwide PEP database and adverse media — with fuzzy matching and an audit-ready report for every check. New organisations get 100 free credits, no card required.
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