FATF’s October 2025 Plenary: A Global Reset in AML/CFT Strategy & What It Means for Your Practice

The global fight against financial crime is entering a new, more dynamic phase. As the Managing Partner of Fonyam and Partners, I make it a point to dissect the pivotal shifts announced at the recent FATF Plenary. This isn’t just regulatory news; it’s a strategic map for every law firm, financial institution, and corporate compliance department. Here are the critical developments and their immediate implications:

1. Strategic Delistings: A Signal of Reform & Rising Standards

The FATF has removed four significant African jurisdictions—South Africa, Nigeria, Mozambique, and Burkina Faso—from its “Grey List” (Jurisdictions under Increased Monitoring).

Why this matters for us: This is a powerful message from the FATF. Meaningful reform is not only possible but is recognized and rewarded. It signals that the global compliance bar is being raised. For our clients, this necessitates a prompt review of all country-risk matrices. Previously elevated risk ratings for these jurisdictions may now require recalibration, affecting transactional due diligence and ongoing monitoring obligations.

2. A Sharper Focus on Asset Recovery

The adoption of new guidance on asset recovery marks a strategic pivot.

The Legal Imperative: The focus is no longer solely on preventing illicit financial flows but actively disrupting criminal networks and recovering the proceeds of crime. For our litigation and advisory practices, this means we must integrate asset-tracing and recovery considerations directly into our clients’ AML/CFT programs. The question is shifting from “Are we compliant?” to “If a breach occurs, are we equipped to reclaim the assets?”

3. The New Frontier: Generative AI & Deepfakes

The FATF’s “Horizon Scan” officially flags generative AI and deepfakes as emerging vectors for illicit finance.

The Threat Landscape: We are now in an era where sophisticated fraud and identity manipulation can be executed at scale. This moves the technology risk from an IT issue to a core legal and governance concern. Our clients’ KYC and transaction monitoring systems must be stress-tested against these novel threats. Governance frameworks need explicit protocols for AI-driven financial crime.

Actionable Takeaways for Legal and Compliance Leaders:

1. Immediately Recalibrate Country Risk: Conduct a formal review of your exposure to the delisted nations. Update your internal risk-rating models and ensure your due-diligence frameworks reflect this new reality.
2. Forensic Readiness: Bolster your AML programs with a strong asset-recovery component. Engage with forensic experts now to ensure you have the tools and partnerships ready to act when needed.
3. Governance for the Digital Age: Proactively assess your firm’s and your clients’ vulnerabilities to AI-facilitated crime. This includes training, technology upgrades, and updating internal policies.
4. Anticipate the Ripple Effects: The regulatory environment in the delisted countries will evolve. Engage with local counsel to understand new opportunities and shifting compliance obligations on the ground.

The overarching message from the FATF is clear: static compliance is obsolete. The future belongs to vigilant, adaptable, and forward-looking risk management.

Let’s connect and discuss. How is your organization preparing for these shifts in the global AML/CFT landscape? Share your thoughts in the comments.