Beyond the Grey List: What FATF Delisting Confirms—and What It Does Not—for Mauritius and Seychelles

On 30 October 2026, at the close of its Plenary in Paris (28–30 October), the Financial Action Task Force (FATF) removed four jurisdictions from its list of jurisdictions under increased monitoring (the "grey list"), and no jurisdiction was added, and the list fell from 22 to 18.

The four jurisdictions removed were:-

• Monaco

• Bulgaria

• Côte d'Ivoire

• The Democratic Republic of the Congo (DRC)

In each case, the FATF found that the Action Plan had been completed within the agreed timeframe, after an on-site visit verified the reforms.

What does delisting actually confirm

FATF delisting is not a general certificate of good health. It confirms three things:

1. The Action Plan is complete. The FATF first determines that a plan has been substantially completed — the trigger for an on-site visit — and confirms completion upon delisting.

2. Implementation is real. The on-site visit verifies that the reforms have begun and are being sustained, and that political commitment remains in place.

3. Monitoring returns to normal. The jurisdiction leaves the FATF's increased monitoring process and continues with the ordinary follow-up by its FATF-style regional body (FSRB).

That is the full extent of it. The technical compliance ratings, effectiveness ratings across the 11 Immediate Outcomes, and the risk of a future listing are still open questions for the mutual-evaluation and follow-up cycle.

The exits are a useful lens for Mauritius and Seychelles -

• Two of the four exits are African.

  • Côte d'Ivoire continues its work through GIABA.

  • The DRC through GABAC and ESAAMLG.

• The exits are a useful lens for Mauritius and Seychelles —

  • Two ESAAMLG members, one of whom has gone through the grey-list process and the other has remained outside it.

  • Both now face something more demanding than listing or delisting: a new mutual evaluation, with Seychelles first in line.

The African exits of October 2026

• Côte d'Ivoire was placed under increased monitoring in October 2024, following its June 2023 mutual evaluation by GIABA.

  • The FATF's published statements on its Action Plan covered, among other items, the use of international cooperation in money-laundering and terrorist-financing investigations and prosecutions, risk-based supervision, the dissemination of financial intelligence by the FIU, and a sustained increase in terrorist-financing investigations and prosecutions in line with its risk profile.

  • It exited in two years.

• The DRC has been listed since October 2022.

  • The FATF's statements on its Action Plan covered, among other items, disseminating its national risk assessment, developing and implementing risk-based supervision, collecting adequate, accurate, and up-to-date beneficial ownership information on legal persons, and increasing the FIU's resources and the quality of the financial intelligence it sends to law enforcement.

  • It exited in four years.

• Different speeds, same sequence:

  • Action Plan, on-site verification, removal, return to FSRB follow-up.

• One practical caution.

  • FATF delisting does not instantly move every other list. At the time of writing, the European Union's list of high-risk third countries still includes Côte d'Ivoire, the DRC, and Monaco, pending an amending delegated regulation by the Commission. Firms with EU-facing obligations or EU correspondent relationships should expect that lag.

What does this mean for Mauritius?

• Mauritius was placed on the grey list in February 2020 following its 2018 ESAAMLG mutual evaluation.

• After an on-site visit on 13–15 September 2021, the FATF removed it on 21 October 2021. At that point, Mauritius was Compliant or Largely Compliant on 39 of the 40 Recommendations; by its 5th Enhanced Follow-up Report in September 2022, it was Compliant on 26 and Largely Compliant on the remaining 14.

• Removal from the UK and EU high-risk lists followed. Mauritius nevertheless remains in enhanced follow-up with ESAAMLG on effectiveness.

• The next test is fixed. Government guidance states that the mutual evaluation begins in March 2027, with the ESAAMLG on-site visit planned for January–February 2028 and adoption of the report expected in August–September 2028.

• The October 2026 exits reinforce a sequence Mauritius has already completed.

• The implication is continuity, not novelty: the credibility gained in 2021 is real, but it will be retested.

  • A strong technical-compliance record will not carry the evaluation.

  • Effectiveness will — investigations, prosecutions and confiscation, risk-based supervision in practice, and beneficial-ownership information that is accurate and accessible, not merely required.

What does this mean for Seychelles?

• Seychelles is not on the FATF grey list.

• It has, however, been in ESAAMLG enhanced follow-up since its September 2018 mutual evaluation, which rated it Compliant on 10 Recommendations, Largely Compliant on 10, Partially Compliant on 16 and Non-Compliant on 4 — and found a Low level of effectiveness on 10 of the 11 Immediate Outcomes.

• Technical progress since then has been substantial.

  • The 13th Enhanced Follow-up Report and 6th Technical Compliance Re-rating, approved by the ESAAMLG Task Force in March 2026 and published on 14 May 2026, upgraded Recommendation 15 (new technologies, including virtual assets) to Largely Compliant — from Non-Compliant in 2018 and Partially Compliant in August 2025.

  • Seychelles is now Compliant on 14 Recommendations, Largely Compliant on 24, and Partially Compliant on 2: Recommendations 6 and 7, the targeted financial sanctions regimes for terrorist and proliferation financing. None are Non-Compliant.

• On tax transparency,

  • The OECD Global Forum's reassessment, published on 21 January 2026, rated Seychelles Largely Compliant overall on exchange of information on request, up from Partially Compliant.

  • The EU removed Seychelles from Annex II of its list of non-cooperative jurisdictions for tax purposes on 17 February 2026; it had been on Annex I between October 2023 and February 2024.

• The point most commentary misses are timing.

  • ESAAMLG's assessment calendar schedules Seychelles' possible on-site visit for June/July 2027, with a plenary discussion in March/April 2028 — ahead of Mauritius.

  • Follow-up reports assess only technical compliance; they do not re-rate effectiveness.

  • The ratings that will matter most in the next evaluation are the ones that have not been revisited since 2018.

  • Staying outside and increasing monitoring while closing technical gaps is a strong achievement.

  • Demonstrating effectiveness — including in targeted financial sanctions, international business companies, non-resident clients and virtual-asset activity — is the work of the next eight months.

What does delisting not confirm?

Delisting ends one formal process; it does not end scrutiny.

• Effectiveness lags technical compliance. A jurisdiction can exit the grey list with strong technical ratings and still face pointed findings on the Immediate Outcomes at its next evaluation.

• Commitment must be sustained. Enforcement inconsistency, governance issues or new risk vectors — virtual assets, beneficial-ownership opacity, cross-border flows — can reopen questions.

• Lists move at different speeds. The FATF, the EU, other standard-setters and correspondent banks' own country-risk models each update on their own timetable and by their own criteria. A clean FATF status is necessary but not sufficient for low friction.

What should firms do now?

• Review; do not auto-downgrade. Revisit the country-risk ratings for Bulgaria, Côte d'Ivoire, the DRC and Monaco under your own methodology, record the rationale and approval, and check whether any EU-list obligations still apply to the relationship.

• Seychelles firms: treat mid-2027 as the deadline. Evidence of effectiveness — risk-based customer due diligence, quality of suspicious transaction reporting, accurate beneficial ownership records, and sanctions screening — will be tested in practice.

• Mauritius firms: use 2027 to close the gap between policy and practice before the on-site visit in early 2028.

• Boards: ask for management information that shows the controls are working, not just that they exist.

Conclusion

• The October 2026 exits of the DRC and Côte d'Ivoire confirm that African jurisdictions can complete FATF Action Plans, pass on-site verification and return to ordinary FSRB monitoring.

  • For Mauritius, the parallel is direct: it has done so and must now show that the gains of 2021 are durable in practice.

  • For Seychelles, the lesson is different: staying off the grey list and closing technical gaps is valuable, but its next evaluation comes first and will be decided on effectiveness.

• Delisting is a verified transition, not a permanent exemption. The grey list is not the only mechanism through which strategic deficiencies are identified.

END

Nov 4, 2026

Sources

• FATF, Outcomes FATF Plenary, 28–30 October 2026: https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-october-2026.html

• FATF, Jurisdictions under Increased Monitoring (statements of October 2024, February 2024, February 2025 and February 2026): https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions.html

• Financial Services Commission Mauritius, FATF & ESAAMLG: https://www.fscmauritius.org/amlcftcpf/financial-action-task-force-fatf-eastern-and-southern-africa-anti-money-laundering-group-esaamlg/

• Government of Mauritius, Mauritius AML/CFT/CPF Portal (Mutual Evaluation 2027): https://muamlcft.govmu.org/muamlcft/

• ESAAMLG, Third Round of Mutual Evaluations Assessments Calendar: https://www.esaamlg.org/schedules

• ESAAMLG, Seychelles 13th Enhanced Follow-up Report & 6th Technical Compliance Re-rating (2026): https://www.esaamlg.org/reports/Seychelles%20FUR-March%202026.pdf

• Seychelles Nation, "Seychelles gains FATF upgrade", 28 May 2026: https://nation.sc/articles/30902/seychelles-gains-fatf-upgrade

• OECD Global Forum, Seychelles 2026 (Second Round, In-depth Review): https://www.oecd.org/en/publications/2026/01/global-forum-on-transparency-and-exchange-of-information-for-tax-purposes-seychelles-2026-second-round-in-depth-review_ca4f0da6.html

• Council of the EU, EU list of non-cooperative jurisdictions — timeline: https://www.consilium.europa.eu/en/policies/eu-list-of-non-cooperative-jurisdictions/timeline-eu-list-of-non-cooperative-jurisdictions/