Circular Letter No. CC/2025/00000034

Circular Letter No. CC/2025/00000034
Sent to:
Credit Institutions, Financial Companies, Payment Institutions, Electronic Money Institutions and entities carrying out activities with virtual assets.
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Subject: Disclosure of FATF communications (October 2025 plenary meeting)

I. COMMUNICATIONS ISSUED BY THE FATF
With the aim of protecting the international financial system from the risks associated with money laundering and terrorist financing, as well as fostering adequate compliance with AML/CFT standards, the FINANCIAL ACTION TASK FORCE (FATF) acts to identify jurisdictions presenting strategic deficiencies in money laundering and terrorist financing prevention and to develop coordinated and decisive responses worldwide to combat these realities.

Following the plenary meeting held between October 22 and 24, 2025, the FATF published the following documents:

• HIGH-RISK JURISDICTIONS SUBJECT TO A CALL FOR ACTION, dated October 24, 2025, which identifies jurisdictions subject to countermeasures and jurisdictions with strategic deficiencies in money laundering and terrorist financing prevention that have not made sufficient progress in overcoming these deficiencies and/or have not agreed with the FATF on an action plan for this purpose. The full content of this document can be consulted at: High-Risk Jurisdictions subject to a Call for Action - 24 October 2025.

• JURISDICTIONS UNDER INCREASED MONITORING, dated October 24, 2025, which identifies jurisdictions with strategic deficiencies in money laundering and terrorist financing prevention that have developed an action plan to overcome them and are subject to a monitoring process by the FATF. The full content of this document can be consulted at: Jurisdictions under Increased Monitoring - 24 October 2025.

Regarding these documents, the following should be noted:

a) Regarding the list of High-Risk Jurisdictions Subject to a Call for Action:

• The FATF reiterates its call for the application of countermeasures against the Democratic People's Republic of Korea (North Korea) and the Islamic Republic of Iran, emphasizing an increased risk of proliferation financing (“Given heightened proliferation financing risks, the FATF reiterates its call to apply countermeasures on these high-risk jurisdictions.”).
• The Republic of the Union of Myanmar remains in the category of jurisdictions subject to the application of enhanced identification and due diligence measures proportional to the risks resulting from them, with the FATF reiterating that if no progress is made by February 2026, countermeasures will be considered.

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b) Regarding the list of Jurisdictions Under Increased Monitoring:

• Since June 2025, the FATF has assessed the progress of 19 jurisdictions, and their respective statements have been updated;
• Regarding the Plurinational State of Bolivia, the British Virgin Islands, the Republic of Haiti, the Republic of Yemen, and the Lebanese Republic, previous FATF statements have been included in this document, but these may not reflect the current state of their respective money laundering and terrorist financing prevention regimes;
• It is noted that four jurisdictions have exited: the Republic of South Africa, Burkina Faso, the Republic of Mozambique, and the Federal Republic of Nigeria.

In addition, it is important to note the continued maintenance of the suspension of the membership status of the Russian Federation.

II. Comparative Framework with Communications Issued by the FATF in June 2025

HIGH-RISK JURISDICTIONS SUBJECT TO A CALL FOR ACTION | JURISDICTIONS UNDER INCREASED MONITORING --- | --- Jurisdictions subject to the application of countermeasures | Jurisdictions subject to the application of enhanced measures | Jurisdictions subject to a monitoring process | Jurisdictions that exited the monitoring process

PLENARY MEETING
22-24 October 2025
Democratic People's Republic of Korea (North Korea) | Islamic Republic of Iran; Republic of the Union of Myanmar | Republic of Angola; Algerian Democratic and Popular Republic; Plurinational State of Bolivia; Republic of Bulgaria; Republic of Cameroon; Democratic Republic of Congo; Republic of Côte d'Ivoire; Republic of Haiti, Republic of Yemen; British Virgin Islands; Democratic People's Republic of Laos; Lebanese Republic; Principality of Monaco; Republic of Namibia; Nepal; Republic of Kenya; Syrian Arab Republic; Republic of South Sudan; Bolivarian Republic of Venezuela; Socialist Republic of Vietnam. | Republic of South Africa; Burkina Faso; Republic of Mozambique; Federal Republic of Nigeria

PLENARY MEETING
12-13 June 2025
Democratic People's Republic of Korea (North Korea) | Islamic Republic of Iran; Republic of the Union of Myanmar | Republic of South Africa; Republic of Angola; Algerian Democratic and Popular Republic; Plurinational State of Bolivia; Republic of Bulgaria; Burkina Faso; Republic of Cameroon; Democratic Republic of Congo; Republic of Côte d'Ivoire; Republic of Haiti; Republic of Yemen; British Virgin Islands; Democratic People's Republic of Laos; Lebanese Republic; Republic of Mozambique; Principality of Monaco; Republic of Namibia; Nepal; Federal Republic of Nigeria; Republic of Kenya; Syrian Arab Republic; Republic of South Sudan; Bolivarian Republic of Venezuela; Socialist Republic of Vietnam. | Republic of Croatia; Republic of Mali; United Republic of Tanzania

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III. PROCEDURES AND MEASURES TO BE ADOPTED BY INSTITUTIONS
Taking into account the content of the documents produced by the FATF and within the scope of the duty to disseminate information to which supervisory authorities are bound (Article 120 of Law No. 83/2017, of August 18 - “Law No. 83/2017”), the Bank of Portugal informs the following, regarding business relationships, occasional transactions, and operations carried out with persons, entities, and collective interest centers without legal personality1 residing or established in the jurisdictions identified below:

a. Considering the existence of a very high risk of money laundering, terrorist financing, and proliferation of weapons of mass destruction, it is determined, under the terms and for the purposes of paragraph 1(b) of Article 99 of Law No. 83/2017, the maintenance of countermeasures, proportional to those risks, regarding the DEMOCRATIC PEOPLE'S REPUBLIC OF KOREA (NORTH KOREA) and the ISLAMIC REPUBLIC OF IRAN, which must in any case include the countermeasures identified in the High-Risk Jurisdictions Subject to a Call For Action and in paragraphs (f) to (h) and (k) of paragraph 3 of Article 99 of the aforementioned Law No. 83/2017.

b. Under paragraph 2 of Article 36 and paragraph 3(b) of Article 37 of Law No. 83/2017, enhanced identification and due diligence measures shall continue to be adopted – including necessarily the measures specified in the High-Risk Jurisdictions Subject to a Call For Action – and all business relationships, occasional transactions, and operations involving the DEMOCRATIC PEOPLE'S REPUBLIC OF KOREA (NORTH KOREA), the ISLAMIC REPUBLIC OF IRAN, or the REPUBLIC OF THE UNION OF MYANMAR shall be examined with special care.

c. Regarding business relationships, occasional transactions, and operations involving jurisdictions subject to a monitoring process, or other high-risk third countries that are part of Delegated Regulation (EU) 2016/1675 of the Commission, of July 14, 2016, in its currently effective version, enhanced measures that are proportional to the risk concretely identified shall be adopted, without prejudice to the above, under the provisions of paragraph 2 of Article 36, and paragraph 1 and paragraph 3(b) of Article 37, all of the aforementioned Law No. 83/2017.

Supplementary information on the conclusions of the FATF plenary meeting can be obtained on the website www.fatf-gafi.org.
Bank of Portugal
By delegation

1 Including their respective representatives and beneficial owners.