Results of the FATF Plenary: June 2022

The FATF plenary of 14 to 17 June 2022 produced four decisions that mattered operationally: Russia's role in the organisation was severely limited, Gibraltar was added to the list of jurisdictions under increased monitoring, Malta was removed from it after twelve months, and the mutual evaluations of Germany and the Netherlands were adopted.

This is a record of that specific meeting rather than a live status page. Where a June 2022 decision has since been overtaken, the current position is given next to it.

Key takeaways

• Malta left the grey list on 17 June 2022, less than twelve months after becoming the first EU member state ever placed under increased monitoring on 25 June 2021.
• Gibraltar was the only addition at this plenary and stayed listed until 23 February 2024.
• The June 2022 restrictions on Russia were a step rather than an endpoint. FATF suspended Russia's membership on 24 February 2023 and that suspension still stands.
• Germany and the Netherlands were both assessed as technically strong and both were criticised on beneficial ownership, the same subject the plenary was consulting on through its Recommendation 25 white paper.
• FATF listings reach EU-regulated firms through a separate instrument on a long lag. Gibraltar entered the EU high-risk third country list in December 2022 and only left it in August 2025.

What did FATF decide about Russia at the June 2022 plenary?

FATF agreed to severely limit the Russian Federation's role and influence within the organisation, citing the invasion of Ukraine. In practice that meant losing leadership and co-chair positions and losing the ability to represent FATF externally, as recorded in the outcomes of the 14 to 17 June 2022 plenary.

The measures escalated twice more. In October 2022 the plenary barred Russia from current and future FATF project teams and excluded it from meetings of the FATF-style regional bodies in its capacity as an FATF member. On 24 February 2023 the plenary suspended Russia's membership outright, a decision recorded in FATF's statement on the Russian Federation and in the February 2023 plenary outcomes.

Two points are easy to get wrong. Suspension is not listing: Russia has never appeared on the grey list or the black list, so no FATF-derived enhanced due diligence trigger attaches to it. Sanctions exposure to Russia comes from OFAC, the EU, the UK and other national regimes, not from FATF.

Which jurisdictions changed grey-list status at this plenary?

Two, and only two. Gibraltar was added to the list of jurisdictions under increased monitoring and Malta was removed from it. No jurisdiction moved on or off the call-for-action list at this meeting.

Gibraltar's listing is a useful illustration that grey-listing turns on effectiveness rather than statute quality. The two items in its action plan, set out on FATF's Gibraltar country page, were that supervisors of trust and company service providers, lawyers, gaming businesses and estate agents should apply effective, proportionate and dissuasive sanctions for AML/CTF breaches, and that Gibraltar should pursue more final confiscation judgements proportionate to its risk profile.

Neither item required new primary legislation. Both required enforcement output that a supervisor could point to: penalties imposed, cases published, judgements obtained. Our Gibraltar coverage page carries the current position.

Why was Malta able to leave the grey list in under a year?

Malta was listed on 25 June 2021, the first EU member state to be placed under increased monitoring. The concerns were narrow and concrete: beneficial ownership information held on Maltese entities was not reliably accurate, and financial intelligence was not being used effectively to pursue tax-related money laundering.

That narrowness is why the exit was quick. Malta's Financial Intelligence Analysis Unit confirmed the delisting on 17 June 2022, after FATF reviewed progress made since March 2022 and conducted an on-site visit. An action plan of two or three verifiable items can be closed inside a review cycle; one that requires a rebuilt supervisory function cannot.

There is a structural point worth noting for EU-facing firms. The EU high-risk third country list only covers third countries, so Malta's FATF listing never produced an EU-level enhanced due diligence obligation. Firms that keyed their controls solely to the EU list would have seen no change at all in either direction. See the Malta coverage page for the current regime detail.

What did the mutual evaluations of Germany and the Netherlands conclude?

Both reports were adopted at this plenary and published in August 2022. Germany's evaluation ran from an on-site visit in November 2021 to adoption on 17 June 2022, with the report published on 25 August 2022. The Federal Ministry of Finance's own account describes technical compliance as strong and the overall result as mid-table, with several reforms too recent to demonstrate effectiveness, and places Germany in enhanced follow-up with annual reporting.

The Netherlands received a similar shape of verdict in its 2022 mutual evaluation, following an on-site visit between 27 October and 18 November 2021. Technical compliance was strong, understanding of money laundering risk was good, and international cooperation on virtual asset cases was significant. The gaps were in the regulation of virtual asset service providers, in resources for tackling unlicensed activity, and in beneficial ownership, where Dutch law permitted a senior managing director to be registered as a pseudo beneficial owner where no true owner could be identified.

What did the plenary agree on beneficial ownership of trusts?

FATF had already tightened Recommendation 24 on legal persons in March 2022. At this plenary it turned to legal arrangements, approving the release of a white paper for public consultation on revising Recommendation 25, with comments due by 1 August 2022.

The questions put out for consultation were the ones that decide how much work a KYB function has to do: which legal arrangements fall in scope, how foreign trusts should be treated, what obligations sit on trustees, how the beneficial owner of an arrangement is defined, and what obstacles block access to accurate and current information. Delegates also agreed to seek targeted stakeholder views before finalising guidance on the revised Recommendation 24 in October 2022.

The revisions to Recommendation 25 were agreed at the February 2023 plenary, deliberately aligned with Recommendation 24 so that trusts and companies are treated coherently. For screening and onboarding teams the direction was clear from June 2022 onwards: trustee, settlor, protector and beneficiary all need the same look-through treatment as a corporate ownership chain.

What did FATF set as its priorities under the incoming presidency?

Marcus Pleyer's German presidency ended with this plenary. T. Raja Kumar of Singapore took office on 1 July 2022 for a two-year term, the first Singapore presidency since the country joined FATF in 1992.

The published objectives for 2022 to 2024 named four priorities: strengthening asset recovery, countering the illicit finance of cyber-enabled crime, improving the effectiveness of global AML measures, and reinforcing FATF's partnerships with the regional bodies that assess most of the world's jurisdictions. Our post on the Singapore presidency priorities traces how those objectives were worked through.

Asset recovery is the one that produced the most durable change, because it pushed the standards towards outcomes that can be counted. That framing is also visible in Gibraltar's action plan item on confiscation judgements agreed at the same meeting.

Where do the June 2022 decisions stand in 2026?

Every listing decision from this plenary has since been superseded, which is exactly why a plenary write-up should never be used as a live reference. The table below sets the June 2022 position against the position after the plenary of 17 to 19 June 2026.

The pattern across four years is that grey-list membership churns steadily while the standards themselves move slowly. A jurisdiction risk model built on a hard-coded country list ages badly; one built on a feed with an effective date does not.

How should a compliance team turn a plenary outcome into a control change?

Start with the instrument that actually binds you, which is rarely FATF itself. FATF publishes a list; your enhanced due diligence obligation usually comes from a national or regional instrument that copies that list across on its own timetable. Gibraltar shows the size of the gap in both directions.

FATF grey-listed Gibraltar on 17 June 2022, but EU-regulated firms only picked up a mandatory enhanced due diligence trigger when Delegated Regulation (EU) 2023/410 added it, adopted 19 December 2022. Coming off was slower still: FATF delisted Gibraltar on 23 February 2024, yet the EU obligation only fell away when Delegated Regulation (EU) 2025/1184 of 10 June 2025 entered into force on 5 August 2025, some seventeen months later.

That gap has to be handled deliberately. Record which list each rule keys off, hold both the FATF and the EU effective dates against each country, and be able to reproduce which rule set applied on a given date when a supervisor asks why a 2024 file was treated as high risk. MemberCheck maintains country risk data against list effective dates for this reason rather than against a single blended score.

Mutual evaluation reports deserve the same treatment as listings. A report naming beneficial ownership accuracy or virtual asset supervision as a weakness is a fair predictor of where that country's supervisor will look next, which is why the German and Dutch findings above were worth reading in full by firms operating there. See our jurisdiction risk page, sanctions and PEP screening, the explainer on what mutual evaluations mean for financial institutions, the February 2023 plenary write-up, and the wider jurisdictions and regulation collection.