FATF keeps Myanmar on its call-for-action list and warns Vietnam it will consider next steps

Implications for lenders

Lenders with customers, remittance flows or counterparties linked to Myanmar may need to keep enhanced due diligence and closer transaction monitoring in place, while avoiding blanket refusal of legitimate remittances. Lenders in or funding Vietnam can review whether foreign banks, investors or payment partners may ask for more due-diligence information if the FATF takes next steps. For Laos, a documented risk-based assessment rather than blanket de-risking remains the expected approach.

Implications

Facts

Myanmar: the FATF's plenary in Paris ended on 30 October 2026. Reuters reported that Myanmar and Iran remain on the list of high-risk jurisdictions subject to a call for action and that the FATF reinforced its warning on Myanmar. In its previous statement of 19 June 2026, as reproduced in a circular to reporting institutions dated 21 July 2026, the FATF called for enhanced due diligence proportionate to the risk arising from Myanmar, not countermeasures, and said it would consider countermeasures if no further progress was made by October 2026. That statement also asked that flows for humanitarian assistance, legitimate non-profit activity and remittances be "neither disrupted nor discouraged". The reports of the October outcome do not mention a move to countermeasures.

Vietnam: Vietnam remains on the list of jurisdictions under increased monitoring. Reuters reported that the FATF expressed significant concern about the pace of progress and said it "will consider next steps if Vietnam does not make tangible improvements" before the next plenary. In June the FATF had noted that all of Vietnam's action-plan deadlines expired in May 2025; open items included regulation of virtual assets and their service providers, risk-based supervision, beneficial ownership and monitoring of proliferation-financing sanctions.

Laos and the list: the FATF removed 4 jurisdictions ¹ from increased monitoring, and reports of the updated list show no additions. A published summary of the updated list still includes the Lao PDR, which committed to its action plan in February 2025. For jurisdictions under increased monitoring the FATF does not call for enhanced due diligence; it asks institutions to take the listing into account in a risk-based approach.

Analysis

Over time, the three Mekong listings sit at different stages. Myanmar's action plan expired in September 2021 and the FATF moved to call for enhanced due diligence in October 2022, so by October 2026 it had spent four years on the call-for-action list. Vietnam was listed in June 2023 and its deadlines lapsed in May 2025; the October warning adds an explicit reference to possible next steps. Laos has been listed since February 2025.

Across the region, neither Thailand nor Cambodia appears on either list. For lenders and investors working across the Mekong, the practical difference is that the FATF calls for enhanced due diligence on Myanmar links, while Vietnam and Laos links call for a risk-based assessment rather than blanket measures.

Counterpoints and uncertainties

The FATF's own October statements are the authoritative text, and their full wording on Myanmar and Vietnam may contain detail beyond the press reports. The FATF can still decide on countermeasures for Myanmar or further steps for Vietnam at a later plenary, and national authorities may add their own requirements when they circulate the October statements.