From 20 to 24 October 2025, the Financial Action Task Force (FATF) will gather in Paris for its latest plenary and working group meetings that will set the direction of global anti-money-laundering policy.
For the legal sector, these sessions matter more than many realise. The way FATF defines and interprets risk filters down into national rules, professional guidance and ultimately the daily work of lawyers, compliance officers and regulators.
Recent FATF publications and updates suggest several areas of potential relevance to the legal sector that may arise at the Plenary.
- A new toolkit for assessing money-laundering risk – In August, FATF released its Money Laundering National Risk Assessment (NRA) Toolkit, an updated guide to how jurisdictions should analyse threats and vulnerabilities. The document moves beyond financial-sector templates and acknowledges the complex roles played by legal persons and arrangements, the informal economy, virtual assets and corruption risks. For law firms that handle company formation, property transactions or high-value asset transfers, this matters. The toolkit offers a framework for understanding how these activities are viewed through the risk-assessment lens that regulators and mutual evaluators use. It is a signal that FATF wants consistency and evidence when professionals describe how they manage exposure.
- Re-examining the treatment of non-profits – In July, FATF launched a formal process to identify and correct unintended consequences of its own standards, starting with their impact on non-profit organisations (NPOs). This new procedure grew out of years of concern that compliance over-reach had made it harder for legitimate NPOs to operate. The implications extend beyond the charity sector. Lawyers who advise or represent NPOs, and regulators overseeing their work, will need to understand how this recalibration of proportionality may influence wider Designated Non-Financial Businesses and Professions (DNFBP) expectations.
- Simplified due diligence and financial inclusion – A quieter but equally meaningful change came earlier in the year. In February 2025, FATF refreshed its Financial Inclusion Guidance, clarifying when simplified due diligence (SDD) can legitimately apply in lower-risk situations. For compliance officers in law firms, this update supports a more pragmatic approach – rigorous checks where risk is high, but fewer barriers where it is not. It could directly influence how DNFBPs, including legal professionals, design and document their client-onboarding processes and transaction-monitoring frameworks. The challenge will be ensuring that every simplified step is backed by reasoning and records that demonstrate professional judgment, not complacency.
- Jurisdictional Monitoring Updates – FATF’s ongoing jurisdictional monitoring for progress on AML/CFT deficiencies continues to shape enhanced due-diligence obligations across borders. Earlier this year for example, the organisation added Laos and Nepal to its ‘grey list’ and removed the Philippines, confirming that progress or back-sliding is never static. Further changes are likely once the October Plenary concludes.
For firms, especially DNFBPs such as law practices advising international clients, these updates are more than diplomatic signals; they are direct compliance triggers. Intake systems and client-screening tools should be refreshed as soon as the new statements are published to ensure risk ratings remain current.
What to expect from Paris
Behind the headlines, FATF delegates are expected to keep refining how countries, and the professions within them, are assessed.
Key priorities include updates to the recommendations affecting DNFBPs such as lawyers and accountants, adjustments to the mutual-evaluation process and continued focus on beneficial-ownership transparency.
Taken together, these strands reflect a single aim – to ensure that professional gatekeepers, including the legal sector are judged on a demonstrable understanding of risk.
Why this matters for the profession
For firms, the practical steps are familiar but increasingly urgent:
- Risk assessments should reflect the categories and examples used in the new NRA toolkit.
- Onboarding policies need to show where simplified due diligence is defensible and where enhanced checks remain essential.
- Matter-intake systems should be able to flag jurisdictions under increased monitoring automatically.
- Every compliance decision should be recorded with enough clarity to stand up to audit or regulatory scrutiny.
Regulators and professional bodies will need to keep pace with evolving FATF expectations, as the next round of mutual evaluations will again examine how self-regulatory models and professional privilege operate within national AML frameworks.
A turning point worth attention
The October Plenary will not rewrite the rulebook overnight, but it will set the tone for the next few years of AML evolution – one that prizes evidence, proportionality and collaboration across sectors.
For the legal profession, the opportunity is to stay ahead and to shape compliance that is credible, not surface-level and to show, once again, that good lawyers are essential to financial integrity.
We’ll be publishing a short post-Plenary analysis later this month explaining what the outcomes mean for Compliance Officers for Legal Practice (COLPs), regulators and law-firm leaders.
We continuously monitor how FATF’s decisions are implemented across jurisdictions. If you would like to explore what these changes mean for your organisation get in touch mail@hooktangaza.com