FATF Updates on Recommendation 15 Implementation in Jurisdictions With Materially Important Virtual Asset Sectors

Today, the Financial Action Task Force (FATF)—the global standard setter for anti-money laundering (AML) and counter-terrorist financing (CFT) rules—released its sixth targeted update on the implementation of its virtual asset standards. The report assesses global progress in applying AML/CFT measures to virtual assets (VAs) and virtual asset service providers (VASPs), with a particular focus on jurisdictions that host materially significant VASP activity. 

While FATF notes progress since 2025—when it released its last such report—in regulatory development and enforcement actions, the report identifies persistent gaps in licensing, registration, VASP identification, and oversight of offshore platforms. It underscores that weak implementation in any one jurisdiction creates systemic vulnerabilities in a borderless crypto ecosystem.

The FATF’s findings also reflect heightened illicit finance risks, with virtual assets increasingly exploited by threat actors. The report highlights the growing criminal use of stablecoins by networks tied to North Korea, terrorist financiers, and drug traffickers, including the record-breaking USD 1.5 billion Bybit hack attributed to North Korea. FATF further points to a sharp rise in fraud and scams, with industry estimates attributing more than USD 50 billion in illicit on-chain activity to fraud schemes in 2024. Cases like the UK’s “Operation Destabilise” are cited as examples of why international cooperation and asset-freezing capabilities remain essential to disrupting professionalized illicit networks.

As part of this update, FATF also released a revised version of its jurisdictional implementation table—originally published in March 2024—with updated data from TRM Labs. The new table tracks the implementation status of FATF’s Recommendation 15 (R.15/INR.15) across 67 jurisdictions, now covering approximately 98% of global VASP activity. Nine new countries have been added to the list as their digital asset markets have become materially significant. To support global efforts around cross-border payment transparency, FATF will also release best practices for supervising the Travel Rule, now adopted or in process in 99 jurisdictions. These updates form part of FATF’s broader strategy to address emerging risks in the digital asset sector and to push for full global implementation of its standards.

Why is the table of materially important jurisdictions important?

FATF requirements on virtual assets have been in place for nearly six years, with countries now having their implementation of these rules assessed during their fifth round mutual evaluations which commenced this year. FATF's preliminary findings over this initial five-year period have shown suboptimal results. In June of 2024, FATF reported that 75% of assessed jurisdictions were only partially compliant or non-compliant with their rules. This presents a challenge as both FATF's report and TRM's analysis indicate a direct correlation between the implementation of regulatory frameworks and the levels of illicit finance to which a jurisdiction is exposed.

FATF’s updated table is intended to accelerate the development and enforcement of anti-money laundering and counter-terrorist financing frameworks for virtual assets, particularly among jurisdictions with high volumes of centralized services such as exchanges, custodians, and brokers. One key component of these frameworks is the implementation of the Travel Rule, which requires VASPs to collect, transmit, and retain originator and beneficiary information for certain digital asset transactions. This is designed to bring virtual asset transfers in line with the standards applied to wire transfers in the traditional financial system, enhancing transparency and enabling law enforcement to trace illicit flows.

Centralized platforms—often used as entry and exit points between fiat and crypto—remain key targets for abuse by illicit actors, making their regulation a top priority. FATF’s table provides jurisdictions with a structured view of where their implementation stands relative to others and highlights areas where further action is needed. It also supports FATF’s broader mandate to identify and monitor risks across all sectors it oversees. For virtual assets, this means ensuring that jurisdictions are not only conducting risk assessments but are also equipped to detect new threats as they emerge.

How was the table decided? 

The table highlights the work of a total of 67 jurisdictions, up from 58 in the last review— representing the jurisdictions responsible for 98% of the global crypto market. This includes all 38 FATF member states and 29 additional jurisdictions The methodology for inclusion in the table is as follows:

1. The jurisdiction is an official member of FATF 
2. The jurisdiction hosts VASPs with >0.25% of global virtual asset trading volume
3. The jurisdiction has a large virtual asset user base, and is a top 30 jurisdiction in terms of virtual asset ownership and adoption rates 

In its earlier version of the table, the FATF applied a threshold of one million or more active users to determine whether a jurisdiction met the third criterion for inclusion. However, the FATF has since revised this threshold, citing that publicly available data on user numbers—used in the previous assessment—is no longer freely accessible.

Importantly, the FATF emphasizes in its accompanying report that a jurisdiction’s inclusion in the table should not be interpreted as an indicator of its exposure to illicit finance. The methodology did not take this factor into account. As the FATF notes, “A jurisdiction’s inclusion in the table therefore carries no indication – either positive or negative – regarding that jurisdiction’s degree of risk or its level of compliance.”

What were the findings?

Among the 67 jurisdictions included:

• 97% had completed or begun a virtual asset risk assessment 
• 90% had either enacted, or were in the progress of enacting legislation to introduce licensing/registration requirements, as well as AML/CTF obligations
• 76% had actually licensed or registered VASPs
• 84% had conducted or begun supervisory inspections
• 75% had conducted or begun enforcement or supervisory action on VASPs 
• 85% had enacted, or were in the process of enacting, the Travel Rule 
• 9% had banned, or were in the process of banning, the use of virtual assets and VASPs 

How has the landscape changed?

‍‍The findings were based on jurisdictions’ responses to a 2025 self-reported survey conducted by FATF. Jurisdictions were also asked to provide basic evidence to support their responses. 

Where can I find the table and what does FATF's updated table mean for virtual assets? 

The full table can be found here. 

In its latest report, the Financial Action Task Force (FATF) stated that the updated implementation table is designed “to enable the FATF network to best support jurisdictions in regulating and supervising VASPs for AML/CFT purposes, and to encourage jurisdictions with materially important VASP activity to fully implement Recommendation 15 in a timely manner.” The table is also intended to help supervisors and the private sector assess implementation status across key markets.

With that in mind, how can different stakeholders in the virtual asset ecosystem use this table?

For the public sector

For policymakers and regulators, the FATF table serves as both a benchmarking tool and a practical roadmap. It allows jurisdictions to quickly see how they compare to peers and competitors when it comes to meeting the FATF Standards on virtual assets and service providers. Where gaps exist, the table can help crystallize areas for improvement—whether related to licensing, Travel Rule implementation, or supervisory enforcement—and serve as a catalyst for dedicating resources or accelerating legislation.

It may also encourage greater cross-border collaboration. By identifying common challenges—such as supervision of offshore VASPs or customer due diligence across decentralized platforms—the table provides a foundation for regulatory knowledge sharing and capacity building.

Just as importantly, the table can help regulators assess jurisdictional risk when evaluating incoming or outgoing flows. For example, if a country is handling a growing volume of cross-border crypto payments but has minimal implementation of Recommendation 15, counterparties may warrant additional scrutiny.

For the private sector

Virtual asset service providers (VASPs) and financial institutions can also use the FATF table to better understand the compliance posture of partner jurisdictions. For many firms, assessing the strength of a foreign jurisdiction’s AML/CFT regime is a challenge. A country that appears low-risk may, in fact, lack sufficient oversight; another may be quietly advancing enforcement capabilities. The FATF table provides clearer visibility into these dynamics.

When implementing the Travel Rule or conducting jurisdictional risk assessments, this information becomes essential. A VASP operating across multiple borders can use the table to identify which jurisdictions are likely to have implemented core requirements—and which are still catching up—thereby helping to calibrate onboarding controls, counterpart due diligence, and transaction monitoring protocols.

How TRM can help

If you’re a policymaker or regulator working to meet FATF’s standards on virtual assets, TRM can help. Our tools and guidance support governments in licensing VASPs, investigating unregistered operators, and building effective supervisory frameworks. Reach out to learn more or subscribe to our newsletter to be notified about our upcoming webinar series on blockchain intelligence for regulators.

If you’re a VASP navigating today’s regulatory environment, TRM provides the risk insights and tools needed to assess counterparties, comply with the Travel Rule, and meet global expectations. Get in touch to explore how we can help—and check out our blog for the latest in regulatory, compliance, and enforcement updates and analysis.