FATF lists and your Zerodha account
The FATF lists are the two registers of high-risk countries maintained by the Financial Action Task Force, the inter-governmental body that sets the global standards for anti-money-laundering and counter-terrorist-financing, and they decide whether a non-resident or foreign national can open or hold a Zerodha account: a resident of a country on the FATF black list cannot open an account, and a resident of a country on the FATF grey list can open one only after Zerodha’s compliance team approves it. India is a FATF member and gives the lists legal force through the Prevention of Money Laundering Act, 2002 , the PML Rules 2005, and the SEBI Master Circular on AML/CFT obligations dated 6 June 2024.
The two lists are not interchangeable. The black list, formally the High-Risk Jurisdictions Subject to a Call for Action, names countries with such serious deficiencies that the FATF calls on its members to apply countermeasures and enhanced due diligence. The grey list, formally Jurisdictions under Increased Monitoring, names countries that have committed to fix identified weaknesses and are being watched while they do; for these the FATF asks for a risk-based approach, not a blanket cut-off. Zerodha operationalises that distinction directly: black list means no account, grey list means an account subject to compliance approval.
This article explains what the FATF is, the difference between the black and grey lists, who sits on each as of the June 2026 plenary, how India turns the lists into law through PMLA and the SEBI circular, and exactly how the lists affect opening and running a Zerodha NRI or foreign-national account.
Conflict-of-interest disclosure. This guide is published by the WebNotes Editorial Team for informational purposes and is written independently. WebNotes operates a Zerodha account-opening referral programme, disclosed on the pages that carry the referral link; this guide does not carry it and earns no referral commission from the procedure described here.
What the FATF is
The Financial Action Task Force is an inter-governmental body founded in 1989 by the G7 to combat money laundering, with its mandate later extended to terrorist financing and the financing of weapons proliferation. It issues the FATF Recommendations, the 40 standards that national anti-money-laundering regimes are measured against, and it assesses how well each country implements them through mutual evaluations. India has been a full FATF member since 2010, and the September 2024 Mutual Evaluation Report placed India in the “regular follow-up” category, the best of the four outcome tiers.
The FATF does not regulate individual investors or brokers. It sets standards and publishes country assessments, and member states implement those standards through their own law. In India that implementation runs through the PMLA, the PML Rules, and the sector regulators, which for the securities market is SEBI.
The two lists
After each plenary the FATF publishes two public statements that together form the lists brokers act on.
The black list, the High-Risk Jurisdictions Subject to a Call for Action, identifies countries with significant strategic deficiencies that pose a risk to the international financial system. For these jurisdictions the FATF calls on members to apply enhanced due diligence and, in the most serious cases, countermeasures. As of the FATF statement following the June 2026 plenary, the black list holds three countries: Iran, North Korea (DPRK) and Myanmar. It has not changed since Myanmar was added in October 2022.
The grey list, the Jurisdictions under Increased Monitoring, identifies countries that have strategic deficiencies but have given a high-level political commitment to address them and are working with the FATF on an action plan. The FATF does not call for enhanced due diligence to be applied to grey-list jurisdictions across the board; it asks members to take the increased monitoring into account in a risk-based approach and warns against wholesale de-risking. As of the FATF statement of 19 June 2026, the grey list stood at 22 jurisdictions.
| List | Formal FATF name | What FATF asks members to do | Effect at Zerodha |
|---|---|---|---|
| Black list | High-Risk Jurisdictions Subject to a Call for Action | Apply enhanced due diligence and, where stated, countermeasures | Resident cannot open an account |
| Grey list | Jurisdictions under Increased Monitoring | Take into account in a risk-based approach; no blanket de-risking | Resident can open an account only after compliance-team approval |
The lists are reviewed three times a year. The FATF plenary meets in February, June and October, and at each meeting jurisdictions are added to or removed from the grey list. The June 2026 plenary kept the black list unchanged at Iran, North Korea and Myanmar and adjusted the grey list, which is why any list cited here must be checked against the live FATF page before you rely on it.
How India turns FATF into law
The FATF standards reach an Indian broker through three layers. The PMLA, 2002 is the parent statute making the broker a reporting entity with client due-diligence and reporting duties. The Prevention of Money-Laundering (Maintenance of Records) Rules, 2005 set the operational rules, including the duty to grade clients by money-laundering risk. The SEBI Master Circular on AML/CFT obligations of securities market intermediaries, dated 6 June 2024, is the instruction set SEBI gives brokers; it supersedes the earlier Master Circular SEBI/HO/MIRSD/MIRSD-SEC-5/P/CIR/2023/022 dated 3 February 2023 and its FATF-related amendment SEBI/HO/MIRSD/SEC-FATF/P/CIR/2023/0170 dated 13 October 2023.
The SEBI circular tells intermediaries to use the FATF public statements, circulated by SEBI from time to time and available publicly, to identify countries that do not or insufficiently apply the FATF Recommendations. Clients connected to those countries, alongside PEPs and NGOs, fall into the Clients of Special Category bucket that attracts enhanced due diligence. So the FATF country list is one input into the broader client-risk grading every Indian broker is required to run.
How the FATF lists affect a Zerodha account
Zerodha applies the FATF country lists directly in its NRI and foreign-national account-opening policy. The rule has two tiers that map onto the two FATF lists.
For an NRI or foreign national resident in a black-list country, Zerodha will not open an account. Its account-opening guidance states that an NRI living in a blacklisted country cannot open a Zerodha account, and the same bar applies to foreign nationals resident in those countries. The restriction also reaches a resident-to-NRI conversion: if an existing resident client moves to a black-list country and becomes an NRI there, the account cannot continue on that basis.
For an NRI or foreign national resident in a grey-list country, Zerodha can open an account, but only after its compliance team approves it. The compliance review is the enhanced-due-diligence step: confirming identity, establishing the source of funds, and weighing the country risk before the account goes live. This is consistent with the FATF’s own position that grey-list residence calls for a risk-based assessment rather than an automatic refusal.
Two further points follow from the list being a moving target. First, because every NRI is already a Client of Special Category , income proof is mandatory for an NRI account regardless of country, and the FATF country filter sits on top of that. Second, because the grey list changes up to three times a year, an applicant’s eligibility can shift between application and approval, or between one re-KYC cycle and the next, depending on the FATF status of their country of residence at the time.
What to do if your country is listed
If you are an NRI or foreign national and your country of residence appears on the FATF black list, a Zerodha account is not available while that listing stands; the bar is a regulatory one, not a Zerodha preference, and contacting support will not produce an exception. If your country is on the grey list, you can still apply, but build in time for the compliance-team review and keep your income proof and address documents ready, because the enhanced-due-diligence check is where the application is decided. In either case, verify the current status on the FATF’s official page rather than a secondary summary, because the lists are revised at every plenary and a country’s status as of June 2026 may not hold at your next re-KYC .
See also
- Zerodha
- Clients of Special Category (CSC)
- Prevention of Money Laundering Act
- Politically Exposed Person
- KYC Registration Agency
- Central KYC Records Registry
- Zerodha KRA
- How to re-KYC your Zerodha account
- How to check your KYC status at Zerodha
- How to open a Zerodha NRI account
- How to update PAN resident status for an NRI
- How to respond to a KYC-update email from Zerodha
- How to respond to an additional-documents email from Zerodha
- How to reactivate a dormant Zerodha account
- How to verify PAN and Aadhaar at Zerodha
- SEBI
- Reserve Bank of India
- Foreign Exchange Management Act
- Zerodha Console
- Kite by Zerodha
- In-person verification
- Is Zerodha safe?
- Zerodha cyber security
- CKYC number explained
External references
- FATF: black and grey lists
- FATF: Jurisdictions under Increased Monitoring, 19 June 2026
- FATF: High-Risk Jurisdictions Subject to a Call for Action
- SEBI: Master Circular on AML/CFT obligations of securities market intermediaries under PMLA
- Financial Intelligence Unit-India
References
- Financial Action Task Force, Jurisdictions under Increased Monitoring, statement dated 19 June 2026, and High-Risk Jurisdictions Subject to a Call for Action (black list: Iran, North Korea and Myanmar, unchanged since October 2022).
- SEBI Master Circular, Guidelines on Anti-Money Laundering (AML) Standards and Combating the Financing of Terrorism (CFT) / Obligations of Securities Market Intermediaries under the Prevention of Money Laundering Act, 2002, dated 6 June 2024 (superseding the 3 February 2023 circular and its 13 October 2023 FATF amendment).
- Prevention of Money Laundering Act, 2002, and the Prevention of Money-Laundering (Maintenance of Records) Rules, 2005.
- FATF, India Mutual Evaluation Report, September 2024 (India placed in regular follow-up).
WebNotes Editorial Team prepares factual reference articles based on publicly available regulatory documents and broker disclosures. WebNotes is not affiliated with Zerodha Broking Limited. FATF lists are revised at every plenary; verify the current black and grey lists at fatf-gafi.org and current account rules at support.zerodha.com before acting.