PNG's grey-list exit: why “months, not years” needs operational evidence

Papua New Guinea can aim for an early exit from the Financial Action Task Force's grey list. The question is what evidence would justify that confidence.

The Prime Minister's office published a statement on 15 February 2026 in which James Marape said an exit could come “within months, not years”. The statement also allowed for a period of two years or sooner. It expressed optimism about speed; it did not promise removal by December 2026. That is the claim worth testing against FATF's process. PM's office statement.

On the public evidence reviewed, removal during 2026 appears unlikely. That is an assessment, not a prediction of FATF's decision. It could change if PNG demonstrates that it has substantially completed its action plan and FATF verifies that progress. Passing legislation, appointing a task force or announcing a major investigation cannot, by itself, establish that the full programme has been delivered.

The timeline starts in 2023, but grey listing starts in 2026

These dates describe different stages of the process:

Sources: Bank of PNG's evaluation chronology, 2024 mutual evaluation report, FASU 2024 annual report, February listing, June update.

The distinction is important in both directions. PNG has had years to respond to the assessment findings. Equally, improvements made before February 2026 can contribute to an exit; the country does not have to start its work from zero on listing day.

The outstanding work includes measurable operations

FATF's February statement describes seven broad areas of work. They cover understanding risk and coordinating strategy; pursuing international cooperation to trace proceeds overseas; supervising banks, money-transfer businesses, foreign exchange providers and higher-risk professional sectors; increasing money-laundering investigations and prosecutions; improving freezing, seizure and confiscation; strengthening proliferation-financing sanctions implementation; and addressing legal and reporting deficiencies. FATF also acknowledged reforms already made. FATF's PNG action-plan summary.

Those are not simply drafting tasks. An amended law can create a power. Demonstrating that agencies use it competently, consistently and in cases matching the country's risks requires records of actual work.

The Bank of PNG described 18 milestones in the national plan and identified legislation as an early deadline. Its Governor emphasised effectiveness in practice. FASU separately identifies the programme as the Grey List Action Plan 2026–2028. The seven public FATF workstreams and 18 domestic milestones are different ways of organising the programme; they should not be treated as competing counts of outstanding problems. Governor's March outlook, FASU's 2025 annual-report release.

The PM's later messaging recognises the same difficulty

There is a fair counterweight to the February optimism. On 10 March the Prime Minister called for agencies to enforce existing laws. On 11 March his office emphasised coordinated investigations and stronger systems. These statements recognise that legislation alone is insufficient. 10 March statement, 11 March statement.

The same theme appears in TVWAN's public LinkedIn report of its interview: the PM sought an early exit while identifying audits, investigations and prosecutions as necessary work. This is public social-media reporting of an interview, not a verified transcript of everything said. TVWAN interview report.

In August the PM welcomed ICAC's enforcement progress. Such developments deserve recognition, but a government account of progress is not equivalent to FATF's acceptance that the action plan has been completed. Arrest, prosecution and final asset confiscation are also distinct outcomes. 14 August statement.

What rapid exits actually required

Three relatively rapid modern exits provide useful comparisons. These are verified examples, not a claim to an exhaustive ranking of every country and historical listing episode. Durations measure the interval between public listing and removal announcements.

Sources: Malta's entry, Malta's completed actions, Malta's exit and on-site verification, Iceland's FATF history, Mongolia's FATF history, June 2020 action-plan progress, October 2020 removals.

Malta is a useful speed benchmark, but Mongolia is a particularly relevant operational comparison. It had to improve the investigation, prosecution and asset-related activity that also features in PNG's programme. Different starting conditions and action plans prevent a simple transfer of either country's timetable to PNG.

These examples demonstrate that a comparatively quick exit is possible. They do not establish a universal minimum of twelve months, or show that announcing reforms is enough.

What would make a 2026 exit credible?

FATF's published removal process requires a country to address all or nearly all components of its action plan. FATF then arranges an on-site assessment to verify implementation and the commitment and capacity to sustain it. A successful verification leads to a removal decision at a subsequent plenary. FATF's monitoring and removal procedure.

The public record reviewed for this article does not contain an announcement that PNG has reached that verification stage. June's deferred reporting limits what can be inferred from that particular update. It does not prove either failure or completion.

For confidence in an early exit to increase, the useful evidence would be:

• Progress against each agreed milestone, with clear distinctions between work started, completed and accepted by FATF.
• Investigations and prosecutions addressing significant money-laundering risks, supported by evidence of effective agency coordination.
• Asset restraint and recovery outcomes, distinguishing provisional freezing from final confiscation.
• Risk-based supervisory work and meaningful follow-up of failures.
• Evidence of effective international cooperation and sustainable institutional capability.
• Confirmation of FATF's assessment and on-site verification stage.

This is an analytical set of indicators, not a substitute for the confidential detail of PNG's agreed action plan. Public information may lag actual progress.

The strongest argument for caution is therefore procedural and practical: broad operational work remains to be demonstrated, and verification must follow. A rapid exit should be judged against that evidence. The ambition is understandable; the timetable needs proof.

Related reading on why operating evidence matters more than documentation: Read why compliance needs evidence of operation. If you would like to discuss enterprise onboarding and evidence practices in Papua New Guinea, our PNG enquiry form is the place to start.