Financial Crime World

Assessing Countries’ Anti-Money Laundering and Counter-Terrorist Financing Systems

The Financial Action Task Force (FATF) Recommendations provide a framework for countries to prevent and combat money laundering and terrorist financing. Assessing the effectiveness of these systems is crucial in ensuring global financial stability. This article outlines a methodology for evaluating countries’ Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) systems against the FATF Recommendations.

Assessment Components

The assessment focuses on two main components:

Technical Compliance

Evaluates whether the country has implemented the specific requirements of the FATF Recommendations, including laws, regulations, and institutional frameworks.

Key aspects of technical compliance include:

  • Implementing specific requirements of the FATF Recommendations
  • Evaluating the framework of laws and enforceable means
  • Assessing the existence, powers, and procedures of competent authorities

Effectiveness

Assesses the effectiveness of the AML/CFT system in practice, including measures such as sanctions, international cooperation, and the ability to prevent and investigate crimes.

The effectiveness component includes evaluating measures such as:

  • Sanctions applied to ensure future compliance and deter non-compliance by others
  • International cooperation, including cross-border investigations and supervision of international groups
  • Draft legislation and proposals that may affect AML/CFT systems

Assessment Criteria

Assessors will reach a conclusion about the extent to which a country complies (or not) with each Recommendation, using four possible levels of compliance:

  • Compliant: The country has implemented the relevant FATF Recommendations.
  • Largely Compliant: The country has substantially achieved the requirements, but some issues remain.
  • Partially Compliant: The country has partially achieved the requirements.
  • Non-Compliant: The country does not meet the requirements.

In exceptional circumstances, a Recommendation may also be rated as “not applicable”.

Methodology Emphasis

The assessment methodology emphasizes that assessors should only consider laws, regulations, or other AML/CFT measures that are in force by the end of the on-site visit. It also highlights the importance of considering FATF Guidance as background information, but not incorporating it into the assessment.