Learning from Eight Advanced Countries' National Assessments of Money Laundering Risks: [NRAs]
01/08/2022
The Financial Action Task Force (FATF) requires national governments to demonstrate an understanding of the money laundering risks in the country.
Such an understanding is the foundation for effectively controlling money laundering under the FATF's risk-based approach.
The authors analysed the National Risk Assessments (NRAs) published by eight systemically important countries to test whether they demonstrate that basic understanding and to draw lessons for national governments from those NRAs.
The study looks at eight advanced countries— Canada, Italy, Japan, the Netherlands, Singapore, Switzerland, the United Kingdom (UK), and the United States (US).
The eight-show country tests very different conceptualizations, analytic approaches, and products, and each raised serious issues regarding the risk assessment methodology.
For example, most relied mainly on expert opinion, which they solicited in ways inconsistent with the well-developed methodology for using expert opinion.
They misinterpreted data from suspicious activity reports and failed to provide risk assessments relevant to policymakers. Only one described the methodology employed.
The report concludes with suggestions for (international) policymakers and those conducting NRAs for improving risk assessments.
Suggestions include increased clarity about the conceptualization of risk, transparency about data and methods so that each country can learn from others, and adopting more formal and standardized methods of eliciting expert opinion.
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As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.