Decrypting AML Risk Assessments and the FATF’s High-Risk Jurisdictions

What are AML Risk Assessments and Why are They Important?

Anti-Money Laundering (AML) Risk Assessments are systematic evaluations conducted by financial institutions to identify, assess and mitigate the risks of money laundering and terrorist financing.

These assessments help institutions recognise and understand the specific risks they face and then develop strategies to manage and reduce these risks. In undertaking these assessments, institutions ensure compliance with regulatory requirements, protect their reputation and contribute to the integrity of the financial system.

What is the FATF and what is its role in AML Regulations?

The Financial Action Task Force (FATF) is an international organisation established in 1989 to develop policies to combat money laundering and terrorist financing. The FATF sets international standards and promotes effective implementation of legal, regulatory, and operational measures for combating these threats.

The FATF conducts reviews of member countries to assess their compliance with its recommendations and maintains lists of jurisdictions with strategic deficiencies in their AML/CTF (Counter Terrorist Financing) regimes.

What criteria are used to determine High-Risk Jurisdictions?

High-risk jurisdictions are determined based on several criteria, including:

  • The extent of deficiencies in a country’s AML/CTF framework;
  • The level of cooperation with international AML/CTF efforts;
  • The prevalence of financial crimes such as money laundering and terrorist financing;
  • The effectiveness of law enforcement and regulatory bodies in combating financial crimes; and
  • The transparency of the financial system and availability of reliable financial data.

What is the Difference Between the FATF Black List and Grey List?

The FATF Black List, refers to high-risk jurisdictions with significant strategic deficiencies in their regimes to counter money laundering, terrorist financing, and financing of proliferation. The Grey List, or the list of jurisdictions under increased monitoring, includes countries that have strategic deficiencies but are actively working with the FATF to address them. Being on the Black List typically carries more severe consequences than being on the Grey List.

The FATF publishes updates to its Black and Grey Lists three times a year. These updates typically occur in February, June and October. Prior to these updates, the FATF reviews the progress made by jurisdictions in addressing deficiencies in their AML/CFT frameworks and makes decisions about any changes to the lists.

How should financial institutions respond to clients from High-Risk Jurisdictions?

Financial institutions should implement enhanced due diligence and stricter compliance measures when dealing with clients from high-risk jurisdictions. This includes but is not limited to:

  • Conducting more rigorous background checks and ongoing monitoring of transactions;
  • Carrying out regular reviews of the client and update if the client’s risk profile changes;
  • Understanding the purpose and intended nature of the business relationship;
  • Obtaining additional information on the source of funds and wealth;
  • Ensure that employees are trained to recognise and respond to the risks associated with high-risk jurisdictions;
  • Reporting any suspicious activities to the relevant authorities; and
  • Evaluate the specific risks associated with the high-risk jurisdiction and assign a higher risk profile to that client.

What are the consequences for firms onboarding clients from or operating in countries listed on the FATF Black or Grey List?

Engaging in business relationships with clients from or operating in high risk jurisdictions can have significant consequences, including:

  • Increased scrutiny from international financial institutions and investors, leading to increased audits, reduced foreign investment and financial inflows;
  • Non-compliance with AML/CTF regulations can result in penalties and sanctions;
  • Increased resources and training required by the compliance and risk management teams to carry out enhanced monitoring and compliance checks; and
  • Negative impact on the firm’s reputation, due to associations with high risk jurisdictions and individuals, which can affect economic stability and growth.

How Complyport can help

Effective Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) controls are essential to safeguarding your organisation from financial crime risks. Complyport’s AML Healthcheck service provides a thorough assessment of your current AML and CTF Frameworks, ensuring they meet the latest regulatory standards and best practices. The services we offer include:

  • Comprehensive AML and CTF Framework Assessments: Evaluate your current AML and CTF governance and controls against legal standards and industry best practices
  • AML Audits: Conduct a thorough review of your AML policies, risk assessments, procedures and compliance practices to assess the effectiveness of your company’s measures to prevent and detect money laundering activities
  • Training: Design a comprehensive training and assessment programme to ensure your teams understand financial crime risks and controls
  • Regulatory Alignment: Help you prepare for supervisory visits, ensuring your framework meets the latest regulatory requirements
  • Ongoing Support: Provide continuous assistance to implement and enhance your AML and CTF

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