A Policy Paper from the IMF on 4th February says that it is increasingly recognised that effective AML/CFT frameworks, and financial integrity more broadly, are key to financial stability, and that efforts to this effect should be pursued.  An Annex to the Paper sets out the evolution of the Fund’s AML/CFT programme.  The Paper also explains the timeline of the assessment process, from pre-assessment to the final report.  It also provides a handy guide to the FATF Immediate Outcomes assessment criteria for effectiveness –

Effectiveness is measured against 11 Immediate Outcomes (IO). Each of these represents one of the key goals that an effective AML/CFT system should achieve. The following is a summary of the 11 outcomes that are assessed, as reflected in much more detail in the FATF assessment methodology.

IO.1 Risk, policy and co-ordination

Money laundering and terrorist financing risks are understood and, where appropriate, actions coordinated domestically to combat money laundering and the financing of terrorism and proliferation.

IO.2 International co-operation

International cooperation delivers appropriate information, financial intelligence, and evidence, and facilitates action against criminals and their assets.

IO.3 Supervision

Supervisors appropriately supervise, monitor and regulate financial institutions and DNFBPs for compliance with AML/CFT requirements commensurate with their risks.

IO.4 Preventive measures

Financial institutions and DNFBPs adequately apply AML/CFT preventive measures commensurate with their risks and report suspicious transactions.

IO.5 Transparency of legal persons and arrangements Legal persons and arrangements are prevented

from misuse for money laundering or terrorist financing, and information on their beneficial ownership is

available to competent authorities without impediments.

IO.6 Financial intelligence

Financial intelligence and all other relevant information are appropriately used by competent authorities for money laundering and terrorist financing investigations.

IO.7 Money laundering investigation and prosecution

Money laundering offences and activities are investigated, and offenders are prosecuted and subject to effective, proportionate and dissuasive sanctions.

IO.8 Confiscation

Proceeds and instrumentalities of crime are confiscated.

IO.9 Terrorist financing investigation and prosecution

Terrorist financing offences and activities are investigated and persons who finance terrorism are prosecuted and subject to effective, proportionate and dissuasive sanctions.

IO.10 Terrorist financing targeted financial sanctions and non-profit organisations

Terrorists, terrorist organizations and terrorist financiers are prevented from raising, moving and using funds, and from abusing the NPO sector.

IO.11 Proliferation financing targeted financial sanctions

Persons and entities involved in the proliferation of WMD are prevented from raising, moving and using funds, consistent with the relevant UNSCRs.


Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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