On 1 March, FATF is developing guidance to help both public and private sectors in implementing the new requirements to identify, assess, understand and mitigate proliferation financing risk as defined in FATF Recommendation 1 and its Interpretive Note. The Guidance seeks to assist both sectors in conducting a risk assessment in the context of proliferation financing, and applying corresponding risk mitigation measures.  It says that it primarily seeks views from financial institutions and designated non-financial businesses and professions (DNFBP), but would also welcome contributions from other interested stakeholders.  It invites views on the content of the Guidance, in particular certain areas listed in the news release.  The consultation closes on 9 April.

The areas that FATF input are –

  1. Does the Guidance provide sufficient clarity in distinguishing the mandatory requirements of the updated FATF Standards on proliferation financing risk assessment and mitigation, and additional measures that may support the implementation of these new requirements?
  2. Do you consider the four categories of risk indicators (including a sectoral focus on the maritime sector and trade finance) relevant, useful, and sufficient for your understanding of the risk of potential breach, non-implementation of evasion of proliferation financing targeted financial sanctions in the context of FATF Recommendation 7? What other indicators could be included in this section?
  3. Does the risk mitigation section of the Guidance provide sufficient clarity on how financial institutions and DNFBP can address the risk of potential breach, non-implementation and evasion of targeted financial sanctions? What specific risk mitigation measures do you take to address such risks?
  4. Does the Guidance set clear expectations for financial institutions and DNFBP in case of high-risk and low-risk customers and business relationships, including likely impact on de-risking and financial inclusion?


I would be grateful for any modest contribution for my time and ongoing costs of computer, relocation, and (still ongoing) removal costs, I have a page, where contributions start as low as $3, at https://www.buymeacoffee.com/KoIvM842y

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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