On 27 September, the Basel Institute of Governance posed this question following publication of the latest Basel AML Index.  This, it says, reveals that lawyers, accountants, real estate agents, casinos, precious metal dealers,​​​​​​ and other so-called designated non-financial businesses and professions (DNFBP) are significantly less protected against money laundering and terrorism financing risks than financial institutions. They also do less to contribute to AML/CFT efforts. They should be considered a serious vulnerability in most jurisdictions’ AML/CFT framework. It says that it believes more supervision is urgently needed to close that gap.  It then reproduces a relevant extract from the Index.  Reviewing 2021 data on jurisdictions’ performance in respect of the relevant FATF Recommendation 28, which sets standards for the regulation and supervision of DNFBP, reveals that far too little has changed:

  • compliance with R.28 remains very lowat 45% on average;
  • 15 jurisdictions still score a radical 0%for compliance with R.28; and
  • only 8 jurisdictions are fully compliantwith R.28.

Any modest contributions for my time and ongoing expenses are welcomed!  I have a page where you can do so, and where one-off contributions start as low as $3, at

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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