On 27 October, FATF published a report which represented the first phase of its work was a stocktake, to consolidate previous analysis of these phenomena by FATF and other stakeholders, including expert bodies, in order to identify and understand to what extent, and in what manner, these unintended consequences are occurring.  Next, FATF will identify and consider potential options to mitigate these unintended consequences. The results of the first phase of this project will also inform FATF’s work on the strategic review, which aims to make FATF more timely, targeted and effective at holding countries to account.

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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