Effectiveness Expert Working Group | FATF Subgroup Working Paper: How to improves the Effectiveness of the Mutual Evaluation Process

The Global Coalition provided the results of work done by financial crime experts to FATF making 20 recommendations on how to improve the effectiveness of the FATF Mutual Evaluation (ME) process.

The FATF sub group was led by Daniel Thelesklaf, a former Moneyval Chair and former Co-chair FATF Risk Trends & Methods Group, under the broader effectiveness work underway with experts led by Sir Rob Wainwright. This sub-working group asked itself five important questions and have provided commentary culminating in specific recommendations.

The questions explored key issues, such as whether the ME took ML/TF threat and materiality into account when they assess effectiveness. Whether materiality and threat be weighted more importantly for the grey and blacklists, whether  contextual factors (such as corruption in the public sector) is taken into account sufficiently. Whether the ME (and ICRG) processes sufficiently transparent, whether the ME process would be more effective if it included information from NGOs, academia and other “independent“ sources, what might be missing in the data collection exercise and whether FATF should set out more specific expectations around the development / use of public-private partnerships including whether FATF should do more to challenge barriers to information sharing (private to private, cross-border etc).

The FATF Subgroup was established under the Effectiveness Expert Working Group initiated by the Global Coalition to Fight Financial Crime. The FATF Sub Group is one of 14 groups looking into questions and suggesting recommendations to improve effectiveness. The FATF Working Group was established alongside 3 other Expert Working Groups, focussed on Law Enforcement/FIUs, Regulators and the Financial Institutions. These Expert Working Groups are expected to finalise their work later this year.