GCFFC response to FATF consultation on proposed revisions to R.1/INR.1/INR.10/INR.15

The GCFFC have submitted a response to the FATF consultation on proposed revisions to R.1/INR.1/INR.10/INR.15 which in particular focusses on the Risk Based Approach. 

As the paper states – “Whilst we support the changes proposed, we believe that these changes alone are unlikely to have a material effect. In particular we believe that significant improvements to the FATF Standards governing country National Risk Assessments are a necessary precondition to improving the risk based approach”.

We double down on this precondition and explain how the current risk based approach is not working effectively and has consequences for financial inclusion.

We make specific proposals and drafting editing suggestions which we feel would prove invaluable and should be taken into account in the 5th round of country evaluations.

Thanks to the many expert contributions to this submission including from: Greta Barkauskiene (Lithuania), Kateryna Boguslavska (Switzerland), Nick Choules Burbidge (Canada) Julia Chin (Singapore), Andrew Chow (Singapore), Alison Clew (USA), John Cusack (UK), Michal Gromek (Poland), Angela Harbour (UK), Xolisilie Khanyile (South Africa), Mike Levi (UK), Matt Long (Luxembourg) Ursula M’Crystal (Singapore), Phale McMillan (UK), Dr Sorcha MacLeod (Denmark), Karen Nitschke (Australia), Jean Michel Rousseau (Switzerland) & Denisse Rudiche (UK), Julia Chin (Singapore) and Andrew Chow (Singapore)