Page 9 - 20200513 Newsletter - 07042020 Final

Volume 3, Edition 1 Chatterbox 07/04/2020

Part Two: Regulatory Response
In Focus: FATF

Wolfsberg Group

...continued

The FATF agreed to maintain
the rating of Compliant for
Recommendation 2 (National
cooperation and coordination),
Recommendation 5 (Terrorist
financing offence) and
The Wolfsberg Group of 13 of the defined priority areas Recommendation 21 (Tipping-
largest private banks (does not off and confidentiality). The
include banks from China and Russia), 3. Establish a reasonable and risk- FATF also maintained the
continues to espouse good practice based set of controls to mitigate the rating of Largely Compliant
and in a one-page missive provided a risks of an FI being used to facilitate for Recommendation 7
high level statement on effectiveness. illicit activity by: (Targeted financial sanctions
related to proliferation),
In short, the Group does not believe 2. identifying current practices that Recommendation 8 (Non-profit
there is adequate consideration of are not required by law or regulation. organisations), Recommendation
the effectiveness of the outcomes of 3. do not lead to the production of 15 (New technologies) and
an institution’s AML/CTF plan – with highly useful information to relevant Recommendation 18 (Internal
an undue focus instead being placed government agencies and controls and foreign branches
upon technical compliance rather 4. are of little financial crime risk and subsidiaries).
than looking at what is actually being management value to the FI.
achieved. The United States is now
The Group believe that a firm should compliant on 9 of the 40
It is the opinion of the Group that discontinue these practices and Recommendations and largely
firms should adopt, at a micro level, employ resources more efficiently. compliant on 22 of them. It
the FATF ‘outcomes-based’ focus remains partially compliant on 5
with there being three key elements Food for thought! of the 40 Recommendations and
required: not compliant on 4 of them.
https://www.wolfsberg-principles.
1. Comply with AML/CTF laws and com/sites/default/files/wb/pdfs/ The United States remains
regulations Effectiveness%201%20pager%20 in enhanced follow-up and
Wolfsberg%20Group%202019%20 will report back to the FATF
2. Provide highly useful information FINAL_Publication.pdf on progress to strengthen its
to relevant government agencies in implementation of Anti-Money
Laundering / Countering the
Financing of Terrorism measures.

http://www.fatf-gafi.org/
publications/mutualevaluations/
documents/fur-united-
states-2020.html

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