ML/TF Risk Assessment Process

In establishing a ML/TF risk assessment process, some countries may choose to establish a more formal inter-agency working group or the like to oversee their risk assessment process.

Round-table discussions, working groups of experts and taskforces of relevant agencies and bodies are other examples of how such a process may be organised. It is useful if the process is as inclusive and co-operative as possible. However, ideally there should be a clear determination and designation of the specific agency, organisation or “task force” in charge of leading and coordinating the process. See Annex III which contains examples of national-level assessments for specific ways that countries have organised their assessments.

24. As mentioned in the previous

A clear project plan describing the process, roles and responsibilities of various partners for identifying, assessing and understanding the country’s ML/TF risks may therefore be useful. In addition, an appraisal of likely resource requirements needed to undertake the ML/TF risk assessment may be beneficial. 25. There are a variety of processes through which a country may reach an informed understanding of the risks it faces – in a particular situation or overall. This includes top-down approaches (resulting from a single, co-ordinated framework or system) and bottom-up (building a national assessment from a patchwork of assessments with a smaller scope). It also includes organic processes which may develop an understanding of risk incrementally, for example by starting with a limited or specific focus assessment and gradually expanding it whilst learning from the experience of the preceding work.

3.2 Sources of information

Contributors to the risk assessments

26. While some aspects of the ML/TF risk assessment may be conducted through a single agency process, in most cases, it is unlikely that one organisation by itself possesses all

Contributors that may provide essential input to the national-level ML/TF risk assessment process include the following

(see also Figure 1):

National Money Laundering and Terrorist Financing Risk Assessment

FATF Guidance

14  2013

 Policy-making bodies: Policy making bodies should, where relevant, be included in the conduct of a risk assessment – not necessarily as providers of information, but as the principal users of risk assessments – in order to ensure that risk assessments adequately address high-level questions and that any implications of the risk assessment for the revision of national

AML/CFT policies are identified. They have a particular role to play in helping frame the scope of the risk assessment exercise.

 Law enforcement and prosecutorial authorities (including police, customs/border control, and criminal intelligence agencies where appropriate): These operational authorities may be able to provide information on specific cases involving the particular area under assessment and may also assist, where possible, in estimating amounts of proceeds of crime based on information on predicate offence. They thus are likely to play a central role as a source of information for the process.