Global Coalition to Fight Financial Crime’s Post

FATF Consultation on RBA: - 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. The submitted paper is also available on the GCFFC website - see comments for link. 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: Alison Clew (USA), Angela Harbour (UK), Andrew Chow (Singapore), Denisse Rudich (UK), Dr Sorcha MacLeod (Denmark), Greta Barkauskienė (Lithuania), Jean-Michel Rousseau (Switzerland), John Cusack (UK), Julia Chin 陈碧茹 (Singapore), Karen Nitschke (Australia), Kateryna Boguslavska (Switzerland), Matthew Long (Luxembourg), Michael Levi (UK), Michal Gromek (Poland), Nicolas Choules-Burbidge (Canada), Phale M. (UK), Ursula M'Crystal (Singapore), Xolisile Khanyile (South Africa). , , , Che Sidanius

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