Q: Why is there so much time between mutual evaluations?
A: The mutual evaluation process is very thorough and intensive. In a single round of evaluations, the FATF assesses over 40 jurisdictions (other jurisdictions in the global network are assessed by the FATF-style Regional Bodies, the IMF and the World Bank). Each assessment takes 14 months for the team to complete. The FATF Plenary discusses and adopts two mutual evaluation reports at each of its three annual Plenary meetings. This means that each assessment cycle takes 7 to 8 years to complete.
Q: The FATF mutual evaluation cycles are very spaced out. In between these cycles, does FATF look at its members’ measures to tackle money laundering and terrorist financing?
A: Yes. The completion of an assessment and the publication of the mutual evaluation report (MER) is a starting point for the country to continue strengthening its measures to tackle money laundering and terrorist financing. The country subsequently reports back to the FATF on a regular basis on the progress it has made. After three years, the general expectation is for countries to have addressed most if not all of the technical compliance deficiencies identified in their MER. After five years, the FATF conducts a follow-up assessment which looks at the priority actions from the mutual evaluation report and the reforms the country has introduced to improve the effectiveness of its actions to protect the integrity of the financial system and their compliance with the FATF Recommendations.
Q: Who decides when an assessment will take place?
A: The FATF determines the dates of an assessment in consultation with the assessed country and in the case of a joint assessment, with the other assessing body/bodies. The assessment is a demanding process that requires considerable resources from both assessing bodies and the assessed country. FATF’s resources allow it to finalize 6 assessments each year.
Q: Where can I find out when an assessment takes place?
A: The FATF publishes the calendar of assessments at this link.
These dates are tentative. This calendar is regularly updated.
Q: I have information that I think might be useful for the assessment team, can I share this with you?
A: Occasionally, the FATF Secretariat receives unsolicited information from persons wishing to share information with the assessment team. Under our Procedures, any information that is taken into account in the course of an evaluation must be shared with both the assessment team and the assessed country, and the source of the information must also be identified. As assessors have huge volumes of material to review, information which is presented in a succinct manner and in a format that mirrors the Methodology is more helpful. There is no mechanism under our Procedures to provide feedback about how or if information received has been taken into account.
Q: Can I find out who is on the assessment team and speak to them or interview them?
A: Members of the assessment team are subject to strict confidentiality agreements and are, therefore, not able to discuss the evaluation with outside parties or disclose any information obtained by reason of their participation either during or after the assessment. This ensures the impartiality of the assessment. After the assessment is concluded, the final published mutual evaluation report will identify the members of the assessment team.
Q: Who does the assessment team talk to when they go on an on-site visit and who decides who they need to speak with?
A: During the on-site visit, the assessment team speaks to a range of:
The assessors, in consultation with the assessed country and Secretariat, decide who they need to speak with during the evaluation.
Q: Who takes part in an assessment and how are they selected?
A: The mutual evaluation process is a peer review process and, as such, the assessment team is generally comprised of five to six experts with a range of experience from the governments of the FATF Membership and supported by the FATF Secretariat. Where the FATF is conducting an assessment jointly with an FSRB, the assessment team will also include at least one expert from the FSRB Membership and will also be supported by the FSRB Secretariat.
Because the FATF Recommendations cover a wide range of issues, each assessment team must include experts with a range of experience covering legal, law enforcement and Financial Intelligence Unit (FIU) issues, financial supervision and regulation, and international cooperation.
To ensure a consistently high quality of its mutual evaluations, the FATF organizes assessor training for these experts. This training teaches assessors how to critically analyse a country’s technical compliance with the FATF Recommendations and how to assess whether the country’s AML/CFT measures are effective.
Only experts who have successfully completed this training can take part in an assessment.
Q: The FATF recently organized an on-site visit to country [X] what were the conclusions from this visit?
A: The FATF is not in a position to comment on the country’s implementation of AML/CFT measures while a mutual evaluation is ongoing. The conclusions from the on-site visit will be included in the mutual evaluation report which must first be discussed and adopted by the FATF Plenary. Mutual evaluation reports are published on the FATF public website about ten months after the on-site visit. For more information about the stages in the assessment process see http://www.marymuses.com/publications/mutualevaluations/documents/more-about-mutual-evaluations.html
Q: Country X recently adopted a law on [x] can you tell me if this has improved their compliance with the FATF Recommendations?
A: The FATF cannot comment on the effectiveness of a country’s framework to combat money laundering or terrorist financing on the basis of one law or regulation. A country’s protection against these risks is a complex framework of legal, regulatory and operational measures. The FATF can only comment on a country’s efforts to tackle money laundering and terrorist financing in the context of a mutual evaluation or related follow-up process in which it analyses the relevant legal and institutional framework, and discusses how effectively the country is preventing, detecting and punishing money laundering and terrorist financing.
Q: Can you tell me how well Country X is tackling money laundering and terrorist financing?
A: The latest mutual evaluation reports and subsequently published follow-up reports provide a snapshot of a country’s efforts to tackle these risks. The country reports back regularly to the FATF on the actions it is taking to address the weaknesses identified in its mutual evaluation report. Not all of these follow-up reports are published. The FATF’s 4th round procedures set out which reports will be made public: http://www.marymuses.com/media/fatf/documents/methodology/FATF-4th-Round-Procedures.pdf
Q: Why is there no mention of very recent media coverage about relevant ML/TF developments in a mutual evaluation report you just published?
A: A mutual evaluation is a snapshot of the measures in place in a country during the assessment team’s on-site visit. Measures which come into force and effect after the on-site visit are not taken into account. The reason is because the assessment team is no longer in the country and able to fully discuss with the authorities and the private sector how measures are being implemented in practice. New measures which are put in place after the on-site will be taken into account subsequently during the mutual evaluation follow-up process.