The FATF Recommendations and the AML/CFT Methodology are the international standards and assessment tool with which all countries around the world are assessed about having and effectively implementing a national institutional and supervisory framework to combat money laundering and the financing of terrorism.
Based on the results of the country Mutual Evaluation Reports that are published on the FATF/FSRB websites and the Principal’s knowledge of the challenges that continue to beset all stakeholders and Assessment Bodies involved in the Mutual Evaluation processes globally, there is a strong and urgent need for access to online technical assistance and training in this area on a continuous basis.
The requirements of the FATF Recommendations and the assessment tool the AML/CFT Methodology are extremely onerous. The results of the country Mutual Evaluation Reports on the state of national AML/CFT compliance are published on the FATF/FSRB websites every five years with Follow up Reports at varying intervals thereafter.
It is accepted globally that the requirements of the FATF Recommendations and Methodology are extremely onerous for countries in both human and financial terms. Additionally, the lingering impacts of the global financial and economic crisis continue to bedevil the ability of countries to allocate adequate resources to undertake the necessary legislative and institutional strengthening and capacity building reform programmes that will ensure high levels of compliance.
Areas of Practice
STRATEGY AND PUBLIC AFFAIRS
The provision of Strategic Advice so that a jurisdiction:
Develops and provides strategic advice as well as undertaking the attendant national, regional and international crisis management, public diplomacy and outreach, in response to global initiatives and opinions on national and regional compliance
Inspires, engages and empowers governments, businesses, professionals and the public at large to effectively address problems of the day like the black listings of countries who are deemed to have weak AML/CFT regimes that pose threats to the global financial system or the current impasse on de-risking and loss of correspondent banking relationships
Undertakes global advocacy with the international compliance and investment communities and the regional and international media on behalf of countries
The provision of Strategic Advice so that a jurisdiction;
Engages with the regional and international media houses when countries are identified on negative lists of standard setters
Contributes to the resolution of the ongoing De-Risking and Loss of Correspondent Banking relations crisis that continues to beset small and developing countries globally.
ANALYTICS & ADVISORY
Bespoke strategic advice and guidance on demand or on an ongoing basis as follows to:
Heads of States and Governments, Cabinet Ministers, Ambassadors and High Commissioners on the ability of their respective jurisdictions to satisfy the FATF Recommendations on a national and sector by sector basis
Governments and private sector globally on overall national and sectoral AML/CFT compliance
On hot topics of the day to governments and private sector on issues such as beneficial ownership and transparency and improving the criminal justice systems as well as engaging with the initiatives by the Global Forum and the European Union on transparency, exchange of information, tax avoidance and tax evasion
Evaluate technical assistance and training needs of all national stakeholders and assist with coordination and delivery of same by identifying and accessing donor programmes and facilities
Provide up to date reports on a rolling basis, to all national stakeholders on developing money laundering trends and patterns, and how they are and could impact national, sectoral and international AML/CFT policy
FOURTH ROUND MUTUAL EVALUATION SUPPORT
The provision of Strategic Advice so that a jurisdiction:
Takes full cognizance of and addresses with the national interests in mind initiatives by the G7, G20, FATF, Global Forum and the European Union on transparency, exchange of information, tax avoidance and tax evasion and crypto currency, de-risking and loss of correspondent banking relationship, beneficial ownership and transparency and improving the criminal justice systems
Establishes its reputation as a leading country in the region and globally with high levels of compliance with the FATF Recommendations and has the capacity to provide South/South Technical Assistance and Training to other countries in the region
Undertakes a Self -Assessment process against the FATF Forty Recommendations 2012 and any recent amendments thereto, the AML/CFT Methodology 2013, Interpretive Notes and the growing body of jurisprudence on the interpretation of the standards
Prepares for and undertakes a National Risk Assessment (NRA) and develops and implements the National Action Plan from the NRA exercise including an AML/CFT training programme at all levels
Assesses and implements an effective national data collection mechanism for AML/CFT related statistics that will provide the empirical data to underpin the effective implementation of the FATF Recommendations
Adopts an integrated, whole of government approach towards the Mutual Evaluation process so that the next Mutual Evaluation Report (MER) produced on the jurisdiction is an accurate reflection of its AML/CFT architecture, complies with the FATF Forty Recommendations at the time of the onsite visit and is being effectively implemented
Develops and disseminates a High-Level Political commitment to attaining the highest levels of AML/CFT or other standard setter compliance requirements globally
Avoids being placed in the CFATF Enhanced Follow up and the FATF International Cooperation Review Group (ICRG) processes, referenced in the FATF ICRG Compliance Document and subjected to countermeasures by the AML/CFT Network
Assesses and develops an Action Plan to ameliorate and sustain where relevant the jurisdiction's compliance reputation globally, vis-a-vis standard setters, regulators, financial institutions, investment houses, correspondent banks, law enforcement and financial intelligence communities
Undertakes global advocacy with the international compliance and investment communities and media and contributes to the resolution of the ongoing De-Risking and Loss of Correspondent Banking relations crisis that continues to beset most regions in the world including Africa
Positions itself favourably to pursue membership in the FATF as relevant
TECHNICAL ASSISTANCE & TRAINING
Public education and awareness raising initiatives through the delivery of technical assistance and training on the international AML/CFT standards are vital and towards the protection of the safety and soundness of governmental institutions and business operations within a fast paced and ever changing global regulatory environment.
However globally, there is a shortage of human and financial resources to undertake the Fourth Round of Mutual Evaluations, which makes it imperative that delivery of much needed technical assistance and training to all stakeholders is undertaken efficiently, using new and creative mechanisms to ensure that the information is available on a rolling basis and updated as evolving circumstances dictate.
CWA fills the existing gaps through the provision of technical assistance and training on reputational risks to the integrity of their jurisdictions/enterprises, considering changing regulatory standards, regulatory expectations and enforcement actions to the following;
Heads of State, Heads of Governments, Parliaments, Cabinets, Ministers of Governments and Senior Government Officials, Ambassadors and High Commissioners, Heads of Regional and International Institution, Boards of Directors, Chief Executive Officers of private sector organizations, Senior Management and Compliance Officers of Banks, Insurance Companies, Securities Firms, Corporations, Lawyers, Independent Legal Professionals, Notaries, other, and any person providing Trust and Company Services), Accountants, Dealers in High Valued Goods such as Precious Metals/Stones, Money or Value Transfer Services, Casinos, Real Estate Agencies
CWA will also provide technical assistance with the establishment of Financial Intelligence Units and the training of Financial Investigators and Analysts to operationalize them to private sector financial institutions globally.
CWA also offers general or sector specific Compliance Conferences as an avenue to enhancing the national and regional Culture of Compliance through the continuous education and training of compliance officers and front-line staff at all public/private sector and charitable organizations is in much demand, given that national legislation globally mandates that all reporting entities be trained annually, and Self-Regulatory Bodies also require professionals under their purview to undergo annual Continuous Professional Development.