Identifying and managing low money laundering risk : perspectives on FATF\u27s risk-based guidance

Abstract

Purpose &ndash; The purpose of this paper is to investigate Financial Action Task Force (FATF)\u27s risk-based guidance to combat money laundering and terrorist financing to determine its approach to the identification and management of low-risk providers, products and transactions. Design/methodology/approach &ndash; The paper analyses the relevant FATF recommendations and its guidance notes and reflects on key questions for regulators and financial institutions. Findings &ndash; FATF has not defined &ldquo;risk&rdquo; for purposes of the risk-based approach. The absence of a clear definition complicates the identification of low-risk products. FATF do provide an example of a risk matrix that can be used to identify low-risk banks, but the example is based on assumptions and generalisations that are not sustainable. In addition, it identifies certain low-value transactions as &ldquo;low risk&rdquo; transactions. The paper reflects on the role of value as an indicator of risk and concludes with a number of suggestions to clarify the conceptual framework. Originality/value &ndash; Low-risk products and transactions are often overlooked because the risk-based approach focuses attention on high-risk matters. Low-risk products are however crucial to the efforts to increase financial inclusion. The paper identifies gaps in the current conceptual framework and indicates ways in which they can be addressed.<br /