RISK-BASED SUPERVISION
MARCH 2021
,The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes
policies to protect the global financial system against money laundering, terrorist financing and the financing of
proliferation of weapons of mass destruction. The FATF Recommendations are recognised as the global anti-money
laundering (AML) and counter-terrorist financing (CFT) standard.
For more information about the FATF, please visit www.fatf-gafi.org
This document and/or any map included herein are without prejudice to the status of or sovereignty over any
territory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area.
As
Citing reference:
FATF (2021), Guidance on Risk-Based Supervision, FATF, Paris,
www.fatf-gafi.org/publications/documents/Guidance-RBA-Supervision.html
© 2021 FATF/OECD. All rights reserved.
No reproduction or translation of this publication may be made without prior written permission.
Applications for such permission, for all or part of this publication, should be made to
the FATF Secretariat, 2 rue André Pascal 75775 Paris Cedex 16, France
(fax: +33 1 44 30 61 37 or e-mail: )
Photocredits coverphoto ©Getty Images
, Acknowledgements
Supervisors oversee the measures put in place by the private sector to implement anti-money laundering
checks and report suspicions. Effective, risk-based supervision is an essential part of a strong anti-money
laundering system. This document guides supervisors on how to assess risks in the sectors they oversee
and adapt their resources accordingly and includes strategies to address common challenges. The
guidance is based on the work of the following project team members and the extensive input by the
FATF Global Network of FATF Members and FATF-Style Regional Bodies (FSRBs), together making up
more than 200 jurisdictions. The guidance also benefited from informal consultation with a range of
private sector representative bodies and financial inclusion stakeholders.
The work for this guidance was led by Jun Yuan Tay (Monetary Authority of Singapore), Philippe Bertho,
(L'Autorité de contrôle prudentiel et de resolution of France), Hamish Armstrong (Jersey Financial
Services Commission), with Shana Krishnan, Jay Song and Ben Aldersey from the FATF Secretariat. The
project team received significant contributions from Joo Seng Quek (Monetary Authority of Singapore),
Julien Escolan and Fadma Bouharchich (ACPR France), Damian Brennan (Central Bank of Ireland),
Ke Chen and Grace Jackson (International Monetary Fund), Kuntay Celik (World Bank), Carolin Gardner,
(European Banking Authority), Claire Wilson (UK Gambling Commission), Melanie Knight and Lee Adams
(UK Office for Professional Body AML Supervision (OPBAS)), Lesya Yevchenko (The Office of the
Superintendent of Financial Institutions (OFSI) Canada), Marlene Manuel-Fevrier, (Department of
Finance Canada), Mike Hertzberg (US Treasury with the input of various US supervisors), Juliana Petribu
and Izabela Correa (Central Bank of Brazil), Tomohito Tatsumi and Arisa Matsuzawa (Financial Services
Agency Japan) and Alexandr Kuryanov (Rosfinmonitoring Russia).
, 2 GUIDANCE ON RISK-BASED SUPERVISION
Table of contents
Acronyms 4
Executive Summary 5
PART ONE: HIGH-LEVEL GUIDANCE ON RISK-BASED SUPERVISION 7
1. Introduction 7
1.1. Objectives and scope 7
1.2. Overview of relevant FATF recommendations and assessment methodology 8
1.3. Common supervisory frameworks 10
1.4. Characteristics of an effective risk-based supervisory framework 11
1.5. Overview of the risk-based supervision process 12
2. Supervisors’ risk understanding 14
2.1. What is the scope and purpose of supervisory risk assessments? 14
2.2. What does the supervisory risk assessment process involve? 17
2.3. What information does a supervisor need to identify and understand the risks? 22
2.4. How do supervisors keep their risk understanding updated? 24
3. Risk-based approach to supervision 25
3.1. What is a supervisory strategy? 25
3.2. How can supervisory strategies address the risks identified? 26
3.3. How can supervisors adjust their approach to vary the nature, frequency, intensity and focus
of supervision? 27
3.4. How can supervisors use a combination of off-site and on-site tools to strengthen their risk-
based approach? 29
3.5. How should supervisors treat lower risk sectors and entities? 31
3.6. How can supervisors develop a more robust risk-based approach over time? 33
3.7. How should remedial actions and available sanctions be applied in risk-based supervision? 35
3.8. How should supervisors measure the effectiveness of their risk-based approach? 36
3.9. Domestic co-operation, including between AML/CFT supervision and prudential supervision 39
3.10. International co-operation to achieve a risk-based approach to supervision 39
4. Cross-cutting issues 42
4.1. Use of technology by supervisors (“SupTech”) 42
4.2. Engagement with the private-sector 43
4.3. Use of third-parties 44
Annex A. Overview of supervisory tools 46
PART TWO: STRATEGIES TO ADDRESS COMMON CHALLENGES IN
RISK-BASED SUPERVISION & JURISDICTIONAL EXAMPLES 48
Objectives and scope 48
Overview of challenges identified in Mutual Evaluations 48
5. Strategies to address challenges in assessing ML/TF risks 49
5.1. Disconnect from, or misalignments with, the NRA 49
5.2. New areas of supervisory responsibility – identifying the regulatory population 50
5.3. New areas of supervisory responsibility – identifying and understanding the risks 51
5.4. Difficulties in assessing risks at the entity-level 51
5.5. Building risk understanding over time 53
5.6. Engagement with other authorities to supplement the risk assessment 54
5.7. Data collection issues 55
5.8. Special considerations for DNFBP supervisors 56
5.9. Other guidance 57
6. Applying risk-based supervision 58
© FATF/OECD 2021
MARCH 2021
,The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes
policies to protect the global financial system against money laundering, terrorist financing and the financing of
proliferation of weapons of mass destruction. The FATF Recommendations are recognised as the global anti-money
laundering (AML) and counter-terrorist financing (CFT) standard.
For more information about the FATF, please visit www.fatf-gafi.org
This document and/or any map included herein are without prejudice to the status of or sovereignty over any
territory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area.
As
Citing reference:
FATF (2021), Guidance on Risk-Based Supervision, FATF, Paris,
www.fatf-gafi.org/publications/documents/Guidance-RBA-Supervision.html
© 2021 FATF/OECD. All rights reserved.
No reproduction or translation of this publication may be made without prior written permission.
Applications for such permission, for all or part of this publication, should be made to
the FATF Secretariat, 2 rue André Pascal 75775 Paris Cedex 16, France
(fax: +33 1 44 30 61 37 or e-mail: )
Photocredits coverphoto ©Getty Images
, Acknowledgements
Supervisors oversee the measures put in place by the private sector to implement anti-money laundering
checks and report suspicions. Effective, risk-based supervision is an essential part of a strong anti-money
laundering system. This document guides supervisors on how to assess risks in the sectors they oversee
and adapt their resources accordingly and includes strategies to address common challenges. The
guidance is based on the work of the following project team members and the extensive input by the
FATF Global Network of FATF Members and FATF-Style Regional Bodies (FSRBs), together making up
more than 200 jurisdictions. The guidance also benefited from informal consultation with a range of
private sector representative bodies and financial inclusion stakeholders.
The work for this guidance was led by Jun Yuan Tay (Monetary Authority of Singapore), Philippe Bertho,
(L'Autorité de contrôle prudentiel et de resolution of France), Hamish Armstrong (Jersey Financial
Services Commission), with Shana Krishnan, Jay Song and Ben Aldersey from the FATF Secretariat. The
project team received significant contributions from Joo Seng Quek (Monetary Authority of Singapore),
Julien Escolan and Fadma Bouharchich (ACPR France), Damian Brennan (Central Bank of Ireland),
Ke Chen and Grace Jackson (International Monetary Fund), Kuntay Celik (World Bank), Carolin Gardner,
(European Banking Authority), Claire Wilson (UK Gambling Commission), Melanie Knight and Lee Adams
(UK Office for Professional Body AML Supervision (OPBAS)), Lesya Yevchenko (The Office of the
Superintendent of Financial Institutions (OFSI) Canada), Marlene Manuel-Fevrier, (Department of
Finance Canada), Mike Hertzberg (US Treasury with the input of various US supervisors), Juliana Petribu
and Izabela Correa (Central Bank of Brazil), Tomohito Tatsumi and Arisa Matsuzawa (Financial Services
Agency Japan) and Alexandr Kuryanov (Rosfinmonitoring Russia).
, 2 GUIDANCE ON RISK-BASED SUPERVISION
Table of contents
Acronyms 4
Executive Summary 5
PART ONE: HIGH-LEVEL GUIDANCE ON RISK-BASED SUPERVISION 7
1. Introduction 7
1.1. Objectives and scope 7
1.2. Overview of relevant FATF recommendations and assessment methodology 8
1.3. Common supervisory frameworks 10
1.4. Characteristics of an effective risk-based supervisory framework 11
1.5. Overview of the risk-based supervision process 12
2. Supervisors’ risk understanding 14
2.1. What is the scope and purpose of supervisory risk assessments? 14
2.2. What does the supervisory risk assessment process involve? 17
2.3. What information does a supervisor need to identify and understand the risks? 22
2.4. How do supervisors keep their risk understanding updated? 24
3. Risk-based approach to supervision 25
3.1. What is a supervisory strategy? 25
3.2. How can supervisory strategies address the risks identified? 26
3.3. How can supervisors adjust their approach to vary the nature, frequency, intensity and focus
of supervision? 27
3.4. How can supervisors use a combination of off-site and on-site tools to strengthen their risk-
based approach? 29
3.5. How should supervisors treat lower risk sectors and entities? 31
3.6. How can supervisors develop a more robust risk-based approach over time? 33
3.7. How should remedial actions and available sanctions be applied in risk-based supervision? 35
3.8. How should supervisors measure the effectiveness of their risk-based approach? 36
3.9. Domestic co-operation, including between AML/CFT supervision and prudential supervision 39
3.10. International co-operation to achieve a risk-based approach to supervision 39
4. Cross-cutting issues 42
4.1. Use of technology by supervisors (“SupTech”) 42
4.2. Engagement with the private-sector 43
4.3. Use of third-parties 44
Annex A. Overview of supervisory tools 46
PART TWO: STRATEGIES TO ADDRESS COMMON CHALLENGES IN
RISK-BASED SUPERVISION & JURISDICTIONAL EXAMPLES 48
Objectives and scope 48
Overview of challenges identified in Mutual Evaluations 48
5. Strategies to address challenges in assessing ML/TF risks 49
5.1. Disconnect from, or misalignments with, the NRA 49
5.2. New areas of supervisory responsibility – identifying the regulatory population 50
5.3. New areas of supervisory responsibility – identifying and understanding the risks 51
5.4. Difficulties in assessing risks at the entity-level 51
5.5. Building risk understanding over time 53
5.6. Engagement with other authorities to supplement the risk assessment 54
5.7. Data collection issues 55
5.8. Special considerations for DNFBP supervisors 56
5.9. Other guidance 57
6. Applying risk-based supervision 58
© FATF/OECD 2021
