National assessments of money laundering risks: Stumbling at the start

Abstract

The Financial Action Task Force (FATF) requires national governments to demonstrate an understanding of the distribution of money laundering risks across different sectors of the financial system. Such understanding is the foundation for effective control of money laundering under the risk-based approach called for by the FATF. We analyzed the National Risk Assessments (NRAs) of eight systemically important countries before 2020 to test whether these demonstrated that basic understanding. The eight show very different conceptualizations, analytic approaches, and products. None showed more than minimal competence at risk assessment. For example, most relied largely on expert opinion, solicited, however, in ways that violated the well-developed methodology for eliciting expert opinion. They consistently misinterpreted Suspicious Activity Reports, the most fine-grained quantitative data available on money laundering, and failed to provide risk assessments relevant for policymakers. Only one described the methodology employed. Although conducting strong money laundering risk assessments is challenging, given the difficulty of estimating the extent of laundering in any sector, existing practices can be improved. We offer some potential explanations for the failure of governments to take this task seriously. The lack of involvement of risk assessment professionals is an important contributing factor to the weaknesses of the current NRAs.