Learning from Money Laundering National Risk Assessments: The Case of Italy and Switzerland

Abstract

The FATF requires each country to undertake a national risk assessment (NRA) to show the government’s knowledge of money laundering risks. There is little guidance as to how these NRAs are to be conducted, and those that have been published show great variation in terms of data used, analytical methods, and the depth of policy analysis. After expounding some of the concepts basic to any risk analysis, we analyze two of the more detailed published NRAs, from Italy and Switzerland. The Italian NRA, focused on domestic criminal threats, relies almost exclusively on expert opinion. Its most distinctive product is an analysis of the high-threat sectors and the need for specific kinds of policy interventions. The Swiss NRA, focused primarily on threats from other countries, presents far more quantitative data, almost exclusively from suspicious activity reports, to supplement expert opinion. Though both NRAs provide useful insights about money laundering risks, neither is conceptually clear; in particular, neither reflects contemporary practice in the use of expert opinion. Our critique is aimed at helping strengthen the next round of NRAs, and identifies lessons learned for all countries. Our recommendations include the use of risk assessment standards from other fields, the addition of a measure of uncertainty, and a more critical assessment by FATF in its NRA evaluations.