Capacity Building

The Main Components

• Diagnostic Exercises

  To develop a suitable project framework for our clients, we perform diagnoses to identify areas with the greatest deficiencies.

  • Measuring the country’s technical and effectiveness compliance against the FATF Standards
  • One-week on-site mission involving meetings with all AML/CFT/CFP stakeholders
  • Identifying issues sufficiently in advance of a mutual evaluation
  • Drafting a detailed diagnostic report with key findings and recommendations

• Legal Drafting

  To enhance technical compliance, we analyze existing laws and regulations and provide comprehensive services to meet current AML/CFT standards. This includes patiently drafting or developing new legislations to address identified deficiencies.

  • Analyzing existing primary and secondary legislation related to AML/CFT/CFP, full scope or in relation to specific aspects of the FATF Recommendations
  • Identifying shortcomings in relation to the criteria under each Recommendation in the FATF Methodology
  • Drafting legislative instruments or amendments to existing legislation to address shortcomings

• National Strategies and Action Plans

  We tailor an AML/CFT/CFP strategy and action plan that outlines, step-by-step, how the strategy will be implemented within a specific timeframe.

  • Developing comprehensive and structured strategies commensurate with national AML/CFT/CFP risks
  • Devising associated granular national action plans with implementation timeframes
  • Monitoring implementation of action plans
  • Where necessary, devising agency-level action plans

• National, Topical and Sectorial Risk Assessments

  These are the cornerstone of any sound risk-based AML/CFT/CFP framework and according to the FATF, must be conducted on a regular basis. Therefore, we support countries and authorities. Every step of the way.

  • Development of tailor-made risk assessment methodologies and tools
  • Detailed questionnaires for data and information gathering
  • Research into publicly available sources
  • Interviews with all relevant public and private stakeholders
  • Analysis of data and information
  • Drafting the risk assessment report

• Enhancing Risk-Based AML/CFT Supervisory Frameworks

  Financial and non-financial supervisors need a wide range of specialized tools to build their capacity for risk-based AML/CFT supervision.
  These must enable risk assessments of each firm and ensure that appropriate supervisory actions are taken.

  Limited supervisory resources can be allocated in a more efficient manner for each financial or non-financial sector, depending on the risk landscape.
  We strategically guide supervisory authorities in all aspects of their work.

  • STRIX AML is a risk assessment software for supervisors (SupTech) that was developed in line with FATF requirements
  • Development of risk-based on-site inspection procedures
  • Formulating risk-based supervisory strategies and on-site inspection plans
  • Regulatory guidance documents to assist financial institutions and designated non-financial businesses and professions
  • Strengthening fit-and-proper licensing procedures
  • Enhancing enforcement processes in the area of AML/CFT
  • Developing best practices or typologies papers
  • Supporting authorities during on-site inspections

• Strengthening Law Enforcement Processes

  While investigations in classic crime are usually based on tangible evidence, investigations in financial crime are mostly conducted using documents and transaction records. This is often a major challenge for law enforcement agencies. We are highly specialized in financial crime investigations and provide insider knowledge in asset tracing. Additionally, we provide insightful capacity building for investigators, prosecutors, and judges involved in money laundering or terrorist financing investigations.

  • Skill-based training for law enforcement and prosecutors aimed at enhancing their ability to obtain and analyze financial evidence
  • Development of operational manuals and procedures
  • Development of interagency cooperation procedures
  • Assistance with statistics collection mechanisms for law enforcement and prosecution services

• Enhancing Financial Intelligence Units (FIUs)

  FIUs play a key role in any national system to combat money laundering and terrorist financing. They have access to a wide range of information and can support law enforcement efforts. At the same time, they guide financial and non-financial institutions on how to effectively apply preventive measures.

  As an FIU with strong strategic analysis capabilities has the potential to make all aspects of a national AML/CFT framework more effective, we provide focused services in this area.

  • Skill-based training for operational and strategic analyses
  • Development of internal work procedures and operational analysis manuals
  • Development of red flag indicators and guidance documents to enhance the effectiveness of suspicious transaction reporting
  • Development of private sector feedback mechanisms
  • Advice on structural and human resources matters

• Developing Targeted Financial Sanctions (TFS) Frameworks

  Many countries need assistance to improve and strengthen the performance and cooperation on TFS between AML/CFT/CFP authorities.

  We have extensive experience in developing legal frameworks in this area and can contribute efficient support in the practical implementation.

  • Development of legislative frameworks compliant with international standards
  • Development of mechanisms for designations, freezing, unfreezing, listing, and de-listing
  • Development of procedures for operational cooperation among relevant stakeholders
  • Development of relevant typology papers, information homepages, and guidance documents
  • Training and assistance to countries in reviewing various databases (e.g. business, shipping and real estate registers, licensing databases)
  • Organizing awareness-raising campaigns for the private sector

• Enhancing Transparency of Legal Persons, Legal Arrangements and NPOs

  This is not only a priority to the G-7 but also enshrined as an FATF requirement. The design and creation of beneficial ownership registries is at the heart of many countries' efforts. It ensures that relevant beneficial ownership information is obtained, documented, and kept up to date for all registered legal entities.
  We systematically support with the following:

  • Designing and creation of beneficial ownership registers
  • Organizing internal capacities of national authorities for company registries
  • Development of strategies for registries to engage more effectively with the corporate sector

• Private Sector Awareness Raising Campaigns on all AML/CFT Matters

  The most basic AML/CFT obligations are not always clear and there is not always practical guidance on how to implement these. FIs and DNFBPs in many countries openly express the need for more education.

  To support national stakeholders and governments, we diligently design and implement information campaigns on all issues involving AML/CFT. Our training program comprises a range of separate modular modules, which build on each other but can also be individually combined to target each sector’s specific multifaceted needs.

• Training of Public Officials

  We deliver highly customized and practical training events on investigative, supervisory, and regulatory aspects of AML/CFT. Modern and interactive teaching techniques and practical case studies ensure real impact. Each training is tailored to our client’s individual requirements and needs – we do not simply “recycle” training material.