FATF/​FSRB PRO­CESS

Written Submissions

Comprehensive, well-drafted and consistent submissions prior to the on-site visit are key to a successful outcome of the evaluation process.

• Therefore, we systematically support by:

  1. Discussing the expected format, content, and structure of the submissions
  2. Identifying relevant materials for inclusion in the submissions
  3. Preparing a first draft of the submissions
  4. Collecting and collating statistics
  5. Drafting case studies

Coaching for Interviews

The on-site visit is the best opportunity for the assessed country to demonstrate that its AML/CFT/CFP framework functions effectively and therefore officials should be prepared accordingly.

• As trusted partners, we assist with:

  1. Conducting mock interviews with public officials and private sector entities
  2. Providing feedback on how to best present processes and procedures during the on-site visit
  3. Ensuring that all public officials are familiar with the content of the written submissions
  4. Detailing any preparatory steps that may still be required before the on-site visit

Commenting on the Draft Report

After the on-site visit and before the plenary discussions of the final report, the assessed country will receive up to three versions of the draft report to comment on.

• We diligently support by:

  1. Checking the draft report for consistency and factual accuracy
  2. Proposing text to eliminate, or minimize, criticism as much as possible
  3. Inserting comments in the draft report to justify changes or to present counter-arguments
  4. Proposing realistic and doable changes to recommended actions for each Immediate Outcome and support a more positive rating
  5. Conducting a comparative analysis of FATF/FSRB reports on key horizontal issues raised in the draft report
  6. Presenting the results of the comparative analysis in separate documents
  7. Recommending which additional information is required to be produced to address issues and concerns by the assessment team
  8. Reviewing the draft report with the purpose of ensuring that the correct interpretation of the FATF Methodology is applied
  9. Holding meetings with the authorities to clarify changes and comments raised by FTA
  10. Assisting the assessed country to address the issues raised by the external reviewers

Strategic Advice in dealing with the FATF/FSRBs

For the finale phase, when meeting with the assessors and the plenary discussions take place, dedicated preparation is essential.

• Customized services by us include:

  1. Preparing a defense strategy for the face-to-face meeting with the assessment team to discuss the draft report
  2. Providing strategic advice on the selection and order of key issues for discussion at the Working Group on Evaluations
  3. Drafting the country’s response to the key issues and speaking notes for meetings of the Working Group

ICRG-Related Process

In this stage it is often difficult for countries to avoid public listing referral to the ICRG on the basis of the results of a mutual evaluation. Equally, for listed countries it is challenging to convince the global network that progress has been made to address an ICRG action plan.

• For countries in the observation period, we are committed to:

  1. Designing targeted deliverables to demonstrate positive and tangible progress on all recommended actions relating to all Immediate Outcomes rated ‘Moderate’ or ‘Low’
  2. Discussing the expected format, content, and structure of the Post-Observation Period Report (POPR)
  3. Identifying relevant materials for inclusion in the POPR
  4. Preparing a first draft of the POPR
  5. Collecting and collating statistics
  6. Drafting case studies
  7. Conducting mock interviews with public officials from AML/CFT/CFP stakeholders in preparation for the presentation of the POPR to the Joint Review Group

  For listed countries, we competently guide by:

  1. Designing targeted deliverables to address the ICRG action plan
  2. Preparing the progress reports to be submitted to the ICRG ahead of every FATF Plenary