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The Evolution of OSFI Guideline B8:

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The Evolution of OSFI Guideline B8:

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    1. The Evolution of OSFI Guideline B8: Deterring and Detecting Money Laundering and Terrorist Financing May 6, 2009

    2. Agenda Triggers for change Challenges External Consultation Industry Comments Concentration of Comments Sectional Comments Misconceptions in Industry Comments Other Industry Comments Questions

    3. Triggers for Change Canadian legislative amendments FATF Mutual Evaluation Report Key Point: Minimum control standards and supervisory expectations are higherKey Point: Minimum control standards and supervisory expectations are higher

    4. Challenges Introduction of the FATF framework to B8 Compressed timeline for FATF response Key point: Higher standards Key point: Higher standards

    5. External Consultations FINTRAC: Meeting Industry: Meetings + letters Ad Hoc Group of Banks (credit cards) Trust Companies Association Canadian Life & Health Insurance Association Canadian Bankers Association

    6. External Consultation: Purpose Assurance in areas of Alignment in material respects with FINTRAC guidance Clarity and ease of understanding of AML/ATF requirements* Clarity and ease of understanding of B8* * Relatively weaker scores in the October 2008 Life Insurance Sector Consultation Report commissioned by OSFI

    7. External Consultation: High Value Clarified Unintended messages in the document as written Different interpretations of the same PCMLTFA and PCMLTFR requirements, between industry sectors and between industry and OSFI Alternative control practices through which compliance with certain PCMLTFA and PCMLTFR provisions is being managed Confirmed our thinking that industry consultation was imperativeConfirmed our thinking that industry consultation was imperative

    8. Industry Comments (Documented, quantitative)

    9. Concentrations of Industry Comment Areas of most concentration were: Introduction Risk-based approach Principal elements of the AML Program Specific higher risks Main issues were: Mandatory nature of the Guideline Where prescribed action ends and discretionary action begins Inherent risk assessment, client due diligence Mortgages, PEFPs, trade finance, EFTs

    10. Introduction section Mandatory Concern about making it mandatory to follow the Guideline OSFI clarified the mandatory nature of the AML compliance program, the under-pinning role of B-8, and the consequential need to ensure effective controls What is mandatory is that you Comply with the law; In doing so, you know who you are dealing with; and In knowing who you are dealing with, you know or you have a reasonable basis for thinking they are not laundering illegal fundsWhat is mandatory is that you Comply with the law; In doing so, you know who you are dealing with; and In knowing who you are dealing with, you know or you have a reasonable basis for thinking they are not laundering illegal funds

    11. Risk-Based Approach section DTIs Detailed guidance counters the risk-based approach endorsed by the legislation Life insurers and dictates best practices OSFI clarified that compliance with the PCMLTFA and PCMLTFR is essential and set out practices characterized as reasonable

    12. Principal Elements of AML/ATF Program section Significant comments were submitted on, Sr. Management Oversight CAMLO Assessment of Inherent Risks Client Due Diligence Specific Higher Risks

    13. Sr. Management Oversight section DTIs Management, not the CAMLO, should ensure that products & services are delivered in accordance with Compliance Program requirements OSFI clarified that the CAMLO should ensure that a compliant AML program is implemented and management should ensure the program is effective

    14. CAMLO section Life insurers Recognize that Compliance, not the CAMLO, is a key control function and that AML/ATF risk controls are a subset of legislative compliance management (LCM) risk that is managed within an LCM program OSFI clarified that the CAMLO should have responsibility for both LCM and broader ML/TF risk management components of the AML/ATF program

    15. CAMLO section (contd) OSFI recognizes that it is very broad: PCMLTFR s. 71(1)(a): A person to be responsible for the implementation of the program One person (clear accountability) Oversees others to the extent they are needed To implement across the FI and affiliates l Program for compliance with the AML/ATF legislative requirements, which require the design and implementation of ML/TF risk assessment and mitigation processes in the FIs activities ML/TF risks are potentially in Lines of business Employment relationships Supplier/service provider relationships Of parent and affiliates Worldwide

    16. Assessment of Inherent Risks section Life insurers and DTIs: A client relationship entered before the June 23, 2008 or 2002 laws came into force is not a type of inherent client risk, and Transactions are types of behaviour to be monitored. They are not a type of inherent risk OSFI clarified that pre-existing client relationships potentially increase client risk if FI has not identified and risk-assessed the client OSFI clarified that type of transaction is an inherent risk factor in some situations Email from Nick Burbidge: kinds of transactions contemplated by FATF Rec 11 i.e. complex, unusual large transactions that have no apparent visible lawful or economic purpose. Such a transaction could be inherently risky if undertaken by a low risk client in a low risk geography in a low risk business channel.Email from Nick Burbidge: kinds of transactions contemplated by FATF Rec 11 i.e. complex, unusual large transactions that have no apparent visible lawful or economic purpose. Such a transaction could be inherently risky if undertaken by a low risk client in a low risk geography in a low risk business channel.

    17. Client Due Diligence section DTIs - Burden of identifying all 2002 higher risk clients in accordance with the PCMLTFA and Regs now, far outweighs the control value OSFI scaled back B8: Ensure pre-2002 clients are identified per the PCMLTFA and Regs when they buy a product to which the identification requirements apply; and reasonable measures to ensure, could include ascertaining the identity of the client with respect to each product purchased. Also applies to pre-June 23, 2008 clients Credit card banks were most concerned Credit card banks thought the first consultation draft of B8 required them to rate all clients identified by NFTF measures as higher risk. This would have required many to rate almost all clients as higher risk, and therefore apply client identification measures per the Act and Regs to almost all pre-June 23, 2008 clients. So OSFI also removed the language that gave the impression that all clients identified by NFTF measures are inherently higher risk.Also applies to pre-June 23, 2008 clients Credit card banks were most concerned Credit card banks thought the first consultation draft of B8 required them to rate all clients identified by NFTF measures as higher risk. This would have required many to rate almost all clients as higher risk, and therefore apply client identification measures per the Act and Regs to almost all pre-June 23, 2008 clients. So OSFI also removed the language that gave the impression that all clients identified by NFTF measures are inherently higher risk.

    18. Client Due Diligence section (contd) DTIs and Life insurers The use of NFTF identification methods does not make a client higher risk than the use of FTF methods Life insurers Client identification by life insurance agents and brokers is not NFTF client identification, which may be applied where no agent is involved OSFI clarified that customers never met personally are inherently higher risk that those dealt with in person (FATF standard). Monitoring customers that FI cant meet is a challenge OSFI clarified that due diligence should be performed on life insurance agents and brokers who provide client information to the insurer Life insurers were concerned that the use of life insurance agents and brokers Life insurers were concerned that the use of life insurance agents and brokers

    19. Specific Higher Risks section Domestic PEPs: Life insurers Domestic PEPs do not indicate a higher risk OSFI clarified that FRFIs should assess the risk where it knows a client is a domestic PEP Mortgage Loans: DTIs Concerned re: limitations of the focus on drug grow-ops OSFI broadened the focus to fraud generally, a predicate offence for money laundering Life insurers Mortgage business of life insurers is not captured by the PCMLTFA so it should not have to be covered by their AML/ATF programs OSFI maintained that the significant risk warrants coverage in the program

    20. Specific Higher Risks section (contd) Trade Finance: DTIs Use of open account payments can limit ability of bank to monitor trade transactions OSFI clarified to emphasize the role of letters of credit EFTs: DTIs Unrealistic to expect FRFIs to stop processing incoming payments that conform to SWIFT requirements but contain incomplete/inaccurate message fields, as it will stop the Canadian payment system OSFI changed the pre-payment detection requirement to a post-payment requirement

    21. Misconceptions in Industry Comments ML is a narrow risk AML/ATF controls are simply a subset of legislative compliance management (LCM) risk that a FRFI manages within its LCM program OSFI clarified the broader nature of ML- related risk management, and the regulatory risks, and stressed the need to coordinate controls over these and related operational and reputation risks effectively The scope of ML risk is broad: In lines of business; Employment relationships; Supplier/service provider relationships; Of parent and affiliates; Worldwide. Potential reputation damage by the allegation of facilitating money laundering is potentially large AML is a subset of LCM: LCM deals with the risk of non-compliance with regulatory requirements AML deals with (1) the risk of ML and (2) the risk of non-compliance with AML regulatory requirements Reasonable measures means successful measures: Measures dont have to be successful/effective to be reasonable Measures have to be capable of being effective to be reasonable E.g., Procedures for ensuring that the identities of all new clients are ascertained, could be considered reasonable for ensuring that the new clients required by the PCMLTFA and Regs to be identified, are in fact identified. To be reasonable they must only be capable of being effective in the circumstances. Non-compliance with the procedures on account of, for example, carelessness, makes the procedures ineffective; unsuccessful; but not unreasonable.The scope of ML risk is broad: In lines of business; Employment relationships; Supplier/service provider relationships; Of parent and affiliates; Worldwide. Potential reputation damage by the allegation of facilitating money laundering is potentially large AML is a subset of LCM: LCM deals with the risk of non-compliance with regulatory requirements AML deals with (1) the risk of ML and (2) the risk of non-compliance with AML regulatory requirements Reasonable measures means successful measures: Measures dont have to be successful/effective to be reasonable Measures have to be capable of being effective to be reasonable E.g., Procedures for ensuring that the identities of all new clients are ascertained, could be considered reasonable for ensuring that the new clients required by the PCMLTFA and Regs to be identified, are in fact identified. To be reasonable they must only be capable of being effective in the circumstances. Non-compliance with the procedures on account of, for example, carelessness, makes the procedures ineffective; unsuccessful; but not unreasonable.

    22. Misconceptions (contd) Reasonable measures = successful measures OSFI clarified that reasonable measures are measures that are capable in the circumstances of being effective

    23. Other Industry Comments Too long = more costly to comply Too long = repeats the Act and Regulations and FINTRAC guidance OSFI clarified that the length reflects the larger volume and complexity of Canadian regulatory requirements Unpinning function necessitates references to regulatory requirements

    24. Questions

    25. Assessment of Inherent Risks AML Info Session May 6, 2009

    26. Topics What is/is not inherent risk assessment What is required Methodology for assessment Risk categories Risk ratings Examples of weak(er) inherent risk assessments

    27. What is inherent risk assessment? Is a process where: Current and emerging ML and TF risks inherent in activities of the FRFI are identified The relative seriousness of the identified risks are assessed or weighted Higher risks are identified

    28. Definition of inherent existing in something as a permanent or essential attribute -Oxford Dictionary, 10th ed.

    29. What it is not It is not a net assessment of risk: Operational controls are not factored in as a risk mitigant (this is a control self-assessment) The materiality of the business (contribution to revenue/allocation of capital) to the overall operations is not a factor

    30. What it is not Inherent AML risk ? Credit risk

    31. What is required PCMLTFA ss.9.6(2) requires: Compliance program include the development and application of policies and procedures to assess, in the course of the FRFIs activities, the risk of a ML or TF offence.

    32. What is required PCMLTFR, s.71(1)(c) requires four categories of ML and TF risk be covered in an assessment of a FRFIs inherent risk: The clients and business relationship of the FRFI The products and delivery channels of the FRFI The geographic location of the activities of the FRFI Any other relevant factor

    33. Methodology for Assessment Neither the PCMLTFA/R nor OSFI prescribes the methodology to be used Open to FRFIs to develop their own methodology BUT, the methodology should: Be consistently used among all business lines Assess inherent ML and TF risk across all business lines Include all categories of risk Apply a risk scoring model to each criteria Have central oversight by the CAMLO

    34. Why is inherent risk assessment important? Enables FRFIs to identify higher risk clients for enhanced due diligence and ongoing monitoring Enables FRFIs to mitigate against: Regulatory risk Legal risk Reputational risk Operational risk

    35. Risk Categories i. Client and business relationship risk Risk associated with the types of clients that buy or use a FRFIs products and services

    36. Client Risk Examples Politically exposed persons or exposure to a PEFP Persons appearing on the terrorist or criminal list International clients from high risk jurisdictions Quasi legal activities, such as internet gaming Intermediaries, such as lawyers and accountants Intermediary structures, such as holding companies, legal arrangements numbered companies that have no apparent business purpose Clients whose geographic distance from the FRFI is not explainable Clients whose nature, structure or relationship make it difficult to identify the ultimate beneficial owner Clients whose nationality/residence/location of employment is associated with a country on a prohibited country list or a high risk country list Cash and cash equivalent intensive businesses, such as: casinos, MSBs, foreign exchange business, etc Charities Domestic clients whose income is derived from local salary, wages, modest investments, pensions, etc. Plain vanilla retail banking clients limited products, transactions, etc.

    37. Client Risk Risk Ratings Can risk profile for each client: Prohibited: wont do business with this type of customer eg. A person involved in quasi legal activities such as internet gaming, arms dealing, etc. Higher risk: very reluctant to do business with this type of customer because they require the highest level of enhanced due diligence eg. PEFPs, payable-through account holder, etc. High risk: clients that require enhanced due diligence eg. A charity, MSB, etc. Moderate/Low risk: clients that have the standard KYC procedures applied eg. Domestic client whose income is derived from a local salary

    38. Risk Categories ii.a. Product/Service risk Risk associated with products/services of a FRFI that enable clients to move funds.

    39. Product/Service Risk Examples Deposit taking, especially cash, and insurance products that allow large one-time or regular payments or deposits, to be made and subsequently withdrawn Credit accounts where large credit balances are allowed to be maintained Wire transfers Trade Finance services Private Banking Free look or cooling off periods coupled with premium refunds Payable through accounts Internet banking Sale of stored value cards Supports high transaction volumes, high speed movement of funds

    40. Product/Service Risk Risk Rating Can risk profile for each product or service: Prohibited: wont offer or exiting this product or service due to the level of risk eg. Depends on FRFIs risk tolerance level Higher risk: products or services that offers customers the ability to move funds around and requires the highest level of enhanced due diligence eg. Internet banking High risk: products or services that require enhanced due diligence eg. Private banking Moderate/Low risk: products or services that have the standard KYC procedures applied eg. A savings account

    41. Risk Categories ii.b. Delivery Channel Risk The risk associated with how a FRFIs products/services are delivered to clients, including services delivered to clients non-face-to-face.

    42. Delivery Channel Risk Examples Use of intermediaries or introducers eg. Mortgage and deposit agents Internet, telephone and mail as a substitute for face to face interaction

    43. Risk Categories Geographic Risk Risk associated with places in which FRFIs activities are carried out.

    44. Geographic Risk Examples Higher risk include countries: subject to Canadian or other national sanctions, embargoes or similar measures subject to United Nations Security Council sanctions Identified by credible sources as providing support for terrorist activities Identified by credible sources as having significant levels of corruption or other criminal activity Not members of FATF Can categorize domestic risk based on urban vs rural; known crime/gang areas, etc.

    45. Geographic Risk Risk Ratings Can risk profile for geographic risk: Prohibited: exiting this location due to the level of risk eg. A United Nations Security Council sanctioned country Higher risk: countries that are identified as having significant levels of corruption and/or weak AML legislation High risk: certain urban cities based on levels of crime Moderate/Low risk: certain domestic areas where no reported levels of organized crime, drug related crime, etc.

    46. Any Other Relevant Factor Transaction risk -volume, frequency Reputation risk of the client Suspicious/unusual transaction reports filed

    47. Risk Ratings Apply a risk scoring model to each criteria The risk score will determine the degree of customer due diligence for each client -basic or enhanced Will determine the level of ongoing monitoring required

    48. Risk Value Risk Value = Client Risk + Product Risk + Geographic Risk + Other

    49. Risk Rating Factors used in the risk scoring model will result in a total score Some factors may be so significant in and of themselves that they will result in a high risk score irrespective of other factors ie. Association with a high risk country The total score will equate to a risk based category, such as prohibited, higher, high, moderate, low The score and the risk category will determine: -whether the client is accepted or not -the level of senior management approval -the level of due diligence -the level of ongoing monitoring required

    50. Risk Ratings Enables the identification of the higher risks to which enhanced due diligence and ongoing monitoring must be applied Can have a numerical rating assigned to factors to enable the scoring of each category Eg. The country of residence of a client is assigned a score based on the risk of the country. Canada may score a lower value compared to a sanctioned country, which may receive the highest score, but Canada might score higher on organized crime or drug production.

    51. Examples of weak inherent risk assessments Mixing of net risk with inherent risk eg. Operational controls are factored into the inherent risk assessment; therefore the true risk is not adequately understood

    52. Examples of weak inherent risk assessments There is no weighting of the inherent risk criteria to assist in the calculation of an overall inherent risk score

    53. Examples of weak inherent risk assessments Lack of granularity in the risk factors Eg. Geographic risk defined as Canada and not by specific city/neighbourhood, etc.

    54. Examples of weak inherent risk assessments The clients occupation is not factored into the initial risk assessment Risk is that can have a customer with a high risk occupation, ie. an arms dealer that: -May not want to have as a customer (reputation risk); and -Does not have enhanced due diligence or ongoing monitoring Fact that this client is of higher risk is not triggered until maybe too late ie. The unusual/suspicious transaction has already occurred.

    55. Examples of weak inherent risk assessments The risk scoring model does not allow for judgement The total score of the client is close to the high risk category but doesnt fall into this category Client looks like a high risk client Is this client really a high risk client and EDD should apply or not? Can management recommend a bump into the high risk category based on other factors, such as profile similar to other high risk clients?

    56. Examples of weak inherent risk assessments High risk score is not attainable The scoring factors are too onerous and therefore the total score never equals a high risk category Result is that all customers are treated the same for due diligence and monitoring

    57. Enhanced Due Diligence AML Info Session May 6, 2009

    58. Topics What is EDD? What the PCMLTFA and R say What EDD isnt When is EDD appropriate or required?

    59. EDD: What is it? What are OSFIs expectations regarding Enhanced Due Diligence? What does the PCMLTFA/R say on this topic? When does a FRFI have to apply EDD? When should a FRFI apply EDD? These and many other questions will be answered in what follows

    60. Due Diligence To understand EDD, its necessary to understand (regular) due diligence Due Diligence has 4 components: Customer identification; Information gathering; Ascertaining identity; and Ongoing monitoring These elements must be in place for all clients (unless exempted from No. 1)

    61. PCMLTFA/R Act s.9.6(3) says that if FRFIs consider that ML or TF risk is high, they must take prescribed special measures for identifying clients, keeping records, and monitoring financial transactions in respect of the activities that pose the high risk. The prescribed special measures are at 71.1 of the PCMLTFR and are:

    62. Contd. Development and application of written policies and procedures for: Taking reasonable measures to keep client info up to date; Taking reasonable measures to conduct ongoing monitoring for the purpose of detecting [suspicious] transactions; and Mitigating the risk identified under 9.6(3) OSFI reviews these policies and procedures during AML/ATF assessments

    63. What EDD is not EDD is not exclusively used to identify suspicious activity. All activity of all customers must be monitored in some way to detect suspicious activity in order to comply with the obligations set forth in s.7 of the PCMLTFA (every financial transaction) EDD is not something from which customers activities are exempt if the product they bought exempted them from having their identity ascertained. If such a customer is identified by a FRFI as a high risk customer, EDD requirements apply. That could mean applying identification requirements even though the product might otherwise have qualified for exemption from such requirement. EDD is not a standard one size fits all set of measures. Unlike CDD generally (which applies to all customers) OSFI expects components of EDD to be tailored to specific circumstances (for example, classes of customers or situations) As a general rule, the higher the level of risk, the more extensive or intense the EDD measures should be

    64. When is EDD needed? Enhanced due diligence is applied to customers and/or transactions that FRFIs have identified as high risk; i.e. not standard or regular risk. Enhanced due diligence means: Keeping customer information up to date more frequently than for regular customers; Monitoring transactions more intensely and/or apply more complex business rules to identify unusual or suspicious activity; Taking other measures to mitigate high risk.

    65. Contd. Examples of how EDD should be distinguishable from regular CDD: Volume: higher numbers of checks, tests, reports, meetings, searches, etc. Intensity: broader info/details on customer and his/her activities; information on key associates of customer if any; information on sources of funds/wealth; Geographies: measures that are applied to customers in or linked to high risk countries (as defined by FRFI) Business Channels: measures that are designed to deal with non- face to face customers. This can include prescribed measures. Client profile: measures that apply to classes of customers which are designated by the FRFI as higher risk. FRFIs should have a policy clearly identifying what EDD is for them, including all key components. This policy should be cleared linked to the FRFIs assessment of inherent risks. It should be clear to employees which situations require EDD. OSFI should be able to distinguish clearly, when conducting an AML assessment of FRFIs, the difference between regular customer due diligence (for other than high risk customers) and EDD applied to higher risk customers.

    66. Contd. EDD is also required in the following prescribed circumstances: PEFPs: apply reasonable measures to establish the source of all existing and future funds which move into the PEFPs account; and Apply enhanced monitoring of the activities in the account.

    67. Contd. Correspondent Banking: If the FRFI allows customers of a correspondent bank to have direct access to services, it must: Ensure that foreign bank has met identification requirements consistent with ss 54 and 64 applied to those customers; and Ensure that foreign bank will supply customer identification data upon request.

    68. OSFIs International AML/ATF Involvement May 6, 2009

    69. Agenda International ML/TF situation International Response G20 FATF OSFIs International Relationships OSFIs International Activities FATF Commitment to the Private Sector

    70. International ML/TF Situation Sophistication and global nature of ML and TF require a global collaborative response by governments and the private sector Domestic and cross-border imperatives: Information sharing Coordinated action Ongoing changes to prevention and deterrence strategies

    71. International Response: G20 "Global financial stability hinges on collective action at the international level, but also on effective national systems. We call on all jurisdictions to adhere to the international standards in the prudential tax and AML/CFT areas. We agreed that the FATF should revise and reinvigorate the review process for assessing compliance by jurisdictions with AML/CFT standards, using agreed evaluation reports where available. April 2, 2009 National Post ( , 2009/04/02) IMF launches international fund aimed at fighting money laundering The International Monetary Fund yesterday announced the launch of a fund aimed at financing technical assistance in the global fight against money laundering and terrorism financing. The donor-supported trust fund will start operations on May 1 and provide about US$31-million over five years to help strengthen efforts to combat the crimes, the IMF said in a statement. National Post ( , 2009/04/02) IMF launches international fund aimed at fighting money laundering The International Monetary Fund yesterday announced the launch of a fund aimed at financing technical assistance in the global fight against money laundering and terrorism financing. The donor-supported trust fund will start operations on May 1 and provide about US$31-million over five years to help strengthen efforts to combat the crimes, the IMF said in a statement.

    72. International Response: FATF is Key Standard Setter Represents united commitment to the fight at global level Coordinates global cooperative and collaborative combat efforts to Improve national legislative and regulatory AML/ATF standards Promote the understanding, adoption and implementation of appropriate measures by governments and financial sectors Monitor improvements and maintain pressure to improve

    73. FATF is Key Standard Setter (contd) Establishment of effective enforcement measures Pressure on, and assistance to, countries with poor standards, low resources and little will to improve

    74. OSFIs International Relationships FATF-Global AML/ATF network 34 Member jurisdictions, 8 regulatory bodies and 19 other organizations as Observers Asia/Pacific Group on Money Laundering (APG) FATF-style regional body with 39 Member jurisdictions in the Asia/Pacific area Significant presence of Canadian FIs in the area, and Asia/Pacific FIs in Canada About the FATFs 34 members: 32 jurisdictions and 2 regional organisations (the Gulf Cooperation Council and the European Commission } About APG observers: They also include IMF, World Bank, OECD, UN Office on Drugs and Crime, Asian Development Bank and theEgmont Group of FIUs About the FATFs 34 members: 32 jurisdictions and 2 regional organisations (the Gulf Cooperation Council and the European Commission } About APG observers: They also include IMF, World Bank, OECD, UN Office on Drugs and Crime, Asian Development Bank and theEgmont Group of FIUs

    75. OSFIs International Relationships (contd) Caribbean Financial Action Task Force (CFATF) FATFstyle regional body with 30 Member jurisdictions in the Caribbean area Canada and other cooperating and supporting nations are FATF Members contributing financial and other resources to the work and resources of the CFATF Substantial presence of major Canadian banks in many CFATF Member countries

    76. OSFIs International Relationships: Non-FATF Basel Committee on Bank Supervision (BCBS) OSFI is a member of the AML working group Wolfsberg OSFI regularly participates in the Annual Forum for banks and regulators

    77. OSFIs International Activities Regular input on mutual evaluations (all FATF, APG and CFATF Members) Input on new FATF initiatives, such as, Preparations for the 4th round of evaluations (fine-tuning Recommendations, compliance assessment methodology) Standards re: financing weapons of mass destruction and proliferation (2008 addition to FATF mandate) Evaluation of tactics to complete the Global AML/ATF network by securing the involvement of countries not yet involved with the FATF

    78. OSFIs International Activities (contd) OSFI works with a number of other organizations that have Observer status at the FATF E.g., IAIS, BCBS, IMF, UN, World Bank Working with the IMF on the AML/ATF evaluation of Germany Has provided AML supervision expertise to FATF assessor training in Southern Africa and the Asia/Pacific area World Bank and UN training in the Caribbean and Middle East

    79. FATF Commitment to the Private Sector FATF work on non-binding guidance on the risk-based approach to AML/ATF implementation in the insurance sector, expected to be finalized later this year CLHIA participation Continuing FATF dialogue with the private sector, formalized under the Canadian presidency Continuing OSFI consultation with FRFIs on AML/ATF guidance and related subjects

    80. Thank you!

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