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Council of Europe : Typologies report on AML/CFT supervision in times of crisis

Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism

MONEYVAL published today a report aimed at assisting authorities to effectively carry out their anti-money laundering countering terrorist financing (AML/CTF) supervisory activities in times of crisis or challenging external factors. It is based on information collected from supervisors across MONEYVAL jurisdictions and other international actors on the measures they have taken to overcome the difficulties caused by the COVID-19 pandemic, including operational limitations, notably the physical movement restrictions impeding the execution of on-site visits, limited human resources and technical complications. It draws on earlier work conducted by MONEYVAL on the topic of COVID-19 risks.

To mitigate emerging money laundering and terrorism financing (ML/TF) risks, supervisors and reporting entities were prompted to rapidly increase digitalization of their core functions to maintain operational continuity. Business continuity plans proved to be a useful tool for supervisory authorities to swiftly overcome the crisis situations as well. IT solutions, both software and hardware, were essential to access information from reporting entities on ML/TF risks and to enable shifting to remote supervision or hybrid inspections using video conferencing tools. In addition, supervisors used different communications channels, ranging from posting video clips and e-learning material to online webinars and trainings. In order to ensure data security, new protocols were implemented, and staff were trained on issues related to cybersecurity and data protection. Other measures with positive results included setting-up of coordination committees when the AML/CTF supervision was dissipated amongst several supervisors. Supervisors developed guidelines and/or regulations to permit the use of digital ID systems by reporting entities. Furthermore, they explored the exceptional use of simplified customer due diligence in low-risk scenarios, for reporting entities to on-board clients and facilitate the delivery of government benefits in response to the pandemic.

The report concludes that clear and direct communication on the ML/TF risks in challenging circumstances is an effective tool in continuing AML/CTF compliance by the private sector. At the same time, cross-border cooperation between supervisors could be enhanced by simplifying existing regulations and procedures relating to cross-border data exchange. Following the publication of the report, MONEYVAL member states and territories will be invited to provide feed-back on the use of its findings in one year.

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