In this latest edition of Regulation Around the World, we examine the anti-money laundering and counter-terrorist financing (AML/CFT) landscape through the lens of eight questions, drawing on insights from Norton Rose Fulbright practitioners across our global network.
The questions are:
- What are the most significant recent or forthcoming changes to your jurisdiction’s AML/CFT framework, and how are they expected to affect compliance programmes for regulated entities?
- Are there any areas where local AML/CFT requirements diverge materially from international standards (e.g. FATF Recommendations or, where applicable, EU Anti-Money Laundering Directives), and what practical implications does this have for multinational businesses?
- How does your local supervisory authority approach risk-based supervision of AML/CFT obligations in practice, and what sectors or risk areas has it identified as current priorities?
- What is your supervisory authority’s practical stance on the use of new technologies — such as AI-driven transaction monitoring, digital identity verification, or blockchain analytics — within AML/CFT compliance programmes? Has it issued any specific guidance or expectations in this area?
- How does your jurisdiction approach AML/CFT obligations in the context of virtual assets, decentralised finance, and other emerging financial products or services, and are there areas where regulatory expectations remain unclear or are evolving?
- What are the key challenges and regulatory expectations around beneficial ownership transparency in your jurisdiction, particularly in relation to complex corporate structures, trusts, and nominee arrangements?
- What is your supervisory authority’s approach to de-risking — that is, the wholesale termination or restriction of business relationships with entire categories of customers (such as money service businesses, correspondent banking relationships, or non-profit organisations)? Has the authority issued any guidance discouraging blanket de-risking, and how does it expect firms to balance financial inclusion objectives against AML/CFT risk management?
- What are the practical expectations for group-wide AML/CFT compliance programmes operating across borders, and what challenges arise in your jurisdiction around reliance on third-party or group-level due diligence, information sharing within corporate groups, and managing conflicting regulatory requirements?
Read the full update here.
Recent Comments