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Analyse the effectiveness of the FATF in fostering international cooperation against money laundering and terrorist financing.

ICA International Diploma in Anti-Money Laundering

Assessment Two

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Your assignment questions are on the next page.

All parts of the questions can be answered in relation to a jurisdiction with which you are familiar. The name of the jurisdiction you have selected should be clearly stated in your answer.

Answer all the questions.

Question 1

Analyse the effectiveness of the FATF in fostering international cooperation against money laundering and terrorist financing. Evaluate how well its initiatives bridge regulatory gaps between different regions and consider the challenges that arise from divergent national interests.

Provide examples to support your analysis 40 marks

Question 2

Evaluate the impact of your chosen AML regulator on industry practices. Examine how its regulatory actions and guidance can shape the compliance culture within a firm with AML regulatory obligations, using case studies or specific examples to support your analysis. 30 marks

Question 3

Critically analyse the role of AML training in shaping a robust compliance culture within a firm. Select a sector of your choice and evaluate how targeted AML training initiatives contribute to risk mitigation and regulatory adherence. Discuss key training elements and potential implementation challenges. 30 marks

Total 100 marks

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Sample Answer

Question 1 FATF effectiveness and international cooperation (40 marks)

Short thesis: FATF works well at creating a shared global baseline and applying time-bound peer pressure that raises standards, but uneven capacity, domestic politics and risk appetites mean implementation is patchy and sometimes creates side-effects (like de-risking).

What FATF does well

  • Common language & reach. The 40 Recommendations set a global baseline for AML/CFT and are implemented through the FATF and nine FATF-Style Regional Bodies (FSRBs), covering 200+ jurisdictions. That scale lets supervisors, FIUs and prosecutors cooperate with a shared playbook. FATF+2FATF+2

  • Peer pressure that bites. Mutual evaluations and the ICRG “increased monitoring” (the so-called grey list) give countries public, time-bound action plans. The listing process is designed to be proportionate and prioritises jurisdictions with more significant financial sectors, which concentrates attention where spill-overs are largest. FATF+1

Recent outcomes (evidence it works)

  • October 2025 plenary: South Africa, Nigeria, Mozambique and Burkina Faso were removed from the grey list after demonstrable reforms to supervision, financial-intelligence use and inter-agency coordination. Policymakers expect this to ease capital inflows and reduce funding costs, showing how FATF pressure can translate into real changes and market effects. Reuters+1

Where gaps and tensions remain

  • Uneven capacity & politics. Progress relies on national institutions and political will. Even in mature systems, reforms compete with other priorities, so timetables slip; OPBAS’s own experience with professional-body supervisors in the UK shows how inconsistency can persist in practice. (This illustrates a broader global problem: rules can outpace supervisory capacity.) FCA

  • Prioritisation trade-offs. FATF explicitly prioritises reviews of jurisdictions with larger financial sectors; that’s logical for global risk, but it can feed perceptions of uneven treatment and geopolitical influence. FATF

  • Side-effects: de-risking. Public identification can trigger banks to withdraw services from higher-risk corridors or sectors. FATF stresses a risk-based, not zero-risk, approach, yet market behaviour can still overshoot, affecting inclusion and cross-border payments until confidence returns. FATF

Judgement

FATF is effective at coordinating and raising the floor, the global network, common standards and peer reviews work. It is less effective at speed and uniformity of outcomes because implementation depends on domestic choices and capacity. The regime should keep doubling down on effectiveness measures (not just technical ticks) and support countries to avoid de-risking while they fix gaps.

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