ML major issue, millions of organisations, across sectors and 200 FATF member countries need to comply. FATF assessments pointing to major non-compliance with 40 recommendations and mutual evaluations are not not pretty reading, scorecard poor and countries need to lift their game. Meanwhile criminal enterprises are more sophisticated, more nimble and are winning.
Trend is rollout of tranche 2, presents challenges to resource constrained regulators stretched to provide guidance, oversight, management and enforcement. Challenges to T2 business is that cant afford advice, risks are high and controls are immature at best, non-existent at worse.
Massive wave coming