The FATF is consulting private sector stakeholders before finalising the Guidance. We primarily seek views from financial institutions and designated non-financial businesses and professions (DNFBPs), but also welcome contributions from other interested stakeholders. We would welcome your views on the content of the Guidance, in particular on the areas of focus below.
1/ Does the Guidance provide sufficient clarity in distinguishing the mandatory requirements of the updated FATF Standards on proliferation financing risk assessment and mitigation, and additional measures that may support the implementation of these new requirements?
2/ Do you consider the four categories of risk indicators (including a sectoral focus on the maritime sector and trade finance) relevant, useful, and sufficient for your understanding of the risk of potential breach, non-implementation of evasion of proliferation financing targeted financial sanctions in the context of FATF Recommendation 7? What other indicators could be included in this section?
3/ Does the risk mitigation section of the Guidance provide sufficient clarity on how financial institutions and DNFBPs can address the risk of potential breach, non-implementation and evasion of targeted financial sanctions? What specific risk mitigation measures do you take to address such risks?
4/ Does the Guidance set clear expectations for financial institutions and DNFBPs in case of high-risk and low-risk customers and business relationships, including likely impact on de-risking and financial inclusion?
Please provide your response, including any drafting proposals to \FATF.Publicconsultation@fatf-gafi.org with the subject-line “Comments of [author] on the draft Guidance on Proliferation Financing Risk Assessment and Mitigation”, by 9 April 2021 (18h00 CET).
While submitting your response, please indicate the name of your organisation, the nature of your business, and your contact details. You may insert any specific drafting proposals directly in the attached text of the draft Guidance in tracked changes. We will use your contact information only for the purpose of this public consultation and for further engagement with you on this issue.
The FATF will not share this information with third parties without your consent.
At this stage, the FATF has not approved the draft Guidance. The FATF will consider the views received and revise the text of the Guidance for discussions at its June 2021 meetings.
p/o Virginie Gastine Menou
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