Public consultation on FATF Guidance on Proliferation Financing Risk Assessment and Mitigation

Submission from the Centre for Financial Crime and Security Studies (CFCS) at the Royal United Services Institute for Defence and Security Studies (RUSI)

Introduction

This submission is provided by the Centre for Financial Crime and Security Studies (CFCS) at RUSI. RUSI is an independent defence and security think-tank founded in 1831 and headquartered in the United Kingdom. Since launching in 2014, the CFCS has been dedicated to studying and addressing the challenges of financial crime and threat finance, and the
international responses to countering these threats. In 2015, we began a project on countering proliferation financing (PF). We believe that effective implementation of PF controls hinges on close cooperation between government stakeholders and the private sector, including on risk assessments.

We have long advocated for a risk-based approach to PF, and therefore welcomed the amendment of Recommendation 1 to require countries and private sector actors to identify, assess, understand, and mitigate PF risk, as related to the breach or non-implementation of targeted financial sanctions (TFS).

We were similarly pleased to read this draft guidance accompanying the amended Recommendation. The guidance in its current form will not only enhance implementation of TFS, but also make a significant contribution to wider efforts to counter PF.

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