Characteristics of an effective system

A country properly identifies, assesses and understands its money laundering and terrorist financing risks, and co-ordinates domestically to put in place actions to mitigate these risks. This includes the involvement of competent authorities and other relevant authorities; using a wide range of reliable information sources; using the assessment(s) of risks as a basis for developing and prioritising AML/CFT policies and activities; and communicating and implementing those policies and activities in a co-ordinated way across appropriate channels. The relevant competent authorities also cooperate, and co-ordinate policies and activities to combat the financing of proliferation. Over time, this results in substantial mitigation of money laundering and terrorist financing risks.
This outcome relates primarily to Recommendations 1, 2, 33 and 34 and also elements of R.15.

Note to Assessors:

1. Assessors are not expected to conduct an in-depth review of, or assess the country’s assessment(s) of risks. Assessors, based on their views of the reasonableness of the assessment(s) of risks, should focus on how well the competent authorities use their understanding of the risks in practice to inform policy development and actions to mitigate the risks.
2. Assessors should take into consideration their findings for this Immediate Outcome (IO) in their assessment of the other IOs. However, assessors should only let their findings relating to the cooperation and co-ordination of measures to combat the financing of proliferation affect the assessments of IO.11 and not of the other IOs. (i.e. IO.2 to IO.10) that deal with combating money laundering and terrorist financing.

Core Issues to be considered in determining if the Outcome is being achieved

1. 1.1How well does the country understand its ML/TF risks?
2. 1.2How well are the identified ML/TF risks addressed by national AML/CFT policies and activities?
3. 1.3To what extent are the results of the assessment(s) of risks properly used to justify exemptions and support the application of enhanced measures for higher risk scenarios, or simplified measures for lower risk scenarios?
4. 1.4To what extent are the objectives and activities of the competent authorities and SRBs consistent with the evolving national AML/CFT policies and with the ML/TF risks identified?
5. 1.5To what extent do the competent authorities and SRBs co-operate and co-ordinate the development and implementation of policies92Having regard to AML/CFT requirements and Data Protection and Privacy rules and other similar provisions (e.g. data security / localisation) as needed. and activities to combat ML/TF and, where appropriate, the financing of proliferation of weapons of mass destruction?93Considering that there are different forms of co-operation and co-ordination between relevant authorities, Core Issue 1.5 does not prejudge a country’s choice for a particular form and applies equally to all of them.
6. 1.6To what extent does the country ensure that respective financial institutions, DNFBPs and other sectors affected by the application of the FATF Standards are aware of the relevant results of the national ML/TF risks?

1. Examples of Information that could support the conclusions on Core Issues

   1. The country’s assessment(s) of its ML/TF risks (e.g., types of assessment(s) produced; types of assessment(s) published / communicated).
   2. AML/CFT policies and strategies (e.g., AML/CFT policies, strategies and statements communicated/published; engagement and commitment at the senior officials and political level).
   3. Outreach activities to private sector and relevant authorities (e.g., briefings and guidance on relevant conclusions from risk assessment(s); frequency and relevancy of consultation on policies and legislation, input to develop risk assessment(s) and other policy products).

2. Examples of Specific Factors that could support the conclusions on Core Issues

   4. What are the methods, tools, and information used to develop, review and evaluate the conclusions of the assessment(s) of risks? How comprehensive are the information and data used?
   5. How useful are strategic financial intelligence, analysis, typologies, and guidance?
   6. Which competent authorities and relevant stakeholders (including financial institutions and DNFBPs) are involved in the assessment(s) of risks? How do they provide inputs to the national level ML/TF assessment(s) of risks, and at what stage?
   7. Is the assessment(s) of risks kept up-to-date, reviewed regularly and responsive to significant events or developments (including new threats and trends)?
   8. To what extent is the assessment(s) of risks reasonable and consistent with the ML/TF threats, vulnerabilities and specificities faced by the country? Where appropriate, does it take into account risks identified by other credible sources?
   9. Do the policies of competent authorities respond to changing ML/TF risks?
   10. What mechanism(s) or body do the authorities use to ensure proper and regular cooperation and co-ordination of the national framework and development and implementation of policies to combat ML/TF, at both policymaking and operational levels, and where relevant, the financing of proliferation of weapons of mass destruction? Does the mechanism or body include all relevant authorities?
   11. Is interagency information sharing undertaken in a timely manner in a bilateral or multiagency basis as appropriate?
   12. Are there adequate resources and expertise involved in conducting the assessment(s) of risks, and for domestic co-operation and co-ordination?

Characteristics of an effective system

The country provides constructive and timely information or assistance when requested by other countries. Competent authorities assist with requests to:

• locate and extradite criminals; and
• identify, freeze, seize, confiscate and share assets and provide information (including evidence, financial intelligence, supervisory and beneficial ownership information) related to money laundering, terrorist financing or associated predicate offences.

Competent authorities also seek international co-operation to pursue criminals and their assets. Over time, this makes the country an unattractive location for criminals (including terrorists) to operate in, maintain their illegal proceeds in, or use as a safe haven.

This outcome relates primarily to Recommendations 36 - 40 and also elements of Recommendations 9, 15, 24, 25 and 32.

Note to Assessors:

Assessors should take into consideration how their findings on the specific role of relevant competent authorities in seeking and delivering international co-operation under this IO would impact other IOs (particularly IO.3, IO.5, IOs. 6 to 10) including how the country seeks international co-operation with respect to domestic cases when appropriate.

Core Issues to be considered in determining if the Outcome is being achieved

1. 2.1To what extent has the country provided constructive and timely mutual legal assistance and extradition across the range of international co-operation requests? What is the quality of such assistance provided?
2. 2.2To what extent has the country sought legal assistance for international co-operation in an appropriate and timely manner to pursue domestic ML, associated predicate offences and TF cases which have transnational elements?
3. 2.3To what extent do the different competent authorities seek other forms of international cooperation to exchange financial intelligence and supervisory, law enforcement or other information in an appropriate and timely manner with their foreign counterparts for AML/CFT purposes?
4. 2.4To what extent do the different competent authorities provide (including spontaneously) other forms of international co-operation to exchange financial intelligence and supervisory, law enforcement or other information in a constructive and timely manner with their foreign counterparts for AML/CFT purposes?
5. 2.5How well are the competent authorities providing and responding to foreign requests for co-operation in identifying and exchanging basic and beneficial ownership information of legal persons and arrangements?

1. Examples of Information that could support the conclusions on Core Issues

   1. Evidence of handling and making requests for international co-operation with respect to extradition, mutual legal assistance and other forms of international co-operation (e.g., number of requests made, received, processed, granted, or refused relating to different competent authorities (e.g., central authority, FIU, supervisors, and law enforcement agencies) and types of request; timeliness of response, including prioritisation of requests; cases of spontaneous dissemination / exchange).
   2. Types and number of co-operation arrangements with other countries (including bilateral and multilateral MOUs, treaties, co-operation based on reciprocity, or other co-operation mechanisms).
   3. Examples of: (a) making, and (b) providing successful international co-operation (e.g., making use of financial intelligence / evidence provided to or by the country (as the case may be); investigations conducted on behalf or jointly with foreign counterparts; extradition of suspects/criminals for ML/TF).
   4. Information on investigations, prosecutions, confiscation and repatriation/sharing of assets (e.g., number of ML/TF investigations/ prosecutions, number and value of assets frozen and confiscated (including non-conviction-based confiscation) arising from international cooperation; value of assets repatriated or shared).

2. Examples of Specific Factors that could support the conclusions on Core Issues

   5. What operational measures are in place to ensure that appropriate safeguards are applied, requests are handled in a confidential manner to protect the integrity of the process (e.g., investigations and inquiry), and information exchanged is used for authorised purposes?
   6. What mechanisms (including case management systems) are used among the different competent authorities to receive, assess, prioritise and respond to requests for assistance?
   7. What are the reasons for refusal in cases where assistance is not or cannot be provided?
   8. What mechanisms (including case management systems) are used among the different competent authorities to select, prioritise and make requests for assistance?
   9. How do different competent authorities ensure that relevant and accurate information is provided to the requested country to allow it to understand and assess the requests?
   10. How well has the country worked with the requesting or requested country to avoid or resolve conflicts of jurisdiction or problems caused by poor quality information in requests?
   11. How do competent authorities ensure that details of the contact persons and requirements for international co-operation requests are clear and easily available to requesting countries?
   12. To what extent does the country prosecute its own nationals without undue delay in situations when it is unable by law to extradite them?
   13. What measures and arrangements are in place to manage and repatriate assets confiscated at the request of other countries?
   14. Are there aspects of the legal, operational or judicial process (e.g., excessively strict application of dual criminality requirements etc.) that impede or hinder international cooperation?
   15. To what extent are competent authorities exchanging information, indirectly, with noncounterparts?
   16. Are adequate resources available for: (a) receiving, managing, coordinating and responding to incoming requests for co-operation; and (b) making and coordinating requests for assistance in a timely manner?

Characteristics of an effective system

Supervision and monitoring address and mitigate the money laundering and terrorist financing risks in the financial and other relevant sectors by:

• preventing criminals and their associates from holding, or being the beneficial owner of, a significant or controlling interest or a management function in financial institutions, DNFBPs and VASPs; and
• promptly identifying, remedying, and sanctioning, where appropriate, violations of AML/CFT requirements or failings in money laundering and terrorist financing risk management.

Supervisors94In relation to financial institutions and DNFBPs (but not to VASPs), references to "Supervisors" include SRBs for the purpose of the effectiveness assessment. provide financial institutions, DNFBPs and VASPs with adequate feedback and guidance on compliance with AML/CFT requirements. Over time, supervision and monitoring improve the level of AML/CFT compliance, and discourage attempts by criminals to abuse the financial, DNFBP and VASPs sectors, particularly in the sectors most exposed to money laundering and terrorist financing risks.

This outcome relates primarily to Recommendations 14, 15, 26 to 28 , 34 and 35, and also elements of Recommendations 1 and 40.

Note to Assessors:

1. Assessors should determine which financial, DNFBP and VASP sectors to weight as being most important, moderately important or less important, and should reflect their judgment in Chapters 1, 5 and 6 of the report. While judging on the overall effectiveness of this IO, assessors should explain how they have weighted the identified deficiencies and also explain how these have been taken into account in relation to how the assessors have weighted the different sectors.
2. When determining how to weight the various financial, DNFBP and VASP sectors, assessors should consider their relative importance, taking into account the following factors:
   1. the ML/TF risks facing each sector, taking into account the materiality relevant to each sector (e.g. the relative importance of different parts of the financial sector and different DNFBPs and VASPs; the size, integration and make-up of the financial sector95E.g. including, but not limited to, the business concentration in the different sectors; the relative importance of different types of financial products or institutions; the amount of business which is domestic or cross-border; the extent to which the economy is cash-based; and estimates of the size of the informal sector and/or shadow economy), and
   2. structural elements and other contextual factors (e.g. whether established supervisors with accountability, integrity and transparency are in place for each sector; and the maturity and sophistication of the regulatory and supervisory regime for each sector)96E.g. special supervisory activities, such as thematic reviews and targeted outreach to specific sectors or institutions.
   For more information on how assessors should take risk, materiality, structural elements and other contextual factors into account, see paragraphs 5 to 12 of the Methodology. For more guidance on how to reflect in the report their judgment on the relative importance of the financial and DNFBP sectors, see the Mutual Evaluation Report Template in Annex II of the Methodology.
3. Assessors should also consider the relevant findings, including at the financial group level, the level of international co-operation which supervisors are participating in when assessing this IO.

Core Issues to be considered in determining if the Outcome is being achieved

1. 3.1How well does licensing, registration or other controls implemented by supervisors or other authorities prevent criminals and their associates from holding, or being the beneficial owner of a significant or controlling interest or holding a management function in financial institutions, DNFBPs or VASPs? How well are breaches of such licensing or registration requirements detected?
2. 3.2How well do the supervisors identify and maintain an understanding of the ML/TF risks in the financial and other sectors as a whole, between different sectors and types of institution, and of individual institutions?
3. 3.3With a view to mitigating the risks, how well do supervisors, on a risk-sensitive basis, supervise or monitor the extent to which financial institutions, DNFBPs and VASPs are complying with their AML/CFT requirements?
4. 3.4To what extent are remedial actions and/or effective, proportionate and dissuasive sanctions applied in practice?
5. 3.5To what extent are supervisors able to demonstrate that their actions have an effect on compliance by financial institutions, DNFBPs and VASPs?
6. 3.6How well do the supervisors promote a clear understanding by financial institutions, DNFBPs and VASPs of their AML/CFT obligations and ML/TF risks?

1. Examples of Information that could support the conclusions on Core Issues

   1. Contextual factors regarding the size, composition, and structure of the financial, DNFBP and VASP sectors and informal or unregulated sector (e.g., number and types of financial institutions (including MVTS), DNFBPs and VASPs licensed or registered in each category; types of financial (including cross-border) activities; relative size, importance and materiality of sectors).
   2. Supervisors’ risk models, manuals and guidance on AML/CFT (e.g., operations manuals for supervisory staff; publications outlining AML/CFT supervisory / monitoring approach; supervisory circulars, good and poor practises, thematic studies; annual reports).
   3. Information on supervisory engagement with the industry, the FIU and other competent authorities on AML/CFT issues (e.g., providing guidance and training, organising meetings or promoting interactions with financial institutions, DNFBPs and VASPs).
   4. Information on supervision (e.g., frequency, scope and nature of monitoring and inspections (onsite and off-site); nature of breaches identified; sanctions and other remedial actions (e.g., corrective actions, reprimands, fines) applied, examples of cases where sanctions and other remedial actions have improved AML/CFT compliance).

2. Examples of Specific Factors that could support the conclusions on Core Issues

   5. What are the measures implemented to prevent the establishment or continued operation of shell banks in the country?
   6. To what extent are “fit and proper” tests or other similar measures used with regard to persons holding senior management functions, holding a significant or controlling interest, or professionally accredited in financial institutions, DNFBPs and VASPs?
   7. What measures do supervisors employ in order to assess the ML/TF risks of the sectors and entities they supervise/monitor? How often are the risk profiles reviewed, and what are the trigger events (e.g., changes in management or business activities)?
   8. What measures and supervisory tools are employed to ensure that financial institutions (including financial groups), DNFBPs and VASPs are regulated and comply with their AML/CFT obligations (including those which relate to targeted financial sanctions on terrorism, and to countermeasures called for by the FATF)? To what extent has this promoted the use of the formal financial system?
   9. To what extent do the frequency, intensity and scope of on-site and off-site inspections relate to the risk profile of the financial institutions (including financial group), DNFBPs and VASPs?
   10. What is the level of co-operation between supervisors and other competent authorities in relation to AML/CFT (including financial group ML/TF risk management) issues? What are the circumstances where supervisors share or seek information from other competent authorities with regard to AML/CFT issues (including market entry)?
   11. What measures are taken to identify, license or register, monitor and sanction as appropriate, persons who carry out MVTs and virtual asset services or activities?
   12. Do supervisors have adequate resources to conduct supervision or monitoring for AML/CFT purposes, taking into account the size, complexity and risk profiles of the sector supervised or monitored?
   13. What are the measures implemented to ensure that financial supervisors have operational independence so that they are not subject to undue influence on AML/CFT matters?

Characteristics of an effective system

Financial institutions, DNFBPs and VASPs understand the nature and level of their money laundering and terrorist financing risks; develop and apply AML/CFT policies (including group-wide policies), internal controls, and programmes to adequately mitigate those risks; apply appropriate CDD measures to identify and verify their customers (including the beneficial owners) and conduct ongoing monitoring; adequately detect and report suspicious transactions; and comply with other AML/CFT requirements. This ultimately leads to a reduction in money laundering and terrorist financing activity within these entities.

This outcome relates primarily to Recommendations 9 to 23, and also elements of Recommendations 1, 6 and 29.

Note to Assessors:

1. Assessors should determine which financial, DNFBP and VASP sectors to weight as being most important, moderately important or less important, and should reflect their judgment in Chapters 1, 5 and 6 of the report. While judging on the overall effectiveness of this IO, assessors should explain how they have weighted the identified deficiencies and also explain how these have been taken into account in relation to how the assessors have weighted the different sectors.
2. When determining how to weight the various financial, DNFBP and VASP sectors, assessors should consider their relative importance, taking into account the following factors:
   1. the ML/TF risks facing each sector, taking into account the materiality relevant to each sector (e.g. the relative importance of different parts of the financial sector and different DNFBPs and VASPs; the size, integration and make-up of the financial sector97E.g. including, but not limited to, the business concentration in the different sectors; the relative importance of different types of financial products or institutions; the amount of business which is domestic or cross-border; the extent to which the economy is cash-based; and estimates of the size of the informal sector and/or shadow economy), and
   2. structural elements and other contextual factors (e.g. whether established supervisors with accountability, integrity and transparency are in place for each sector; and the maturity and sophistication of the regulatory and supervisory regime for each sector).98E.g. special supervisory activities, such as thematic reviews and targeted outreach to specific sectors or institutions
   For more information on how assessors should take risk, materiality, structural elements and other contextual factors into account, see paragraphs 5 to 12 of the Methodology. For more guidance on how to reflect in the report their judgment on the relative importance of the financial, DNFBP and VASP sectors, see the Mutual Evaluation Report Template in Annex II of the Methodology.
3. Assessors are not expected to conduct an in-depth review of the operations of financial institutions or DNFBPs, but should consider, on the basis of evidence and interviews with supervisors, FIUs, financial institutions and DNFBPs, whether financial institutions, DNFBPs and VASPs have adequately assessed and understood their exposure to money laundering and terrorist financing risks; whether their policies, procedures and internal controls adequately address these risks; and whether regulatory requirements (including STR reporting) are being properly implemented.

Core Issues to be considered in determining if the Outcome is being achieved

1. 4.1How well do financial institutions, DNFBPs and VASPs understand their ML/TF risks and AML/CFT obligations?
2. 4.2How well do financial institutions, DNFBPs and VASPs apply mitigating measures commensurate with their risks?
3. 4.3How well do financial institutions, DNFBPs and VASPs apply the CDD and record-keeping measures (including beneficial ownership information and ongoing monitoring)? To what extent is business refused when CDD is incomplete?
4. 4.4How well do financial institutions, DNFBPs and VASPs apply the enhanced or specific measures for: (a) PEPs, (b) correspondent banking, (c) new technologies, (d) wire transfers rules99In the context of VASPs, this refers to virtual asset transfer rules , (e) targeted financial sanctions relating to TF, and (f) higher-risk countries identified by the FATF?
5. 4.5To what extent do financial institutions, DNFBPs and VASPs meet their reporting obligations on the suspected proceeds of crime and funds in support of terrorism? What are the practical measures to prevent tipping-off?
6. 4.6How well do financial institutions, DNFBPs and VASPs apply internal controls and procedures (including at financial group level) to ensure compliance with AML/CFT requirements? To what extent are there legal or regulatory requirements (e.g., financial secrecy) impeding its implementation?

1. Examples of Information that could support the conclusions on Core Issues

   1. Contextual factors regarding the size, composition, and structure of the financial, DNFBP and VASP sectors and informal or unregulated sector (e.g., number and types of financial institutions (including MVTS), DNFBPs and VASPs licensed or registered in each category; types of financial (including cross-border) activities; relative size, importance and materiality of sectors).
   2. Information (including trends) relating to risks and general levels of compliance (e.g., internal AML/CFT policies, procedures and programmes, trends and typologies reports).
   3. Examples of compliance failures (e.g., sanitised cases; typologies on the misuse of financial institutions, DNFBPs and VASPs).
   4. Information on compliance by financial institutions, DNFBPs and VASPs (e.g., frequency of internal AML/CFT compliance review; nature of breaches identified and remedial actions taken or sanctions applied; frequency and quality of AML/CFT training; time taken to provide competent authorities with accurate and complete CDD information for AML/CFT purposes; accounts/relationships rejected due to incomplete CDD information; wire transfers rejected due to insufficient requisite information).
   5. Information on STR reporting and other information as required by national legislation (e.g., number of STRs submitted, and the value of associated transactions; number and proportion of STRs from different sectors; the types, nature and trends in STR filings corresponding to ML/TF risks; average time taken to analyse the suspicious transaction before filing an STR).

2. Examples of Specific Factors that could support the conclusions on Core Issues

   6. What are the measures in place to identify and deal with higher (and where relevant, lower) risk customers, business relationships, transactions, products and countries?
   7. Does the manner in which AML/CFT measures are applied prevent the legitimate use of the formal financial system, and what measures are taken to promote financial inclusion?
   8. To what extent do the CDD and enhanced or specific measures vary according to ML/TF risks across different sectors / types of institution, and individual institutions? What is the relative level of compliance between international financial groups and domestic institutions?
   9. To what extent is there reliance on third parties for the CDD process and how well are the controls applied?
   10. How well do financial institutions and groups, DNFBPs and VASPs ensure adequate access to information by the AML/CFT compliance function?
   11. Do internal policies and controls of the financial institutions and groups, DNFBPs and VASPs enable timely review of: (i) complex or unusual transactions, (ii) potential STRs for reporting to the FIU, and (iii) potential false-positives? To what extent do the STRs reported contain complete, accurate and adequate information relating to the suspicious transaction?
   12. What are the measures and tools employed to assess risk, formulate and review policy responses and institute appropriate risk mitigation and systems and controls for ML/TF risks?
   13. How are AML/CFT policies and controls communicated to senior management and staff? What remedial actions and sanctions are taken by financial institutions, DNFBPs and VASPs when AML/CFT obligations are breached?
   14. How well are financial institutions, DNFBPs and VASPs documenting their ML/TF risk assessments, and keeping them up to date?
   15. Do financial institutions, DNFBPs and VASPs have adequate resources to implement AML/CFT policies and controls relative to their size, complexity, business activities and risk profile?
   16. How well is feedback provided to assist financial institutions, DNFBPs and VASPs in detecting and reporting suspicious transactions?

Characteristics of an effective system:

Measures are in place to:

• prevent legal persons and arrangements from being used for criminal purposes;
• make legal persons and arrangements sufficiently transparent; and
• ensure that accurate and up-to-date basic and beneficial ownership information is available on a timely basis.

Basic information is available publicly, and beneficial ownership information is available to competent authorities. Persons who breach these measures are subject to effective, proportionate and dissuasive sanctions. This results in legal persons and arrangements being unattractive for criminals to misuse for money laundering and terrorist financing.

This outcome relates primarily to Recommendations 24 and 25, and also elements of Recommendations 1, 10, 37 and 40.

Note to Assessors:

Assessors should also consider the relevant findings in relation to the level of international cooperation which competent authorities are participating in when assessing this Immediate Outcome. This would involve considering the extent to which competent authorities seek and are able to provide the appropriate assistance in relation to identifying and exchanging information (including beneficial ownership information) for legal persons and arrangements.

Core Issues to be considered in determining if the Outcome is being achieved

1. 5.1To what extent is the information on the creation and types of legal persons and arrangements in the country available publicly?
2. 5.2How well do the relevant competent authorities identify, assess and understand the vulnerabilities and the extent to which legal persons created in the country can be, or are being misused for ML/TF?
3. 5.3How well has the country implemented measures to prevent the misuse of legal persons and arrangements for ML/TF purposes?
4. 5.4To what extent can relevant competent authorities obtain adequate, accurate and current basic and beneficial ownership information on all types of legal persons created in the country, in a timely manner?
5. 5.5To what extent can relevant competent authorities obtain adequate, accurate and current beneficial ownership information on legal arrangements, in a timely manner?
6. 5.6To what extent are effective, proportionate and dissuasive sanctions applied against persons who do not comply with the information requirements?

1. Examples of Information that could support conclusion on Core Issues

   1. Contextual information on the types, forms and basic features of legal persons and arrangements in the jurisdiction.
   2. Experiences of law enforcement and other relevant competent authorities (e.g., level of sanctions imposed for breach of the information requirements; where and how basic and beneficial ownership information (including information on the settler, trustee(s), protector and beneficiaries) is obtained; information used in supporting investigation).
   3. Typologies and examples of the misuse of legal persons and arrangements (e.g., frequency with which criminal investigations find evidence of the country’s legal persons and arrangements being used for ML/TF; legal persons misused for illegal activities dismantled or struck-off).
   4. Sources of basic and beneficial ownership information (e.g., types of public information available to financial institutions and DNFBPs; types of information held in the company registry or by the company).
   5. Information on the role played by “gatekeepers” (e.g., company service providers, accountants, legal professionals) in the formation and administration of legal persons and arrangements.
   6. Other information (e.g., information on existence of legal arrangements; responses (positive and negative) to requests for basic or beneficial ownership information received from other countries; information on the monitoring of quality of assistance).

2. Examples of Specific Factors that could support the conclusions on Core Issues

   7. What are the measures taken to enhance the transparency of legal persons (including dealing with bearer shares and share warrants, and nominee shareholders and directors) and arrangements?
   8. How do relevant authorities ensure that accurate and up-to-date basic and beneficial ownership information on legal persons is maintained? Is the presence and accuracy of information monitored, tested/certified or verified?
   9. To what extent is the time taken for legal persons to register changes to the required basic and beneficial ownership information adequate to ensure that the information is accurate and up to date? Where applicable, to what extent are similar changes in legal arrangements registered in a timely manner?
   10. To what extent can financial institutions and DNFBPs obtain accurate and up-to-date basic and beneficial ownership information on legal persons and arrangements? What is the extent of information that trustees disclose to financial institutions and DNFBPs?
   11. Do the relevant authorities have adequate resources to implement the measures adequately?

Characteristics of an effective system

A wide variety of financial intelligence and other relevant information is collected and used by competent authorities to investigate money laundering, associated predicate offences and terrorist financing. This delivers reliable, accurate, and up-to-date information; and the competent authorities have the resources and skills to use the information to conduct their analysis and financial investigations, to identify and trace the assets, and to develop operational analysis.

This outcome relates primarily to Recommendations 29 to 32 and also elements of Recommendations 1, 2, 4, 8, 9, 15, 34 and 40.

Note to Assessors:

1. This outcome includes the work that the FIU does to analyse STRs and other data; and the use by competent authorities of FIU products, other types of financial intelligence and other relevant information100 The sources include information derived from STRs, cross-border reports on currency and bearer negotiable movements, law enforcement intelligence; criminal records; supervisory and regulatory information; and information with company registries etc. Where applicable, it would also include reports on cash transactions, foreign currency transactions, wire transfers records, information from other government agencies including security agencies; tax authorities, asset registries, benefits agencies, NPOs authorities; and information which can be obtained through compulsory measures from financial institutions and DNFBPs including CDD information and transaction records, as well as information from open sources..
2. Assessors should also consider the relevant findings on the level of international co-operation which competent authorities are participating in when assessing this Immediate Outcome. This would involve considering the extent which FIUs and law enforcement agencies are able to, and do seek appropriate financial and law enforcement intelligence and other information from their foreign counterparts.

Core Issues to be considered in determining if the Outcome is being achieved

1. 6.1To what extent are financial intelligence and other relevant information accessed and used in investigations to develop evidence and trace criminal proceeds related to ML, associated predicate offences and TF?
2. 6.2To what extent are the competent authorities receiving or requesting reports (e.g., STRs, reports on currency and bearer negotiable instruments) that contain relevant and accurate information that assists them to perform their duties?
3. 6.3To what extent is FIU analysis and dissemination supporting the operational needs of competent authorities?
4. 6.4To what extent do the FIU and other competent authorities co-operate and exchange information and financial intelligence? How securely do the FIU and competent authorities protect the confidentiality of the information they exchange or use?

1. Examples of Information that could support the conclusions on Core Issues

   1. Experiences of law enforcement and other competent authorities (e.g., types of financial intelligence and other information available; frequency with which they are used as investigative tools).
   2. Examples of the co-operation between FIUs and other competent authorities and use of financial intelligence (e.g., statistics of financial intelligence disseminated/exchanged; cases where financial intelligence was used in investigation and prosecution of ML/TF and associated predicate offences, or in identifying and tracing assets).
   3. Information on STRs (e.g., number of STRs/cases analysed; perception of quality of information disclosed in STRs; frequency with which competent authorities come across examples of unreported suspicious transactions; cases of tipping-off; see also Immediate Outcome 4 for information on STR reporting).
   4. Information on other financial intelligence and information (e.g., number of currency and bearer negotiable instruments reports receive, and analysed; types of information that law enforcement and other competent authorities receive or obtain/access from other authorities, financial institutions and DNFBPs).
   5. Other documents (e.g., guidance on the use and reporting of STRs and other financial intelligence; typologies produced using financial intelligence).

2. Examples of Specific Factors that could support the conclusions on Core Issues

   6. How well does the FIU access and use additional information to analyse and add value to STRs? How does the FIU ensure the rigour of its analytical assessments?
   7. How well do competent authorities make use of the information contained in STRs and other financial intelligence to develop operational analysis?
   8. To what extent does the FIU incorporate feedback from competent authorities, typologies and operational experience into its functions?
   9. What are the mechanisms implemented to ensure full and timely co-operation between competent authorities, and from financial institutions, DNFBPs and other reporting entities to provide the relevant information? Are there any impediments to the access of information?
   10. To what extent do the STRs reported contain complete, accurate and adequate information relating to the suspicious transaction?
   11. To what extent do the relevant competent authorities review and engage (including outreach by the FIU) reporting entities to enhance financial intelligence reporting?
   12. Do the relevant authorities have adequate resources (including IT tools for data mining and analysis of financial intelligence and to protect its confidentiality) to perform its functions?
   13. What are the measures implemented to ensure that the FIU has operational independence so that it is not subject to undue influence on AML/CFT matters?

Characteristics of an effective system

Money laundering activities, and in particular major proceeds-generating offences, are investigated; offenders are successfully prosecuted; and the courts apply effective, proportionate and dissuasive sanctions to those convicted. This includes pursuing parallel financial investigations and cases where the associated predicate offences occur outside the country, and investigating and prosecuting stand-alone money laundering offences. The component parts of the systems (investigation, prosecution, conviction, and sanctions) are functioning coherently to mitigate the money laundering risks. Ultimately, the prospect of detection, conviction, and punishment dissuades potential criminals from carrying out proceeds generating crimes and money laundering.

This outcome relates primarily to Recommendations 3, 30 and 31, and also elements of Recommendations 1, 2, 15, 32, 37, 39 and 40.

Note to Assessors:

Assessors should also consider the relevant findings on the level of international co-operation which competent authorities are participating in when assessing this Immediate Outcome. This would involve considering the extent to which law enforcement agencies are seeking appropriate assistance from their foreign counterparts in cross-border money laundering cases.

Core Issues to be considered in determining if the Outcome is being achieved

1. 7.1How well, and in what circumstances are potential cases of ML identified and investigated (including through parallel financial investigations)?
2. 7.2To what extent are the types of ML activity being investigated and prosecuted consistent with the country’s threats and risk profile and national AML/CFT policies?
3. 7.3To what extent are different types of ML cases prosecuted (e.g., foreign predicate offence, third-party laundering, stand-alone offence101Third party money laundering is the laundering by a person who was not involved in the commission of the predicate offence. Self-laundering is the laundering by a person who was involved in the commission of the predicate offence. Stand-alone (or autonomous) money laundering refers to the prosecution of ML offences independently, without also necessarily prosecuting the predicate offence. This could be particularly relevant inter alla i) when there is insufficient evidence of the particular predicate offence that gives rise to the criminal proceeds; or ii) in situatuins where there is a lack of territorial jurisdiction over the predicate offence. The proceeds may have been laundered be the defendant (self-laundering) or by a third party (third party ML). etc.) and offenders convicted?
4. 7.4To what extent are the sanctions applied against natural or legal persons convicted of ML offences effective, proportionate and dissuasive?
5. 7.5To what extent do countries apply other criminal justice measures in cases where a ML investigation has been pursued but where it is not possible, for justifiable reasons, to secure a ML conviction? Such alternative measures should not diminish the importance of, or be a substitute for, prosecutions and convictions for ML offences.

1. Examples of Information that could support the conclusions on Core Issues

   1. Experiences and examples of investigations, prosecutions and convictions( e.g., examples of cases rejected due to insufficient investigative evidence; what are the significant or complex ML cases that the country has investigated and prosecuted; examples of successful cases against domestic and transnational organised crime; cases where other criminal sanctions or measures are pursued instead of ML convictions).
   2. Information on ML investigations, prosecutions and convictions (e.g., number of investigations and prosecutions for ML activity; proportion of cases leading to prosecution or brought to court; number or proportion of ML convictions relating to third party laundering, stand-alone offence, self-laundering, and foreign predicate offences; types of predicate crimes involved; level of sanctions imposed for ML offences; sanctions imposed for ML compared with those for other predicate offences).

2. Examples of Specific Factors that could support the conclusions on Core Issues

   3. What are the measures taken to identify, initiate and prioritise ML cases (at least in relation to all major proceeds-generating offences) for investigation (e.g., focus between small and larger or complex cases, between domestic and foreign predicates etc.)?
   4. To what extent, and how quickly, can competent authorities obtain or access relevant financial intelligence and other information required for ML investigations?
   5. To what extent are joint or cooperative investigations (including the use of multidisciplinary investigative units) and other investigative techniques (e.g., postponing or waiving the arrest or seizure of money for the purpose of identifying persons involved) used in major proceeds generating offences?
   6. How are ML cases prepared for timely prosecution and trial?
   7. In what circumstances are decisions made not to proceed with prosecutions where there is indicative evidence of a ML offence?
   8. To what extent are ML prosecutions: (i) linked to the prosecution of the predicate offence (including foreign predicate offences), or (ii) prosecuted as an autonomous offence?
   9. How do the relevant authorities, taking into account the legal systems, interact with each other throughout the life-cycle of a ML case, from the initiation of an investigation, through gathering of evidence, referral to prosecutors and the decision to go to trial?
   10. Are there other aspects of the investigative, prosecutorial or judicial process that impede or hinder ML prosecutions and sanctions?
   11. Do the competent authorities have adequate resources (including financial investigation tools) to manage their work or address the ML risks adequately?
   12. Are dedicated staff/units in place to investigate ML? Where resources are shared, how are ML investigations prioritised?

Characteristics of an effective system

Criminals are deprived (through timely use of provisional and confiscation measures) of the proceeds and instrumentalities of their crimes (both domestic and foreign) or of property of an equivalent value. Confiscation includes proceeds recovered through criminal, civil or administrative processes; confiscation arising from false cross-border disclosures or declarations; and restitution to victims (through court proceedings). The country manages seized or confiscated assets, and repatriates or shares confiscated assets with other countries. Ultimately, this makes crime unprofitable and reduces both predicate crimes and money laundering.

This outcome relates primarily to Recommendations 1, 4, 32 and also elements of Recommendations 15, 30, 31, 37, 38, and 40.

Note to Assessors:

Assessors should also consider the relevant findings on the level of international co-operation which competent authorities are participating in when assessing this Immediate Outcome. This would involve considering the extent which law enforcement and prosecutorial agencies are seeking appropriate assistance from their foreign counterparts in relation to cross-border proceeds and instrumentalities of crime.

Core Issues to be considered in determining if the Outcome is being achieved

1. 8.1To what extent is confiscation of criminal proceeds, instrumentalities and property of equivalent value pursued as a policy objective?
2. 8.2 How well are the competent authorities confiscating102For the purposes of assessing the effectiveness of IO.8, full credit should be given for relevant use of the tax system, namely amounts recovered using tax assessment procedures that relate to the proceeds and instrumentalities of crime. The assessed country should ensure that any data provided is limited to tax recoveries that are linked to proceeds/ instrumentalities of crime, or the figures should be appropriately caveated. (including repatriation, sharing and restitution) the proceeds and instrumentalities of crime, and property of an equivalent value, involving domestic and foreign predicate offences and proceeds which have been moved to other countries?
3. 8.3To what extent is confiscation regarding falsely / not declared or disclosed cross-border movements of currency and bearer negotiable instruments being addressed and applied as an effective, proportionate and dissuasive sanction by border/custom or other relevant authorities?
4. 8.4How well do the confiscation results reflect the assessments(s) of ML/TF risks and national AML/CFT policies and priorities?

1. Examples of Information that could support the conclusions on Core Issues

   1. Experiences and examples of confiscation proceedings (e.g., the most significant cases in the past; types of confiscation orders obtained by the country; trends indicating changes in methods by which proceeds of crime is being laundered).
   2. Information on confiscation (e.g., number of criminal cases where confiscation is pursued; type of cases which involve confiscation; value of proceeds of crimes, instrumentalities or property of equivalent value confiscated, broken down by foreign or domestic offences, whether through criminal or civil procedures (including non-conviction-based confiscation); value of falsely / not declared or disclosed cross-border currency and bearer negotiable instruments confiscated; value or proportion of seized or frozen proceeds that is subject to confiscation; value or proportion of confiscation orders realised).
   3. Other relevant information (e.g. value of criminal assets seized / frozen; amount of proceeds of crime restituted to victims, shared or repatriated).

2. Examples of Specific Factors that could support the conclusions on Core Issues

   4. What are the measures and approach adopted by competent authorities to target proceeds and instrumentalities of crime (including major proceeds-generating crimes and those that do not originate domestically or have flowed overseas)?
   5. How do authorities decide, at the outset of a criminal investigation, to commence a financial investigation, with a view to confiscation?
   6. How well are competent authorities identifying and tracing proceeds and instrumentalities of crimes or assets of equivalent value? How well are provisional measures (e.g., freeze or seizures) used to prevent the flight or dissipation of assets?
   7. What is the approach adopted by the country to detect and confiscate cross-border currency and bearer negotiable instruments that are suspected to relate to ML/TF and associated predicate offences or that are falsely / not declared or disclosed?
   8. What are the measures adopted to preserve and manage the value of seized/confiscated assets?
   9. Are there other aspects of the investigative, prosecutorial or judicial process that promote or hinder the identification, tracing and confiscation of proceeds and instrumentalities of crime or assets of equivalent value?
   10. Do the relevant competent authorities have adequate resources to perform their functions adequately?

Characteristics of an effective system

Terrorist financing activities are investigated; offenders are successfully prosecuted; and courts apply effective, proportionate and dissuasive sanctions to those convicted. When appropriate, terrorist financing is pursued as a distinct criminal activity and financial investigations are conducted to support counter terrorism investigations, with good co-ordination between relevant authorities. The components of the system (investigation, prosecution, conviction and sanctions) are functioning coherently to mitigate the terrorist financing risks. Ultimately, the prospect of detection, conviction and punishment deters terrorist financing activities.

This outcome relates primarily to Recommendations 5, 30, 31 and 39, and also elements of Recommendations 1, 2, 15, 32, 37 and 40.

Note to Assessors:

1. Assessors should be aware that some elements of this outcome may involve material of a sensitive nature (e.g., information that is gathered for national security purposes) which countries may be reluctant or not able to make available to assessors.
2. Assessors should also consider the relevant findings on the level of international co-operation which competent authorities are participating in when assessing this Immediate Outcome. This would involve considering the extent which law enforcement and prosecutorial agencies are seeking appropriate assistance from their foreign counterparts in cross-border terrorist financing cases.

Core Issues to be considered in determining if the Outcome is being achieved

1. 9.1To what extent are the different types of TF activity (e.g., collection, movement and use of funds or other assets) prosecuted and offenders convicted? Is this consistent with the country’s TF risk profile?
2. 9.2How well are cases of TF identified, and investigated? To what extent do the investigations identify the specific role played by the terrorist financier?
3. 9.3To what extent is the investigation of TF integrated with, and used to support, national counter-terrorism strategies and investigations (e.g., identification and designation of terrorists, terrorist organisations and terrorist support networks)?
4. 9.4To what extent are the sanctions or measures applied against natural and legal persons convicted of TF offences effective, proportionate and dissuasive?
5. 9.5To what extent is the objective of the outcome achieved by employing other criminal justice, regulatory or other measures to disrupt TF activities where it is not practicable to secure a TF conviction?

1. Examples of Information that could support the conclusions on Core Issues

   1. Experiences and examples of TF investigations and prosecutions (e.g., cases where TF investigations are used to support counter-terrorism investigations and prosecutions; significant cases where (foreign or domestic) terrorists and terrorist groups are targeted, prosecuted or disrupted; observed trends in TF levels and techniques; cases where other criminal sanctions or measures are pursued instead of TF convictions).
   2. Information on TF investigations, prosecutions and convictions (e.g., number of TF investigations and prosecutions; proportion of cases leading to TF prosecution, type of TF prosecutions and convictions (e.g., distinct offences, foreign or domestic terrorists); level of sanctions imposed for TF offences; sanctions imposed for TF compared with those for other criminal activity; types and level of disruptive measures applied).

2. Examples of Specific Factors that could support the conclusions on Core Issues

   5. What are the measures taken to identify, initiate and prioritise TF cases to ensure prompt investigation and action against major threats and to maximise disruption?
   6. To what extent and how quickly can competent authorities obtain and access relevant financial intelligence and other information required for TF investigations and prosecutions?
   7. What are the underlying considerations for decisions made not to proceed with prosecutions for a TF offence?
   8. To what extent do the authorities apply specific action plans or strategies to deal with particular TF threats and trends? Is this consistent with the national AML/CFT policies, strategies and risks?
   9. How well do law enforcement authorities, the FIU, counter-terrorism units and other security and intelligence agencies co-operate and co-ordinate their respective tasks associated with this outcome?
   10. Are there other aspects of the investigative, prosecutorial or judicial process that impede or hinder TF prosecutions, sanctions or disruption?
   11. Do the competent authorities have adequate resources (including financial investigation tools) to manage their work or address the TF risks adequately?
   12. Are dedicated staff/units in place to investigate TF? Where resources are shared, how are TF investigations prioritised?

Characteristics of an effective system

Terrorists, terrorist organisations and terrorist support networks are identified and deprived of the resources and means to finance or support terrorist activities and organisations. This includes proper implementation of targeted financial sanctions against persons and entities designated by the United Nations Security Council and under applicable national or regional sanctions regimes. The country also has a good understanding of the terrorist financing risks and takes appropriate and proportionate actions to mitigate those risks, including measures that prevent the raising and moving of funds through entities or methods which are at greatest risk of being misused by terrorists. Ultimately, this reduces terrorist financing flows, which would prevent terrorist acts.

This outcome relates primarily to Recommendations 1, 4, 6 and 8, and also elements of Recommendations 14, 15, 16, 30 to 32, 37, 38 and 40.

Note to Assessors:

Assessors should also consider the relevant findings on the level of international co-operation which competent authorities are participating in when assessing this Immediate Outcome.

Core Issues to be considered in determining if the Outcome is being achieved

1. 10.1How well is the country implementing targeted financial sanctions pursuant to (i) UNSCR1267 and its successor resolutions, and (ii) UNSCR1373 (at the supra-national or national level, whether on the country’s own motion or after examination, to give effect to the request of another country)?
2. 10.2To what extent, without disrupting or discouraging legitimate NPO activities, has the country applied focused and proportionate measures to such NPOs which the country has identified as being vulnerable to terrorist financing abuse, in line with the risk-based approach?
3. 10.3To what extent are terrorists, terrorist organisations and terrorist financiers deprived (whether through criminal, civil or administrative processes) of assets and instrumentalities related to TF activities?
4. 10.4To what extent are the above measures consistent with the overall TF risk profile?

1. Examples of Information that could support the conclusions on Core Issues

   1. Experiences of law enforcement, FIU and counter terrorism authorities (e.g., trends indicating that terrorist financiers are researching alternative methods for raising / transmitting funds; intelligence/source reporting indicating that terrorist organisations are having difficulty raising funds in the country).
   2. Examples of interventions and confiscation (e.g., significant cases where terrorists, terrorist organisations or terrorist financiers are prevented from raising, moving and using funds or their assets seized / confiscated; investigations and interventions in NPOs misused by terrorists).
   3. Information on targeted financial sanctions (e.g., persons and accounts subject to targeted financial sanctions under UNSC or other designations; designations made (relating to UNSCR1373); assets frozen; transactions rejected; time taken to designate individuals; time taken to implement asset freeze following designation).
   4. Information on sustained outreach and targeted risk-based supervision or monitoring of NPOs that the country has identified as being at risk of TF abuse (e.g. frequency of review and monitoring of such NPOs (including risk assessments); frequency of engagement and outreach (including guidance) to NPOs regarding CFT measures and trends; remedial measures and sanctions taken against NPOs).

2. Examples of Specific Factors that could support the conclusions on Core Issues

   5. What measures has the country adopted to ensure the proper implementation of targeted financial sanctions without delay? How are those designations and obligations communicated to financial institutions, DNFBPs, VASPs and the general public in a timely manner?
   6. How well are the procedures and mechanisms implemented for (i) identifying targets for designation / listing, (ii) freezing / unfreezing, (iii) de-listing, and (iv) granting exemption? How well is the relevant information collected?
   7. To what extent is the country utilising the tools provided by UNSCRs 1267 and 1373 to freeze and prevent the financial flows of terrorists?
   8. How well do the systems for approving or licensing the use of assets by designated entities for authorised purposes comply with the requirements set out in the relevant UNSCRs (e.g., UNSCR 1452 and any successor resolutions)?
   9. What is the approach adopted by competent authorities to target terrorist assets? To what extent are assets tracing, financial investigations and provisional measures (e.g., freezing and seizing) used to complement the approach?
   10. To what extent are all four of the following elements being used to identify, prevent and combat terrorist financing abuse of NPOs: (a) sustained outreach, (b) targeted risk-based supervision or monitoring, (c) effective investigation and information gathering and (d) effective mechanisms for international cooperation. To what extent are the measures being applied focused and proportionate and in line with the risk based approach such that NPOs are protected from terrorist financing abuse and legitimate charitable activities are not disrupted or discouraged?
   11. To what extent are appropriate investigative, criminal, civil or administrative actions, co-operation and coordination mechanisms applied to NPOs suspected of being exploited by, or actively supporting terrorist activity or terrorist organizations? Do the appropriate authorities have adequate resources to perform their outreach / supervision / monitoring / investigation duties effectively?
   12. How well do NPOs understand their vulnerabilities and comply with the measures to protect themselves from the threat of terrorist abuse?
   13. Are there other aspects of the investigative, prosecutorial or judicial process that promote or hinder the identification, tracing and deprivation of assets and instrumentalities related to terrorists, terrorist organisations or terrorist financiers?
   14. Do the relevant competent authorities have adequate resources to manage their work or address the TF risks adequately
   15. Where resources are shared, how are TF related activities prioritised?

Characteristics of an effective system

Persons and entities designated by the United Nations Security Council Resolutions (UNSCRs) on proliferation of weapons of mass destruction (WMD) are identified, deprived of resources, and prevented from raising, moving, and using funds or other assets for the financing of proliferation. Targeted financial sanctions are fully and properly implemented without delay; monitored for compliance and there is adequate co-operation and co-ordination between the relevant authorities to prevent sanctions from being evaded, and to develop and implement policies and activities to combat the financing of proliferation of WMD.

This outcome relates to Recommendation 7 and elements of Recommendations 2 and 15.

Note to Assessors:

Core Issues to be considered in determining if the Outcome is being achieved

1. 11.1How well is the country implementing, without delay, targeted financial sanctions concerning the UNSCRs relating to the combating of financing of proliferation?
2. 11.2To what extent are the funds or other assets of designated persons and entities (and those acting on their behalf or at their direction) identified and such persons and entities prevented from operating or executing financial transactions related to proliferation?
3. 11.3To what extent do financial institutions, DNFBPs and VASPs comply with, and understand their obligations regarding targeted financial sanctions relating to financing of proliferation?
4. 11.4How well are relevant competent authorities monitoring and ensuring compliance by financial institutions, DNFBPs and VASPs with their obligations regarding targeted financial sanctions relating to financing of proliferation?

1. Examples of Information that could support the conclusions on Core Issues

   1. Examples of investigations and intervention relating to financing of proliferation (e.g., investigations into breaches of sanctions; significant cases in which country has taken enforcement actions (e.g., freezing or seizures) or provided assistance).
   2. Information on targeted financial sanctions relating to financing of proliferation (e.g., accounts of individuals and entities subject to targeted financial sanctions; value of frozen assets and property; time taken to designate persons and entities; time taken to freeze assets and property of individuals and entities following their designation by the UNSC).
   3. Monitoring and other relevant information relating to financing of proliferation (e.g., frequency of review and monitoring of financial institutions, DNFBPs and VASPs for compliance with targeted financial sanctions; frequency of engagement and outreach; guidance documents; level of sanctions applied on financial institutions, DNFBPs and VASPs for breaches).

2. Examples of Specific Factors that could support the conclusions on Core Issues

   4. What measures has the country adopted to ensure the proper implementation of targeted financial sanctions relating to financing of proliferation without delay? How are these designations and obligations communicated to relevant sectors in a timely manner?
   5. Where relevant, how well are the procedures implemented for (i) designation / listing, (ii) freezing / unfreezing, (iii) de-listing, and (iv) granting exemption? To what extent do they comply with the UNSCR requirements?
   6. How well do the systems and mechanisms for managing frozen assets and licensing the use of assets by designated individuals and entities for authorised purposes, safeguard human rights and prevent the misuse of funds?
   7. What mechanisms are used to prevent the evasion of sanctions? Do relevant competent authorities provide financial institutions, DNFBPs and VASPs with other guidance or specific feedback?
   8. To what extent would the relevant competent authorities be able to obtain accurate basic and beneficial ownership information on legal persons (e.g., front companies), when investigating offences or breaches concerning the UNSCRs relating financing of proliferation?
   9. To what extent are the relevant competent authorities exchanging intelligence and other information for investigations of violations and breaches of targeted financial sanctions in relation to financing of proliferation, as per the relevant UNSCRs?
   10. Do the relevant competent authorities have adequate resources to manage their work or address the financing of proliferation risks adequately?