[{"data":1,"prerenderedAt":308},["ShallowReactive",2],{"news-key-findings-of-the-basel-aml-index-2025-2894":3,"news-key-findings-of-the-basel-aml-index-2025-2894-similar":45,"i-heroicons:arrow-left-20-solid":303},[4],{"id":5,"status":6,"date_created":7,"date_updated":7,"title":8,"type":9,"body":10,"date":11,"topic":12,"slug":14,"activity":15,"nid":16,"topics":17,"activities":18,"programme":19,"area":19,"websites":19,"language":20,"image":19,"translation_of":19,"countries":21,"tags":22,"authors":23,"images":42,"translations":43,"content":44},10624,"published","2026-06-04T21:13:52.000Z","Key findings of the Basel AML Index 2025","Blog","_The following are key findings of the 14th Basel AML Index Public Edition – an independent, data-based ranking of money laundering and related financial crime risks worldwide._ _Risk, as measured by the Basel AML Index, is defined as a country's vulnerability to money laundering and related financial crimes and its capacities to counter these threats. The Index does not attempt to measure the actual amount of money laundering activity. [Download the full report and related resources.](https:\u002F\u002Findex.baselgovernance.org\u002Fdownloads)_\n\n### Not a race to the bottom – but a slow drift towards the middle \n\nThe global average score in the Basel AML Index improved only slightly in 2025, from 5.30 to 5.28 (on a 0–10 scale where 10 equals maximum risk). The change is statistically insignificant. However, the fact that the global average is not _worsening_ offers some reassurance that efforts to counter money laundering are not being entirely outpaced by fast-moving threats, including the rising use of virtual assets and artificial intelligence for illicit purposes. \n\nThirteen new jurisdictions were added to this year’s [Public Edition](https:\u002F\u002Findex.baselgovernance.org\u002Franking) due to an increase in available data, bringing the total number covered to 177. Myanmar, Haiti and the Democratic Republic of the Congo remain at the top of the risk ranking. Finland is newly crowned as the lowest-risk jurisdiction for money laundering this year, despite a modest increase in its risk score, followed by Iceland and San Marino. \n\nOf the jurisdictions already assessed in last year’s Public Edition, 54 percent (88 jurisdictions) improved their risk scores this year. Forty-three percent (71 jurisdictions) saw their scores worsen and 3 percent (five jurisdictions) remained unchanged. \n\nOverall, the global picture shows a slow drift towards the middle. Improvements among several higher-risk jurisdictions – particularly in Africa – are encouraging, but they are offset by gradual declines among historically strong performers. \n\n### How jurisdictions performed across different risk domains\n\nThere was modest progress in the strength and quality of AML\u002FCFT\u002FCPF frameworks globally, with the average risk level improving from 5.58 to 5.54. Risk levels in corruption and fraud also edged down (5.12 to 5.09). \n\nOne of the most notable deteriorations occurred in the area of financial transparency and standards, highlighting growing concerns about beneficial ownership transparency and weaknesses in tax and financial regulation. This is particularly troubling at a time when mechanisms for evading oversight – such as the use of virtual assets (see page 19) – are expanding. Risks related to public accountability also increased slightly, from 4.23 to 4.35. \n\nIn terms of political and legal risks, the lack of meaningful change in the global average (from 4.45 to 4.46) masks significant variation between regions and individual jurisdictions. \n\n### Regional picture \n\nFour regions saw their average risk scores increase: North America, the EU and Western Europe, Eastern Europe and Central Asia, and the Middle East and North Africa. \n\nIn the EU and Western Europe, roughly 40 percent of jurisdictions received worse scores than last year. While most remained in the same risk category, their worsening scores suggest that historically strong performers may now be stagnating or slipping back. \n\nIn contrast, Sub-Saharan Africa, South Asia, East Asia and the Pacific, and Latin America and the Caribbean saw small overall improvements. \n\nSub-Saharan Africa stands out. Despite a still elevated regional average score (6.14), 70 percent of jurisdictions in this region improved significantly in 2025, and six left the FATF grey list after demonstrating improvements in their AML\u002FCFT frameworks. Seven of the top ten global improvers are African countries, and two – Burkina Faso and Côte d’Ivoire – moved from the higher to the medium risk category. \n\nTop 10 improvers (score ↓) \n\nTop 10 decliners (score ↑) \n\nLiberia, Mozambique, Burkina Faso, Nigeria, Mali, Tanzania, Côte d’Ivoire, Armenia, Philippines, Croatia \n\nKazakhstan, Lithuania, Taiwan (Chinese Taipei), Serbia, Costa Rica, Germany, Suriname, Barbados, Greece, Nicaragua \n\n### A more nuanced understanding of risk levels\n\nThe overall picture is not one of global decline, but of a gradual clustering in the middle of the risk spectrum. This underscores the need for clearer distinctions between risk categories. For that reason, the [Expert Edition of the Basel AML Index](https:\u002F\u002Findex.baselgovernance.org\u002Fexpert-edition) introduces a more balanced three-tier system this year, replacing the broad middle band that previously captured most jurisdictions.\n\nThe change reduces the overcrowding in the “medium risk” category and improves comparability between jurisdictions.","2025-12-05",[13],"","key-findings-of-the-basel-aml-index-2025-2894",[13],2894,[],[],null,"English",[],[],[24],{"id":25,"news_id":26,"authors_id":38},1378,{"id":5,"status":6,"user_created":27,"date_created":7,"user_updated":27,"date_updated":7,"title":8,"type":9,"body":10,"image":19,"date":11,"topic":28,"slug":14,"activity":29,"nid":16,"topics":30,"activities":31,"programme":19,"area":19,"websites":19,"translation_of":19,"language":20,"countries":32,"tags":33,"authors":34,"images":35,"translations":36,"content":37},"03bebfd8-0b40-4a2a-820d-b9d9c13b9de6",[13],[13],[],[],[],[],[25],[],[],[],{"id":39,"name":40,"position":19,"image":41},556,"Dr Kateryna Boguslavska","24433c58-4115-4c6c-b220-142b5a1b135b",[],[],[],[46,77,104,132,166,196,221,255,277],{"id":47,"body":48,"status":6,"type":9,"date":49,"slug":50,"title":8,"image":51,"countries":52,"topic":19,"activity":19,"tags":53,"nid":19,"topics":58,"activities":60,"authors":61,"images":63,"websites":64,"area":65,"programme":68,"language":20,"translations":70,"translation_of":19,"user_created":71,"date_created":72,"user_updated":73,"date_updated":74,"content":75,"link":76},10588,"\u003Cem>The following are key findings of the 14th Basel AML Index Public Edition – an independent, data-based ranking of money laundering and related financial crime risks worldwide. \u003C\u002Fem>\u003Cem>Risk, as measured by the Basel AML Index, is defined as a country's vulnerability to money laundering and related financial crimes and its capacities to counter these threats. The Index does not attempt to measure the actual amount of money laundering activity. \u003Ca href=\"https:\u002F\u002Findex.baselgovernance.org\u002Fdownloads\">Download the full report and related resources.\u003C\u002Fa>\u003C\u002Fem>\n\n### Not a race to the bottom – but a slow drift towards the middle\n\n\u003Cstrong>The global average score in the Basel AML Index improved only slightly in 2025\u003C\u002Fstrong>, from 5.30 to 5.28 (on a 0–10 scale where 10 equals maximum risk). The change is statistically insignificant. However, the fact that the global average is not \u003Cem>worsening \u003C\u002Fem>offers some reassurance that efforts to counter money laundering are not being entirely outpaced by fast-moving threats, including the rising use of virtual assets and artificial intelligence for illicit purposes.\n\n\u003Cstrong>Thirteen new jurisdictions were added to this year’s \u003Ca href=\"https:\u002F\u002Findex.baselgovernance.org\u002Franking\">Public Edition\u003C\u002Fa> \u003C\u002Fstrong>due to an increase in available data, bringing the total number covered to 177. Myanmar, Haiti and the Democratic Republic of the Congo remain at the top of the risk ranking. Finland is newly crowned as the lowest-risk jurisdiction for money laundering this year, despite a modest increase in its risk score, followed by Iceland and San Marino.\n\nOf the jurisdictions already assessed in last year’s Public Edition, 54 percent (88 jurisdictions) improved their risk scores this year. Forty-three percent (71 jurisdictions) saw their scores worsen and 3 percent (five jurisdictions) remained unchanged.\n\n\u003Cstrong>Overall, the global picture shows a slow drift towards the middle\u003C\u002Fstrong>. Improvements among several higher-risk jurisdictions – particularly in Africa – are encouraging, but they are offset by gradual declines among historically strong performers.\n\n### How jurisdictions performed across different risk domains\n\n\u003Cstrong>There was modest progress in the strength and quality of AML\u002FCFT\u002FCPF frameworks globally\u003C\u002Fstrong>, with the average risk level improving from 5.58 to 5.54. Risk levels in corruption and fraud also edged down (5.12 to 5.09).\n\n\u003Cstrong>One of the most notable deteriorations occurred in the area of financial transparency and standards\u003C\u002Fstrong>, highlighting growing concerns about beneficial ownership transparency and weaknesses in tax and financial regulation. This is particularly troubling at a time when mechanisms for evading oversight – such as the use of virtual assets (see page 19) – are expanding. Risks related to public accountability also increased slightly, from 4.23 to 4.35.\n\nIn terms of political and legal risks, the lack of meaningful change in the global average (from 4.45 to 4.46) masks significant variation between regions and individual jurisdictions.\n\n### Regional picture\n\n\u003Cstrong>Four regions saw their average risk scores increase\u003C\u002Fstrong>: North America, the EU and Western Europe, Eastern Europe and Central Asia, and the Middle East and North Africa.\n\n\u003Cstrong>In the EU and Western Europe, roughly 40 percent of jurisdictions received worse scores than last year\u003C\u002Fstrong>. While most remained in the same risk category, their worsening scores suggest that historically strong performers may now be stagnating or slipping back.\n\nIn contrast, Sub-Saharan Africa, South Asia, East Asia and the Pacific, and Latin America and the Caribbean saw small overall improvements.\n\n\u003Cstrong>Sub-Saharan Africa stands out\u003C\u002Fstrong>. Despite a still elevated regional average score (6.14), 70 percent of jurisdictions in this region improved significantly in 2025, and six left the FATF grey list after demonstrating improvements in their AML\u002FCFT frameworks. Seven of the top ten global improvers are African countries, and two – Burkina Faso and Côte d’Ivoire – moved from the higher to the medium risk category.\n\n\u003Ctable>\n\u003Ctbody>\n\u003Ctr>\n\u003Ctd>\n\u003Cstrong>Top 10 improvers (score ↓) \u003C\u002Fstrong>\n\u003C\u002Ftd>\n\u003Ctd>\n\u003Cstrong>Top 10 decliners (score ↑) \u003C\u002Fstrong>\n\u003C\u002Ftd>\n\u003C\u002Ftr>\n\u003Ctr>\n\u003Ctd>\n\u003Cp>\u003Cstrong>Liberia, Mozambique, \u003C\u002Fstrong>\u003Cstrong>Burkina Faso, \u003C\u002Fstrong>\u003Cstrong>Nigeria, Mali, \u003C\u002Fstrong>\u003Cstrong>Tanzania, Côte d’Ivoire, \u003C\u002Fstrong>\u003Cstrong>Armenia, \u003C\u002Fstrong>\u003Cstrong>Philippines, \u003C\u002Fstrong>\u003Cstrong>Croatia \u003C\u002Fstrong>\u003C\u002Fp>\n\u003C\u002Ftd>\n\u003Ctd>\n\u003Cp>\u003Cstrong>Kazakhstan, \u003C\u002Fstrong>\u003Cstrong>Lithuania, Taiwan (Chinese Taipei), \u003C\u002Fstrong>\u003Cstrong>Serbia, Costa Rica, Germany, \u003C\u002Fstrong>\u003Cstrong>Suriname, \u003C\u002Fstrong>\u003Cstrong>Barbados, \u003C\u002Fstrong>\u003Cstrong>Greece, \u003C\u002Fstrong>\u003Cstrong>Nicaragua \u003C\u002Fstrong>\u003C\u002Fp>\n\u003C\u002Ftd>\n\u003C\u002Ftr>\n\u003C\u002Ftbody>\n\u003C\u002Ftable>\n\n### A more nuanced understanding of risk levels\n\nThe overall picture is not one of global decline, but of a gradual clustering in the middle of the risk spectrum. This underscores the need for clearer distinctions between risk categories. For that reason, the \u003Ca href=\"https:\u002F\u002Findex.baselgovernance.org\u002Fexpert-edition\">Expert Edition of the Basel AML Index\u003C\u002Fa> introduces a more balanced three-tier system this year, replacing the broad middle band that previously captured most jurisdictions.\n\u003Cp>The change reduces the overcrowding in the “medium risk” category and improves comparability between jurisdictions.\u003C\u002Fp>","2025-12-08","key-findings","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F989a19a3-3c43-42e7-a7eb-b716058a6c3f?width=1000&height=650&format=webp&quality=80",[],[54],{"tags_id":55},{"id":56,"name":57},1346,"Basel AML Index",[59],"Anti-Money Laundering",[57],[62],1363,[],[57],[66,67],"Asset Recovery & Enforcement","Business Integrity & Governance",[69],"International Centre for Asset Recovery",[],"545a204d-e41b-4882-afda-481ecf3fd971","2025-12-05T11:07:25.000Z","b0662e2a-864d-4888-a1b7-4342b7570b30","2026-06-03T21:58:45.000Z",[],"\u002Fresources\u002Fnews\u002Fkey-findings",{"id":78,"body":79,"status":6,"type":80,"date":81,"slug":82,"title":83,"image":84,"countries":85,"topic":86,"activity":88,"tags":89,"nid":90,"topics":91,"activities":93,"authors":94,"images":95,"websites":96,"area":19,"programme":19,"language":19,"translations":98,"translation_of":19,"user_created":27,"date_created":99,"user_updated":100,"date_updated":101,"content":102,"link":103},10247,"The 2013 edition is the second release of the Basel Anti-Money Laundering (AML) Index. First published in April 2012, it continues to be the only rating of country money laundering\u002Fterrorist financing risk by an independent non-profit institution. A Public Edition of the AML Index is available online free of charge. An Expert Edition facilitates more sophisticated independent risk assessments for financial institutions, which have to comply with AML, counter-terrorism financing (CTF), sanctions, and anti-bribery rules.\n\n### The Basel AML Index 2013 results – key findings\n\nThe 2013 edition of the Basel AML Index covers 149 countries and assigns each country a score on a scale from 0 (Low risk) to 10 (High risk). High scores indicate a country is more vulnerable to money laundering\u002Fterrorist financing based on its AML\u002FCFT framework and other risk categories such as rule of law, corruption and financial and public transparency.\n\nIn the 2013 Basel AML Index, the 10 highest-risk countries were Afghanistan (8.55), Iran (8.48), Cambodia (8.35), Tajikistan (8.27), Iraq (8.19), Guinea-Bissau (8.17), Haiti (8.09), Mali (7.95), Swaziland (7.90), and Mozambique (7.90).\n\nAmong OECD countries, Greece (6.39), Luxembourg (6.24), Turkey (6.11), Japan (6.03), Austria (5.79), Germany (5.79), and Switzerland (5.76) received comparatively high risk scores, which reflects their roles as major financial centres, the Financial Action Task Force’s (FATF) Mutual Evaluation Reports (MER), local secrecy laws, and\u002For public disclosure of matters such as political financing.\n\nAs the Basel AML Index is designed to assess the risk of money laundering, the fact that any of these countries received a high ranking does not necessarily mean that they experience the most money laundering or terrorism financing.\n\nBy contrast, jurisdictions such as Cyprus (5.03), Singapore (4.92), the United Kingdom (4.81), or Colombia (4.64) had comparatively low risk ratings in the 2013 Basel AML Index, despite perceptions of them as major financial centres or tax havens. In these cases, the FATF MERs, which are given considerable emphasis and weight in the Basel AML Index, were an important factor that positively influenced their rating.\n\nThe countries with the lowest scores were Norway (3.17), Slovenia (3.29), Estonia (3.31), Finland (3.74), Sweden (3.75) and Lithuania (3.81).\n\n### Why the Basel AML Index?\n\nFinancial institutions and other businesses are required to identify high-risk jurisdictions in their country risk assessments. Some countries are more vulnerable to money laundering\u002Fterrorism financing than others. High-risk countries in money laundering\u002Fterrorist financing are often low-income or developing countries that are prone to corruption and tax evasion as well as industrialised countries where illicit assets are transferred and managed.\n\nStudies have attempted to trace worldwide illicit financial flows and to estimate their volume. In the absence of exact figures, indicators may help to evaluate countries’ money laundering risks.\n\nThe Basel AML Index addresses the challenge of determining what constitutes a high-risk jurisdiction and then of assessing countries for their money laundering\u002Fterrorism financing risk. It aggregates 14 external independent variables from open source information, measuring countries compliance and implementation of AML and CTF laws as well as related aspects such as banking secrecy, corruption, financial standards, and judicial capacity.","News","2013-06-21","basel-institute-on-governance-publishes-the-2013-edition-of-the-basel-aml-index-362","Basel Institute on Governance publishes the 2013 edition of the Basel AML Index","\u002Fpics\u002Fimg-placeholder.png",[],[59,87],"Asset Recovery",[13],[],362,[59,92],"Asset Recovery and Enforcement",[],[],[],[97],"Main page",[],"2022-05-26T22:59:35.000Z","3d9ff205-1640-4f34-b5b6-86977f51bbd6","2026-05-29T22:22:20.000Z",[],"\u002Fresources\u002Fnews\u002Fbasel-institute-on-governance-publishes-the-2013-edition-of-the-basel-aml-index-362",{"id":105,"body":106,"status":6,"type":9,"date":107,"slug":108,"title":109,"image":110,"countries":111,"topic":112,"activity":113,"tags":115,"nid":120,"topics":121,"activities":122,"authors":123,"images":125,"websites":126,"area":19,"programme":19,"language":19,"translations":127,"translation_of":19,"user_created":27,"date_created":128,"user_updated":100,"date_updated":129,"content":130,"link":131},9814,"_Falling rankings in the Basel AML Index, released today, show how many countries’ AML systems are a weak defence against today’s money laundering risks._\n\nIneffective anti-money laundering and counter financing of terrorism (AML\u002FCFT) systems and lack of transparency are leaving the door open to increasingly sophisticated money laundering schemes.\n\nThese are two findings of the 8th edition of the [Basel AML Index](https:\u002F\u002Fwww.baselgovernance.org\u002Fbasel-aml-index), an independent, research-based ranking that assesses countries' risk exposure to money laundering and terrorist financing (ML\u002FTF). They may help to explain why countries generally considered “safe” for investment have been hitting headlines recently with high-profile money laundering scandals.\n\n### Quality of AML\u002FCFT framework\n\nColombia, Latvia, Finland, China and Lithuania fell significantly in this year’s Basel AML Index rankings due to poor assessments of the effectiveness of their AML\u002FCFT systems by global money laundering watchdog, the Financial Action Task Force (FATF).\n\nFATF evaluations, which since 2013 assess not just _technical compliance_ of anti-money laundering systems but their _effectiveness_, are a key indicator in the Basel AML Index.\n\nFindings suggest that compliance and effectiveness often do not go hand in hand. Vanuatu’s AML\u002FCFT system, for example, scores highly for technical compliance but 0% for effectiveness.\n\nGretta Fenner, Managing Director of the Basel Institute on Governance, which issues the annual ranking, says:\n\n_“It’s like the car emissions scandal, but for illegal money. Preventive systems may be in place, but too often they’re not doing what they’re supposed do. Governments who are really serious about combating financial crime should get in the driver’s seat and start fixing the weaknesses that FATF assessments reveal. Countries benefit far more from being seen as a trustworthy, low-risk location for investment than by letting the dirty money of criminals flow through the loopholes.”_\n\nThis is a wake-up call. When it comes to AML\u002FCFT systems, countries need to focus on effectiveness and not just tick-box compliance.\n\n### Corruption and bribery\n\nDenmark is rated the least risky country for corruption and bribery, followed by New Zealand and Singapore in a list of top 10 performers dominated by Nordic and northern European countries. This risk category draws on Transparency International’s Corruption Perceptions Index and the TRACE Bribery Risk Matrix, which was newly added to the Basel AML Index this year as an indicator of business bribery risk.\n\nThe correlation between corruption and money laundering must be considered by governments when they seek to make their AML systems more effective.\n\n### Financial transparency and standards\n\nOffshore financial centres such as the Marshall Islands and Caribbean islands of Grenada and St. Lucia are among the lowest-performing countries in terms of financial transparency and standards. On a more positive note, some larger financial centres such as Switzerland and the UK have improved their scores in this category since 2018. Financial secrecy is considered a major risk for ML\u002FTF activity.\n\nAnalysis of FATF data reveals disappointing efforts to improve transparency of beneficial ownership, despite the attention this issue has attracted in recent years. The average score for technical compliance in this category is only just over 40%. The situation is even worse when it comes to the average effectiveness score, which is only 23%.\n\nInformation on ownership structures is largely unavailable to competent authorities, adding unnecessary hurdles to effective enforcement of laws on money laundering and related financial crimes. \n\n### Public transparency and accountability\n\nPoor performance in public transparency is mainly associated with political party and election campaign financing, as well as budgetary transparency and accountability. Countries as diverse as Vanuatu, Switzerland, Gambia and Qatar feature on the list of 10 poorest performers.\n\nCould there be room for more streamlined international rules?\n\n### Legal and political risks\n\nThe list of top 10 performers in terms of legal and political risks – covering media freedom and the strength of the rule of law – is again dominated by Nordic and northern European countries, plus New Zealand and Canada.\n\nCountries destabilised by war, with weak rule of law and where members of the press are stifled, are easily abused by criminals. This year’s list of poor performers in this category is led by Yemen and Venezuela.\n\n_For a full overview of results, analysis and interactive country comparison tables, plus the opportunity to demo the Expert Edition, visit the_ _Basel AML Index website:_ [_index.baselgovernance.org_](https:\u002F\u002Findex.baselgovernance.org\u002F)_._\n\nAbout the Basel AML Index\n-------------------------\n\nThe Basel AML Index is an independent annual ranking that assesses the risk of money laundering and terrorist financing (ML\u002FTF) around the world.\n\nPublished by the Basel Institute on Governance since 2012, it provides risk scores based on data from 15 publicly available sources such as the Financial Action Task Force (FATF), Transparency International, the World Bank and the World Economic Forum. The risk scores cover five domains:\n\n*   Quality of ML\u002FTF Framework\n*   Bribery and Corruption\n*   Financial Transparency and Standards\n*   Public Transparency and Accountability\n*   Legal and Political Risks\n\nThe Public Edition of the Basel AML Index 2019 covers 125 countries with sufficient data to calculate a reliable ML\u002FTF risk score.\n\nA comprehensive list of scores and sub-indicators for 203 countries is available in the [Expert Edition](https:\u002F\u002Fwww.baselgovernance.org\u002Fnode\u002F403), a subscription-based service used by companies and financial institutions as an ML\u002FTF country risk-rating tool for compliance and risk assessment purposes. Subscription is free for academic, public, supervisory and non-profit organisations.\n\nAdditional services and resources this year include an upgraded, in-depth analysis of FATF Mutual Evaluation Reports and a detailed analysis of ML\u002FTF risks in post-Soviet countries.\n\n### Downloads\n\n*   [Press release (English)](\u002Fsites\u002Fdefault\u002Ffiles\u002F2019-08\u002Fbasel_aml_index_press_release_en.pdf)\n*   [Comunicado de prensa (Español)](\u002Fsites\u002Fdefault\u002Ffiles\u002F2019-08\u002Fbasel_aml_index_press_release_es.pdf)\n*   [Press release (Russian)](\u002Fsites\u002Fdefault\u002Ffiles\u002F2019-08\u002Fbasel_aml_index_press_release_ru.pdf)\n*   [2019 report including ranking](\u002Fsites\u002Fdefault\u002Ffiles\u002F2019-08\u002FBasel%20AML%20Index%202019.pdf)\n\n### Contacts\n\n*   Technical or country-specific enquiries: Basel AML Index Project Manager, [Kateryna Boguslavska](https:\u002F\u002Fwww.baselgovernance.org\u002Fabout\u002Fpeople\u002Fkateryna-boguslavska)\n*   Media enquiries and requests for interview: Communications Officer: [Monica Guy](https:\u002F\u002Fwww.baselgovernance.org\u002Fabout\u002Fpeople\u002Fmonica-guy)\n*   Subscriptions: via the [website](https:\u002F\u002Fwww.baselgovernance.org\u002Fbasel-aml-index\u002Fexpert-edition) or email [index@baselgovernance.org](mailto:index@baselgovernance.org)","2019-08-19","basel-aml-index-2019-too-little-progress-are-aml-systems-effective-991","Basel AML Index 2019: Too little progress – are AML systems effective?","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F39c492c8-9a5a-4075-b5eb-2646910446eb?width=1000&height=650&format=webp&quality=80",[],[59],[57,114],"Media releases",[116],{"tags_id":117},{"id":118,"name":119},818,"Anti-money laundering",991,[59],[57,114],[124],1258,[],[97,57],[],"2022-05-26T22:56:03.000Z","2026-04-27T21:01:55.000Z",[],"\u002Fresources\u002Fnews\u002Fbasel-aml-index-2019-too-little-progress-are-aml-systems-effective-991",{"id":133,"body":134,"status":6,"type":80,"date":135,"slug":136,"title":137,"image":138,"countries":139,"topic":147,"activity":148,"tags":151,"nid":154,"topics":155,"activities":156,"authors":157,"images":159,"websites":160,"area":19,"programme":19,"language":19,"translations":161,"translation_of":19,"user_created":27,"date_created":162,"user_updated":100,"date_updated":163,"content":164,"link":165},10321,"_A new special short report for the_ [_Basel AML Index_](https:\u002F\u002Findex.baselgovernance.org\u002F) _analyses why so many Sub-Saharan African countries are on the so-called_ [_grey list_](https:\u002F\u002Fwww.fatf-gafi.org\u002Fpublications\u002Fhigh-risk-and-other-monitored-jurisdictions\u002F?hf=10&b=0&s=desc(fatf_releasedate)) _of the Financial Action Task Force (FATF)._\n\n_It covers the impacts on their economic development, the process of grey-listing and what governments need to do to be removed from the list. It also touches on specific areas of concern for anti-money laundering and counter-terrorist financing (AML\u002FCFT) in Sub-Saharan Africa._\n\n### Eight countries in Sub-Saharan Africa now grey-listed\n\nIn October 2022, the Democratic Republic of the Congo, Mozambique and Tanzania were [added](https:\u002F\u002Fwww.fatf-gafi.org\u002Fpublications\u002Fhigh-risk-and-other-monitored-jurisdictions\u002Fdocuments\u002Fincreased-monitoring-october-2022.html#:~:text=The%20FATF%20Standards%20do%20not,below%20in%20their%20risk%20analysis) to the so-called FATF grey list. Officially known as the “list of jurisdictions under increased monitoring”, the FATF grey list includes countries that are assessed to have strategic deficiencies in their national regimes to counter money laundering, terrorist financing and proliferation financing.\n\nSub-Saharan Africa now accounts for a third of countries on the grey list. This aligns with findings of the Basel AML Index, the Basel Institute’s ranking and risk assessment tool for money laundering and terrorist financing (ML\u002FTF). In the 2022 Public Edition of the Basel AML Index, the Sub-Saharan Africa region scored poorly for resilience to ML\u002FTF and more than 60 percent of countries fell into the high-risk category.\n\nAlthough grey-listed countries are not subject to sanctions, being placed on the list does have severe implications for their economies. These include a substantial decline in capital inflows and foreign direct investment.\n\n### Entering and leaving the grey list\n\nThe short report looks at the FATF’s process for grey-listing, which starts with being referred to the special International Co-operation Review Group for one year.\n\nIt then looks at what countries need to do to be removed from the list. A high-level political commitment is essential, as is completing an action plan developed to address each’s country’s specific gaps.\n\nOur analysis shows specific areas where Sub-Saharan African countries display particular weaknesses, and where regional support initiatives may be helpful. Cross-cutting weaknesses at the government level include the fundamental steps of accurately assessing ML\u002FTF risks and developing a risk-based approach to supervision. Enhancing the capacities of law enforcement agencies and financial intelligence units is also a key need.\n\nIt takes effort to complete the action plan, but progress is always welcomed. When an on-site visit confirms that all items are satisfactorily achieved, the FATF announces the country’s removal from the grey list at its next plenary meeting.\n\n### Learn more\n\n*   [Download](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2022-11\u002F221128%20Special%20report%20greylisting%20in%20SSA_final.pdf) the special report on FATF grey-listing in Sub-Saharan Africa.\n*   The report complements a new series of short reports on jurisdictions that have been delisted from the FATF grey list. These will publicly available on the Basel AML Index website ([Downloads page](https:\u002F\u002Findex.baselgovernance.org\u002Fdownload)).\n*   Remember: the Basel AML Index [Expert Edition](https:\u002F\u002Findex.baselgovernance.org\u002Fexpert-edition) offers a sophisticated tool for analysing geographic ML\u002FTF risk. Subscriptions are free to most organisations outside the private sector, as well as journalists.","2022-11-29","grey-listing-for-anti-money-laundering-failings-focus-on-sub-saharan-africa-2320","Grey-listing for anti-money laundering failings: focus on Sub-Saharan Africa","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fb95a9d18-c53a-4289-a7ad-6fa51334924f?width=1000&height=650&format=webp&quality=80",[140,141,142,143,144,145,146],7208,7209,7210,7211,7212,7213,7214,[59,87],[149,150],"Reports","Insights",[152],{"tags_id":153},{"id":118,"name":119},2320,[59,92],[149,150],[158],1152,[],[97],[],"2022-11-29T11:01:24.000Z","2026-05-29T22:22:24.000Z",[],"\u002Fresources\u002Fnews\u002Fgrey-listing-for-anti-money-laundering-failings-focus-on-sub-saharan-africa-2320",{"id":167,"body":168,"status":6,"type":9,"date":169,"slug":170,"title":171,"image":172,"countries":173,"topic":174,"activity":175,"tags":177,"nid":184,"topics":185,"activities":186,"authors":187,"images":190,"websites":191,"area":19,"programme":19,"language":19,"translations":192,"translation_of":19,"user_created":27,"date_created":193,"user_updated":100,"date_updated":163,"content":194,"link":195},10316,"_A joint blog by [Kateryna Boguslavska](https:\u002F\u002Fbaselgovernance.org\u002Fabout\u002Fpeople\u002Fkateryna-boguslavska), Basel Institute on Governance and [Maria Nizzero](https:\u002F\u002Frusi.org\u002Fpeople\u002Fnizzero), Royal United Services Institute (RUSI)._\n\nEffectively tackling illicit finance and money laundering is crucial to the integrity not only of financial systems, but of democratic societies. And alongside fresh ideas and commitments on fighting financial crimes, we need faster progress on existing ones.\n\nThese points are reflected in the latest findings of both the [Basel AML Index](https:\u002F\u002Findex.baselgovernance.org\u002F) and RUSI’s [Taskforce on a Transatlantic Response to Illicit Finance](https:\u002F\u002Fwww.rusi.org\u002Fexplore-our-research\u002Fprojects\u002Ftaskforce-transatlantic-response-illicit-finance) (TARIF).\n\nThe two projects approach the issue of dirty money from different angles. TARIF convened leading illicit finance experts and former policymakers to explore the negative impacts on illicit finance in the US and UK. It focused on the two countries’ vulnerabilities and responses to illicit finance linked to corruption and kleptocracy. It also laid bare the strategic use of illicit finance for malign purposes, and its impact on democracy, security, and financial integrity.\n\nIn contrast, the Basel AML Index is a data-based index that calculates countries’ risks of money laundering and terrorist financing (ML\u002FTF). It draws on 18 indicators providing reliable data on countries’ vulnerabilities to ML\u002FTF threats and their capacity to respond. The [11th Public Edition report](https:\u002F\u002Findex.baselgovernance.org\u002Fdownload) highlighted trends in global progress against money laundering.\n\nYet despite the differences, two points stood out in both projects. First, that the fight against illicit finance and money laundering goes beyond protecting the financial system; it is essential to protect ordinary citizens and democratic society. Second, that even though it is often clear what needs to be done, progress is far too slow. As the final TARIF [Policy Brief](https:\u002F\u002Fwww.rusi.org\u002Fexplore-our-research\u002Fpublications\u002Fpolicy-briefs\u002Fillicit-finance-threat-democracies-transatlantic-response) stated:\n\n> Many of the proposed actions and reforms are not new but have been hindered for years by perceived technical or legal barriers. Leaders should support, through resources and rhetoric, an uncompromising drive for solutions with… an acknowledged need to go further than the status quo.\n\nSo what are those actions that need – well, actioning?\n\n### Coming clean about risks and vulnerabilities\n\nAccording to TARIF, key to a transatlantic response to illicit finance is for the US and the UK to come clean about their own deficiencies. Commitments to combat corruption and illicit finance have been made in international fora, such as the [FATF](https:\u002F\u002Fwww.fatf-gafi.org\u002Fpublications\u002Ffatfgeneral\u002Fdocuments\u002Foutcomes-fatf-plenary-october-2022.html#:~:text=In%20March%202022%2C%20the%20FATF,information%20on%20the%20beneficial%20ownership), [G7](https:\u002F\u002Fwww.gov.uk\u002Fgovernment\u002Fpublications\u002Fg7-interior-and-security-ministers-meeting-september-2021\u002Fannex-3-statement-against-corruption-and-kleptocracies-accessible-version#:~:text=In%20June%202021%2C%20Leaders%20of,wealth%2C%20including%20in%20real%20estate.), [G20](https:\u002F\u002Fwww.fatf-gafi.org\u002Fpublications\u002Ffatfgeneral\u002Fdocuments\u002Fg20-april-2021.html) and [Summit for Democracy](https:\u002F\u002Fwww.state.gov\u002Fsummit-for-democracy\u002F). However, a change in narrative is only the starting point for a plan to tackle kleptocracy to be credible. Concrete actions have to follow.\n\nSimilarly, the 11th Basel AML Index report highlighted the importance of a risk-based approach to addressing money laundering. Tackling money laundering starts with a thorough understanding a country’s risks and vulnerabilities, plus a concrete plan to allocate resources efficiently to address the main risks. The Public Edition found that over the last five years, countries have progressed in conducting risk assessments and identifying high-risk jurisdictions. The next step should be the effective implementation of policies and strategies through robust plans based on these risks assessments. \n\n### Fixing long-standing issues\n\nIn terms of implementing a robust plan, TARIF set out how the US and the UK can practically and effectively strengthen their financial systems, close loopholes and develop safeguards. Many of the recommendations set out in the [Policy Brief](https:\u002F\u002Fwww.rusi.org\u002Fexplore-our-research\u002Fpublications\u002Fpolicy-briefs\u002Fillicit-finance-threat-democracies-transatlantic-response) cover topics discussed in policy forums for years, including enhancing asset recovery, dealing with professional enablers and increasing beneficial ownership transparency.\n\nThis year’s Basel AML Index report highlighted many of the same issues, noting that previous reports have continued to flag these over the years. For example, the report noted with concern the growing gap between countries’ technical compliance with international standards and the effectiveness of their efforts in practice.\n\nThe data also shows that issues of poor transparency of beneficial ownership, poor progress in the investigation and prosecution of ML\u002FTF offences, and low quality of supervision remain problems for all jurisdictions. The current challenges many jurisdictions are encountering with enforcing sanctions against Russian oligarchs only serve to illustrate problems that have long been present.\n\n### Applying standards and aligning goals\n\nThe good news is that we don’t need to reinvent the wheel, just make it turn faster. For some of the above challenges, especially those related to addressing money laundering directly, there are well-established standards like the FATF’s [40 Recommendations](https:\u002F\u002Fwww.fatf-gafi.org\u002Fpublications\u002Ffatfrecommendations\u002F?hf=10&b=0&s=desc(fatf_releasedate)).\n\nFor other aspects, different countries’ approaches may look very different but should ultimately all move towards the same destination. That includes approaches aimed at addressing the strategic use of illicit finance for malign purposes, supporting democracy and enhancing security, including moving from [sanctions-based asset freezes to confiscation](https:\u002F\u002Frusi.org\u002Fexplore-our-research\u002Fpublications\u002Fcommentary\u002Ffreeze-seize-creativity-and-nuance-needed).\n\n### Beyond financial implications\n\nThese actions, TARIF stresses, are not only essential to the fight against corruption. They are also necessary to prevent future abuses by kleptocratic actors and their influence, to strengthen democratic societies and both national and international security.\n\nThe Basel AML Index also notes that tackling money laundering:\n\n> …is about more than just fighting financial crime. It is about protecting people and the environment.\n\nUltimately, effective implementation is the plea at the heart of both reports. Reforms need political will and funding to be successful, whether they are aimed at tackling illicit finance or money laundering specifically. And at the end of the day, it is neither new technology nor blue-sky ideas that will be a gamechanger in the fight against dirty money.\n\nRather, progress will be driven by the effective application of agreed standards and by good old-fashioned principles – in RUSI’s words, of “honesty, cross-border and cross-sector collaboration, and ambition”.","2022-11-14","slow-progress-against-dirty-money-harms-people-and-undermines-democracy-2307","Slow progress against dirty money harms people and undermines democracy","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F68f7a893-99d7-43bf-9fc7-75615dbce6d5?width=1000&height=650&format=webp&quality=80",[],[59,87],[176,150],"Research",[178,182],{"tags_id":179},{"id":180,"name":181},1215,"Illicit financial flows",{"tags_id":183},{"id":118,"name":119},2307,[59,92],[176,150],[188,189],1154,1155,[],[97],[],"2022-11-14T11:01:26.000Z",[],"\u002Fresources\u002Fnews\u002Fslow-progress-against-dirty-money-harms-people-and-undermines-democracy-2307",{"id":197,"body":198,"status":6,"type":9,"date":199,"slug":200,"title":201,"image":202,"countries":203,"topic":205,"activity":206,"tags":207,"nid":210,"topics":211,"activities":212,"authors":213,"images":214,"websites":215,"area":19,"programme":19,"language":19,"translations":216,"translation_of":19,"user_created":27,"date_created":217,"user_updated":73,"date_updated":218,"content":219,"link":220},10384,"_A blog by Zisheng Xing, a law student at the Arizona State University who is undertaking a legal research internship at the Basel Institute on Governance._\n\nA monumental anti-money laundering fine recently dropped in Australia, sending shockwaves throughout the gambling industry – a sector well-known for flying under the radar of anti-money laundering and counter financing of terrorism (AML\u002FCFT) regulations.\n\nOn 11 July 2023, the Federal Court of Australia ordered the Australian gambling giant Crown Resorts (“Crown”) to pay an AUD 450 million (USD 300 million) fine for repeatedly violating the _Anti-Money Laundering and Counter-Terrorism Financing Act 2006_ (“AML\u002FCFT Act”) between 2015–2022. \n\nThe fine resulted from an agreement between Crown and Australia’s financial intelligence unit, AUSTRAC. This significant penalty is one of the largest in the gambling industry and serves as a severe reminder to casinos to implement and maintain effective AML\u002FCFT systems.\n\n### How did Crown breach Australia’s AML\u002FCFT Act?\n\nThe Australian Federal Court [found](https:\u002F\u002Fwww.judgments.fedcourt.gov.au\u002Fjudgments\u002FJudgments\u002Ffca\u002Fsingle\u002F2023\u002F2023fca0782) that Crown’s Melbourne and Perth casinos:\n\n*   failed to implement transaction monitoring programmes that were “appropriate to the nature, size and complexity of their business”;\n*   lacked “appropriate procedures to ensure higher risk customers were subjected to extra scrutiny” in their “enhanced customer due diligence” programmes;\n*   failed to conduct “appropriate ongoing customer due diligence on a range of specific customers who presented higher money laundering risks”;\n*   failed to maintain effective “risk-based systems and controls in their AML\u002FCFT programs”;\n*   failed to appropriately identify, timely assess and respond to ML\u002FTF risks they faced; and\n*   failed to establish appropriate frameworks for management oversight.\n\nWhen assessing the propriety of the penalty, the Federal Court concluded that Crown’s violations were “systemic, longstanding and egregious” and that they permeated “every designated service” that the enterprise provided its customers.\n\n### Risks posed by junkets\n\nA key finding of proceedings was that Crown had shown “a fundamental lack of regard” for the risk posed by junket operators. Junket operators are third parties who enter into agreements with casinos to facilitate gambling for high rollers. Junket operations often involve heightened AML risk, on the basis that they enable transfers of large amounts of money between jurisdictions. These transfers are administered in such a way that the source and ownership of funds involved can be easily obscured.\n\nMany of Crown’s contraventions were based on their relationship with such operations – even when the risks they presented were obvious. For example, AUSTRAC stated that Crown continued a “business relationship with a major casino junket operator” while “aware of allegations the operator was connected to organised crime.\"\n\nAdditionally, AUSTRAC noted at least 75 “suspicious incidents” involving approximately AUD 23 million in cash found in a private gaming room to which Crown Melbourne had given a junket operator exclusive access.\n\n### Why is this decision significant for AML\u002FCFT?\n\nAs [outlined](https:\u002F\u002Fwww.austrac.gov.au\u002Fnews-and-media\u002Fmedia-release\u002Ffederal-court-makes-ruling-crown-matter) by AUSTRAC, “the casino industry by its very nature, faces serious risks of exploitation by criminals seeking to launder the profits of their illicit enterprises.”\n\nConsequently, it is crucial that enterprises involved in this industry strictly implement and maintain strong AML measures and comply with relevant state laws. The penalty imposed on Crown is a clear warning to the entire gambling industry that its AML\u002FCFT compliance systems must be strong enough to meet obligations and “protect the… community and their businesses from serious financial crime.”\n\nThe decision also shows the importance of significant civil or administrative sanctions to enforcing compliance. As highlighted in our [quick guide to money laundering through the gambling industry](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fquick-guide-28-money-laundering-through-gambling-industry), proportionate penalties such as these both deter future breaches and encourage casinos to invest in robust AML\u002FCFT programmes.\n\n### Learn more\n\n*   View our [quick guide](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2022-09\u002FQG28%20gambling.pdf) to money laundering through the gambling industry by Isys Lam and Andrew Dornbierer.\n*   For more on money laundering risk assessment more generally, see the [Basel AML Index](https:\u002F\u002Findex.baselgovernance.org\u002F) – the Basel Institute’s flagship index of money laundering and terrorist financing risks around the world.","2023-08-07","the-crown-resorts-anti-money-laundering-fine-a-wake-up-call-for-the-gambling-industry-2496","The Crown Resorts anti-money laundering fine: a wake-up call for the gambling industry","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F4ba38771-e903-4845-9203-549526518d27?width=1000&height=650&format=webp&quality=80",[204],7170,[59],[13],[208],{"tags_id":209},{"id":118,"name":119},2496,[59],[],[],[],[97],[],"2023-08-07T16:01:34.000Z","2025-08-31T23:14:40.000Z",[],"\u002Fresources\u002Fnews\u002Fthe-crown-resorts-anti-money-laundering-fine-a-wake-up-call-for-the-gambling-industry-2496",{"id":222,"body":223,"status":6,"type":9,"date":224,"slug":225,"title":226,"image":227,"countries":228,"topic":229,"activity":236,"tags":237,"nid":242,"topics":243,"activities":245,"authors":246,"images":248,"websites":249,"area":19,"programme":19,"language":19,"translations":250,"translation_of":19,"user_created":27,"date_created":251,"user_updated":100,"date_updated":252,"content":253,"link":254},9750,"The agility that we pride ourselves on at the Basel Institute is often tested, not least by political turbulence in our partner countries. Beyond its implications for society and its catastrophic impact on victims and health systems, the coronavirus pandemic is the biggest test for us so far.\n\nWe know we are anything but alone in this, and – as with corruption – it is clear we can only come out of this in a good way if we share our experiences and help each other. In this spirit, we wanted to give you a sense of how we are adapting in these early days, with the generous support of our partners and donors, and our feelings for the future.\n\n### Life under lockdown\n\nOur first priority is to ensure the safety of our people – our staff and their families and our colleagues in partner organisations. Our offices are closed and all travel has stopped. Some of our field staff have chosen to remain in-country, while others have been repatriated.\n\nSecond, like others, we are adapting to life under lockdown. There are definite challenges to teleworking in terms of psychological impact and productivity, particularly for those of us with children home from school. But like others, we are finding that video meetings work fairly well and, combined with our regular virtual morning coffee breaks, allow for a degree of human interaction. It is fair to say that we are using means of communication involving seeing each other more frequently than in the past, when we would mostly talk on the phone or write emails. Because we bumped into each other in the coffee room, in the hallway or during in-country trips.\n\nNot attending meetings and conferences is difficult in a line of work where, because we often discuss highly sensitive matters which require trust, face-to-face contacts and relationships are important. And despite the current buzz about virtual training, it doesn’t match the buzz of students [learning about corruption research](https:\u002F\u002Fwww.baselgovernance.org\u002Fpublic-governance\u002Ftraining-courses) with our Head of Governance Research Claudia Baez Camargo, or of trainees working together on a [simulated money laundering case](http:\u002F\u002Fwww.baselgovernance.org\u002Fasset-recovery\u002Ftraining-programmes) during a workshop led by ICAR’s Head of Training Phyllis Atkinson and her training team.\n\nNotwithstanding, and without planning to do away with in-person trainings at all, increasing our virtual training capabilities has advantages. More anti-corruption practitioners can benefit from our capacity-building programmes, and at more flexible times. In fact, our Public Finance Management experts in Peru have already proven this: they launched the latest in a series of [virtual courses for public officials](https:\u002F\u002Fwww.baselgovernance.org\u002Fnews\u002Fvirtual-training-course-public-financial-management-launched-peru) just this week, with 800 new trainees joining the thousands who have benefited from these in the past. In addition, we have already seen a nearly 300 percent increase in activity on our [eLearning courses](https:\u002F\u002Fwww.baselgovernance.org\u002Felearning-courses) and similarly increased demand for our [Basel AML Index](https:\u002F\u002Fwww.baselgovernance.org\u002Fbasel-aml-index) and [Basel Open Intelligence](https:\u002F\u002Fwww.baselgovernance.org\u002Fbasel-open-intelligence) tools.\n\nFinally, less work-related travel helps many of us to clear our heads and to-do lists, not to mention stay healthier. And we have all seen the charts showing the wider environmental benefits of taking cars off the streets and planes out of the skies.\n\nWhatever happens, we have learnt some valuable additional skills and ways of working to take forward into the future.\n\n### Remote working in low-tech contexts\n\nIn many of our partner countries in Africa, Asia and Latin America, digital systems – never mind remote working methods – are not widely available or used. This affects our [International Centre for Asset Recovery](https:\u002F\u002Fwww.baselgovernance.org\u002Fasset-recovery) experts the most, as it makes case mentoring and training a challenge to say the least.\n\n*   Files are often on paper, stored manually and shared in person.\n*   Computers and video conferencing equipment are insufficient or in some cases non-existent.\n*   Electricity and internet connections are unreliable and expensive or, for many staff who have returned to their homes in rural villages, simply unavailable. \n*   Our partners are often not used to communicating virtually. Many government staff in our partner countries don’t use professional email addresses, and computer skills are sometimes weak.\n*   In these contexts, personal contact is even more vital to maintain progress on cases.\n\nBut necessity is the mother of invention and, as one of our field experts points out, patience is her sister. The ICAR team are helping each other find creative ways to continue case assistance and mentoring, from photos of documents and drafts transmitted through secure file-sharing systems to – for relationship-building – social media. They are also finding more time to focus on preparing the institutionalisation of good practices through SOPs and manuals, building on insights from in-country practice for global policy recommendations, and helping partners introduce new technologies more efficiently and securely.\n\nThe crisis is revealing the value of our model of embedding asset recovery experts in partner institutions. Many are still in-country, and the trust built through this model will allow us to continue where we left it quickly as soon as restrictions are relaxed. And as we hope everyone is experiencing, relationships grow stronger when we face a crisis together.\n\n### Digital security challenges\n\nRemote working raises numerous security challenges. Many of these are not new to our IT team because the nature of our work has always required that we pay great attention to this. Still, it’s a good time to review questions like:\n\n*   How do we control remote access to case files and other data internally and with partners?\n*   How do we ensure the security of messages transmitted over email or instant messaging platforms, if that’s what’s commonly in use in our partner countries?\n*   The mixing of professional and personal communication and devices – is it ever OK to use a personal WhatsApp account for work-related information or to store confidential files on a personal phone?\n*   How secure are off-the-shelf video conferencing platforms and how can we use them in a safe way, in particular with respect to retaining control over data?\n*   How do we deal with the fact that criminals are also moving online, and protect ourselves and our partners from the risks of hacking, phishing and cyber fraud?\n\nOur IT team is working hard to find technical solutions in addition to our regular secure processes and communication systems. But security is about people, not just technology, so our emphasis is on pragmatic solutions that work for us and for our partners too.\n\n### Higher stakes for compliance and Collective Action\n\nPracticalities are less of an issue for our [Compliance](https:\u002F\u002Fwww.baselgovernance.org\u002Fcompliance) and [Collective Action](https:\u002F\u002Fwww.baselgovernance.org\u002Fcollective-action) team, as most companies and organisations are well set up with technology and remote collaboration.\n\nBut Gemma Aiolfi, Head of Compliance and Collective Action, says that dealing with a crisis can reveal weaknesses in systems when it comes to preventing corruption. These could come from weaker controls through remote working, the fast adaptation or bypassing of regular systems and procedures, or the postponement of vital compliance training.\n\nThere will be a shake-out in some industry sectors. Economic effects will likely increase competition for business as firms struggle for survival and employees strive to demonstrate their value in bringing in business. This could result in sacrificing resources that would have been allocated to the compliance function. In the worst of all scenarios it could also lead to companies reverting to old bad practices of trying to win contracts through unfair means.\n\nThe crisis is also an opportunity for companies to develop better preparedness for pandemics and other catastrophic risks. Considering [what this means for anti-corruption and corporate governance](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Fbroken-beamers-and-more-shining-light-business-continuity-plans-and-compliance) will be key. They should also consider engaging in Collective Action to supplement their individual compliance efforts more efficiently.\n\n### Pressures on public governance and health systems\n\nThe pressures caused by the pandemic and governments’ resulting measures are, as one colleague in Mozambique says, raising the stakes for all of us and teaching us to live with uncertainty.\n\nThat couldn’t be more true for health systems of countries in which corruption is widespread. Health systems are known to be particularly exposed to high-level corruption risks. In these times, it is even more vital that health services and equipment are provided fairly – not to those who bribe or attempt to profit from the emergency by hoarding equipment or diverting donations of monetary aid and equipment.\n\nWe hope that our [Public Governance](https:\u002F\u002Fwww.baselgovernance.org\u002Fpublic-governance) team’s pilot intervention targeting [social norms in Tanzania’s health system](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Fclaudia-baez-camargos-quick-guide-social-norms-and-corruption) will be able to go ahead, as research projects such as these are crucial to designing more effective anti-corruption interventions. And that Claudia Baez Camargo is right that the crisis, in provoking us all to [rethink governance](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Frethinking-governance-times-covid-19-pandemic), will teach us all the value of public goods.\n\n### A boost for anti-corruption action against illegal wildlife trade\n\nThe pandemic has attracted attention towards [illegal wildlife trad](https:\u002F\u002Fwww.baselgovernance.org\u002Fillegal-wildlife-trade)e, as it becomes clear that COVID-19 was a direct result of the illegal trade in live animals. The pandemic makes a powerful argument that addressing the world’s fourth-largest organised crime is not just about conservation or animals in a faraway land, but has direct implications on human health, security and the economy.\n\nWe welcome commitments by countries including China and Vietnam to crack down on the trade and consumption of wildlife, but caution that the crux is [how effectively these bans are enforced](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Fcoronavirus-wake-call-illegal-wildlife-trade). Key will be to tackle the corruption and financial crime that fuel the illegal trade by [bringing together](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Fcovid-19-how-anti-corruption-tools-and-industry-collaboration-can-help-us-win-fight-against) law enforcement with the companies and financial institutions most closely affected by the trade.\n\n### Adapting together in our connected world\n\nThese are just some initial thoughts, and we hope that our sharing of this experience is useful for others who face similar challenges. We will continue to work with our partners as they also try to stay on track with the vital work they are doing to fight corruption and financial crime, and to make the world a better place. Because if we have learned anything from this crisis, it is that we are all connected, for better and for worse.","2020-04-09","covid-19-what-does-business-continuity-look-like-at-the-basel-institute-1559","COVID-19: What does “business continuity” look like at the Basel Institute?","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fe3c4a15f-2ef1-419f-b8b6-a08cf985cbd6?width=1000&height=650&format=webp&quality=80",[],[87,230,231,232,233,234,235],"Collective Action","Private Sector","Green Corruption","Public Finance Management","Prevention"," Research and Innovation",[150],[238],{"tags_id":239},{"id":240,"name":241},1381,"Health",1559,[92,230,231,232,233,244],"Prevention Research and Innovation",[150],[247],1238,[],[97,230],[],"2022-05-26T22:55:09.000Z","2026-05-29T22:21:53.000Z",[],"\u002Fresources\u002Fnews\u002Fcovid-19-what-does-business-continuity-look-like-at-the-basel-institute-1559",{"id":256,"body":257,"status":6,"type":9,"date":258,"slug":259,"title":260,"image":261,"countries":262,"topic":263,"activity":264,"tags":265,"nid":266,"topics":267,"activities":268,"authors":269,"images":270,"websites":271,"area":19,"programme":19,"language":20,"translations":272,"translation_of":19,"user_created":27,"date_created":273,"user_updated":100,"date_updated":274,"content":275,"link":276},10538,"J. Edward “Ned” Conway became Executive Secretary of the [Wolfsberg Group](https:\u002F\u002Fwolfsberg-group.org\u002F) on 1 November 2024, succeeding Alan Ketley. With its 12 member banks, the Wolfsberg Group is a globally respected source of expertise on financial crime risk management, setting industry standards and building bridges between financial institutions and other stakeholders. The Basel Institute serves as Secretariat to the Group, which is now in its 25th year.\n\nIn this Q&A, Ned challenges us to consider how we can make the fight against financial crimes more effective. He also highlights the value that the Wolfsberg Group can provide to the financial services industry, policymakers and law enforcement, with its global reach and technical knowledge of the financial crime landscape and financial industry.\n\n### What drives your career in countering financial crime?\n\nYou can read my [bio here](https:\u002F\u002Fwolfsberg-group.org\u002Fnews\u002F77\u002F), but I can highlight a couple of things that motivate me.\n\nFirst, my experiences working for the US Department of Defence in Iraq, in a unit focused on analysing and disrupting the financing of terrorist groups and insurgent networks. Most of the old-school ideas and methods we were trying were just not working. That made us ask: What are we _ultimately_ trying to achieve by countering threat finance? What plan or strategy will get us there more effectively?\n\nAs financial crime evolves, it remains vital to keep questioning our goals and the effectiveness of the measures we are using to achieve them. It’s a fascinating, ever-changing field.\n\nSecond, I’m an analyst at heart and love digging into data, so finance is a natural field. But I also relish personal interactions and am fascinated by psychology and behaviour, especially decision-making.\n\nAfter leaving the Department of Defence I studied for a PhD in international relations. During my field work in Central Asia, I saw the real-life impacts of corruption and financial crime on ordinary people and businesses. It was clear that financial crime compliance and risk management are not only interesting fields in themselves. They are also a chance to put the structural pressures in place to incentivise good behaviour, to make it easier for those in power to “do the right thing” and for ordinary people to feel the benefits.\n\nAnd third, properly managing financial crime risks can also have a positive impact on the environment, another area of focus I have been passionate about from a young age. Take illegal logging, illegal mining and wildlife trafficking in places like the Amazon. If financial institutions and law enforcement can do more to disrupt the finances of the organised crime groups profiting from these crimes, the impact on their operations will be significant. That’s positive for biodiversity and for the climate, as well as for local people.\n\n### What drew you to the Wolfsberg Group?\n\nFirst and foremost, it’s the people. It’s exhilarating to work with a group of individuals who are highly knowledgeable about the technical side of countering financial crime and just as passionate about doing it as me.\n\nSo who are we exactly? Our members represent 12 global banks. When you consider their correspondent banking networks, the majority of the US dollar, euro and pound sterling financial system relies on our member banks to process transactions. And these 12 banks collectively have hundreds of millions of customers in their own right, from individuals to large corporations across the world.\n\nPrimary delegates to the Group are usually the heads of the banks’ financial crime compliance divisions, and the secondary delegates are their deputies. Other senior bank staff specialised in, for example, complex investigations, fraud, virtual assets or sanctions form subject-matter expert working groups.\n\nWe also engage with external stakeholders like law enforcement, financial intelligence units, regulators and supervisors, and civil society, depending on the topic.\n\nIt’s safe to say that all of us see the importance and value of our work and want to get it right. That’s vital to our reputation as a trusted source of technical expertise on financial crime risk management.\n\nI pay tribute to Alan Ketley, Tracy Paradise, Hans-Peter Bauer, John Cusack, and other previous secretaries, chairs and members for developing this committed group not just of financial institutions but of people.\n\n### What does the Group do?\n\nIn essence, we act as a bridge between financial institutions and the needs and goals of policymakers and law enforcement.\n\nOn the policy side, we can contribute to shaping more effective laws, regulatory guidance and measures against financial crime. For example, if the EU is thinking of developing new regulations on payment transparency, we can provide constructive feedback on proposed measures and drafts. We can also help regulators and supervisors to responsibly cut red tape and foresee the consequences of deregulation.\n\nOn the law enforcement side, we exchange on investigative techniques, trends and typologies in financial crime. This helps financial institutions to hone their financial crime risk management and reporting frameworks. It also helps law enforcement and FIUs to understand how they can use banks’ information and capabilities more effectively.\n\n### How does your work translate to practical guidance?\n\nWe provide [practical frameworks and guidance](https:\u002F\u002Fwolfsberg-group.org\u002Fresources?type=cbddq-fccq) for the financial services industry as a whole.\n\nA prime example is the [Correspondent Banking Due Diligence Questionnaire](https:\u002F\u002Fwolfsberg-group.org\u002Fnews\u002F36) or CBDDQ. This is an industry standard for conducting reasonable due diligence before agreeing correspondent banking relationships. We have translated the related Guidance, Glossary and FAQs into various languages to make it more accessible.\n\nOther examples include a recent [Statement on Monitoring for Suspicious Activity](https:\u002F\u002Fwolfsberg-group.org\u002Fnews\u002F69). That line of work essentially outlines the responsible framework for innovation in a highly regulated sector, applying artificial and machine learning to improve our ability to support law enforcement and meet supervisory expectations.\n\n### How does the Group work?\n\nOur approach is to build trust and provide constructive feedback based on our technical expertise and deep understanding of the global financial services industry.\n\nWe are a consensus-based group and we do what we say. When our member banks agree on a document, like a statement or a set of guidance, we collectively commit to doing what we recommend in the document. That’s a very powerful statement. And building, finding, and maintaining that consensus takes constant care and management.\n\nOne area I’m keen on advancing is how we can better move from strategic alignment – high-level agreement on financial crime goals and measures – to operational gains, i.e. more effective systems in practice.\n\nFor example, it’s easy to say we should use artificial intelligence to improve systems for monitoring and reporting suspicious activities to the authorities. In practice, doing so will need things like testing, validation, analysing results, explaining how algorithms are working… technical steps that don’t make headlines but that are essential to making progress and doing so responsibly.\n\nWe’ll be doing more workshops and face-to-face interactions to advance those technical steps. That will also help us to tease out areas where there are legitimate differences of opinion between parties, and we can then focus our efforts on addressing those concerns.\n\n### What are the Group’s priorities?\n\nThematically, we continue to take a deep look at:\n\n*   Suspicious activity monitoring. As an industry, we put a huge amount of resources into monitoring and reporting suspicious activities to the competent authorities. But it is broadly recognised that the system is not achieving the desired results.\n*   How we assess risk. This includes applying a risk-based approach to financial crime compliance to avoid detrimental impacts on the underbanked, including non-profit organisations, improving financial inclusion while simultaneously prioritising resources to address clear financial crime risk.\n*   Fraud, especially “confidence scams”, where victims are convinced they are investing in an opportunity or relationship that turns to be completely false.\n\nWe are also very interested in better ways to measure and assess the effectiveness of our financial crime compliance efforts in general. We work with key regulatory authorities in the US, UK EU and other countries and regions as regulation is reformed.\n\n### What bridges do you see with the Basel Institute’s work?\n\n[Like the Basel Institute](https:\u002F\u002Fbaselgovernance.org\u002Fabout), we are primarily focused on technical competence and building bridges between stakeholders, not advocacy in support of narrow interests.\n\nIn fact, the Wolfsberg Group is an early example of [Collective Action](https:\u002F\u002Fcollective-action.com\u002F) – bringing together different stakeholders in a sustained engagement to improve business integrity, or in our case, the management of financial crime risks. The Basel Institute has huge credibility in this space and contributed to the Group’s foundation 25 years ago.\n\nAnd beyond our alignment with the goals of the Basel Institute’s [asset recovery](https:\u002F\u002Fbaselgovernance.org\u002Fasset-recovery\u002F) and [Green Corruption](https:\u002F\u002Fbaselgovernance.org\u002Fgreen-corruption) workstreams, a clear point of interest is the [Basel AML Index](https:\u002F\u002Findex.baselgovernance.org\u002F). This tool for country-based financial crime risk assessments is a core aspect of any financial institution’s risk management process. Most banks use the Basel AML Index in their risk models.","2025-03-10","making-financial-crime-risk-management-work-for-all-insights-from-the-wolfsberg-group-2779","Making financial crime risk management work for all: Insights from the Wolfsberg Group","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Facf339c5-225b-42b7-bd8a-8a6ef363264f?width=1000&height=650&format=webp&quality=80",[],[59,230,231],[150],[],2779,[59,230,231],[150],[],[],[97,230],[],"2025-03-10T11:01:36.000Z","2026-04-27T21:01:58.000Z",[],"\u002Fresources\u002Fnews\u002Fmaking-financial-crime-risk-management-work-for-all-insights-from-the-wolfsberg-group-2779",{"id":278,"body":279,"status":6,"type":80,"date":280,"slug":281,"title":282,"image":283,"countries":284,"topic":285,"activity":286,"tags":291,"nid":292,"topics":293,"activities":294,"authors":295,"images":296,"websites":297,"area":19,"programme":19,"language":19,"translations":298,"translation_of":19,"user_created":27,"date_created":299,"user_updated":100,"date_updated":300,"content":301,"link":302},9688,"Basel Institute on Governance Managing Director Gretta Fenner moderated a discussion on _Finding stolen assets – the role of transparency and proactive measures in developed countries_ at the new Global Forum on Illicit Financial Flows and Sustainable Development series. Hosted by Germany and Norway, the event takes place over two days starting 2 September 2020.\n\nSpeakers from the World Bank \u002F UNODC Stolen Asset Recovery Initiative, Germany and Tunisia explored what needs to be done in countries that serve as transition or destination countries of stolen assets. How are these countries able to contribute more to global asset recovery efforts?\n\n### Key points\n\n1\\. Anti-money laundering and counter financing of terrorism (AML\u002FCFT) frameworks in financial centres around the world are still much too weak.\n\nThis is both in terms of effective enforcement and underlying regulations\u002Finstitutional set-ups. These weaknesses provide criminals with excellent “get-away cars” in the form of opportunities to launder, hide and re-invest their assets with little risk of being detected.\n\nIn order to enhance the capacity of law enforcement to better detect and trace stolen assets, it was recommended that domestic AML\u002FCFT regulations need to address the challenges arising from legal professional privilege on the one hand, and corporate secrecy on the other hand.\n\nThis is because both act as effective veils to financial crime. We are seeing some momentum regarding corporate secrecy around the establishment of beneficial ownership registries. However, the crux of the matter, namely how to verify whether the information in the registries is correct, is still not resolved. Lawyer groups are so far very successful in lobbying against any changes to their professional privileges.\n\n2\\. AML\u002FCFT regimes and investigation tools do not sufficiently take into account the fact that methods for detecting stolen assets vary depending on the role of a jurisdiction in the laundering process. \n\nOne such weakness identified during the panel was that so-called “destination jurisdictions”, i.e. where laundered assets are ultimately placed, do not always have or effectively use centralised registries for key placement opportunities, such as real estate or corporations. This relates to the above point on beneficial ownership. This weakness severely restricts the capacity for proactive investigation, which could provide key information for detecting and recovering stolen assets in requesting and requested states alike.\n\n3\\. Financial centres need to do more to proactively identify and investigate stolen assets located in their jurisdictions. \n\nThe discrepancy between assets that are stolen and assets that are found is far too large for it to be credible that such small amounts of assets are effectively found in major financial centres. This is true even if we deduct stolen assets that may have already been spent and re-invested.\n\nFinancial centres often do not prioritise international corruption and money laundering cases because they are considered too complex and time consuming. Meanwhile, prosecuting services in most countries are overwhelmed with work. It is therefore imperative that financial centres invest more in relevant law enforcement capacity. This needs to be coupled with strong messaging from the highest level of political leadership that tackling illicit financial flows is a top priority. In addition, law enforcement in financial centres would benefit from additional legal tools, such as the introduction of the reversal of the burden of proof for a specific set of crimes.\n\nMore resources will also lead to more responsiveness of financial centres in the context of international cooperation, which is still insufficient and far too slow to tackle a 21st-century crime. Challenges for requesting states to tackle complex international cases include:\n\n*   disparities between legal systems and legislative frameworks governing international cooperation;\n*   limited experience in tracing assets in most countries, even those with advanced enforcement systems;\n*   human rights thresholds for executing mutual legal assistance (MLA) requests and maintaining freeze orders.\n\nGreater efforts are also needed to further harmonise the legislative framework governing international cooperation. Requesting states are overwhelmed when having to deal with multiple jurisdictions in parallel. \n\n4\\. The management of restrained assets is a concern.\n\nParticipants suggested analysing whether development banks or centrally managed escrow accounts could be used to ensure that such assets are protected and well managed.\n\n### About the Global Forum on IFF and Sustainable Development\n\nToday’s event was the first in a new series hosted by the [German Federal Ministry for Economic Cooperation and Development](https:\u002F\u002Fwww.bmz.de\u002Fen\u002F) (BMZ) and the [Norwegian Ministry of Foreign Affairs](https:\u002F\u002Fwww.regjeringen.no\u002Fen\u002Fdep\u002Fud\u002Fid833\u002F) and organised by the [Deutsche Gesellschaft für Internationale Zusammenarbeit](https:\u002F\u002Fwww.giz.de\u002Fen\u002Fhtml\u002Findex.html) (GIZ).\n\nThe aim of the Forum is to establish dialogue across stakeholders, countries, regions and sectors on the following question: _How can measures and policies to combat illicit financial flows can have the greatest possible impact on the advancement of SDG 16.4 without adversely affecting other goals of the sustainable development agenda?_\n\n### Further reading\n\n*   See a description of a 2019-2022 programme on [Combating Illicit Financial Flows](https:\u002F\u002Fwww.giz.de\u002Fen\u002Fworldwide\u002F39748.html) commissioned by the BMZ and Norwegian Ministry of Foreign Affairs.\n*   View a study on [Stolen Asset Recovery Between Germany and Developing Countries](https:\u002F\u002Fcifar.eu\u002Fwp-content\u002Fuploads\u002F2019\u002F06\u002F1.-English-Report-2019-Asset-recovery-Germany.pdf) commissioned by BMZ and GIZ and published in 2019 by the Civil Forum for Asset Recovery (CiFAR).","2020-09-03","how-developed-countries-can-support-asset-recovery-for-sustainable-development-1841","How developed countries can support asset recovery for sustainable development ","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fbd1ee675-4772-4b18-9c07-1e4c164e636d?width=1000&height=650&format=webp&quality=80",[],[59,87],[287,288,289,290],"Events","Presentations","Partnerships","International cooperation",[],1841,[59,92],[287,288,289,290],[],[],[97],[],"2022-05-26T22:54:19.000Z","2026-05-29T22:21:49.000Z",[],"\u002Fresources\u002Fnews\u002Fhow-developed-countries-can-support-asset-recovery-for-sustainable-development-1841",{"left":304,"top":304,"width":305,"height":305,"rotate":304,"vFlip":306,"hFlip":306,"body":307},0,20,false,"\u003Cpath fill=\"currentColor\" fill-rule=\"evenodd\" d=\"M17 10a.75.75 0 0 1-.75.75H5.612l4.158 3.96a.75.75 0 1 1-1.04 1.08l-5.5-5.25a.75.75 0 0 1 0-1.08l5.5-5.25a.75.75 0 1 1 1.04 1.08L5.612 9.25H16.25A.75.75 0 0 1 17 10\" clip-rule=\"evenodd\"\u002F>",1780676521073]