[{"data":1,"prerenderedAt":317},["ShallowReactive",2],{"news-what-can-we-learn-from-recent-money-laundering-cases-992":3,"news-what-can-we-learn-from-recent-money-laundering-cases-992-similar":81,"i-heroicons:arrow-left-20-solid":312},[4],{"id":5,"status":6,"date_created":7,"date_updated":8,"title":9,"type":10,"body":11,"date":12,"topic":13,"slug":15,"activity":16,"nid":19,"topics":20,"activities":21,"programme":22,"area":22,"websites":23,"language":22,"image":25,"translation_of":22,"countries":38,"tags":39,"authors":60,"images":78,"translations":79,"content":80},9817,"published","2022-05-26T22:56:06.000Z","2025-12-08T23:00:53.000Z","What can we learn from recent money laundering cases?","Blog","During 2018 and 2019, the world has faced serious money laundering scandals involving reputable institutions. Surprisingly, abuses of financial systems were uncovered in countries that have low risk scores in the [Basel AML Index](http:\u002F\u002Findex.baselgovernance.org\u002F), like Estonia and Sweden.\n\nThese countries have correspondingly low risk scores in other indices that the Basel Institute uses to analyse the quality of anti-money laundering and counter financing of terrorism (AML\u002FCFT) frameworks and quantify corruption, financial transparency and standards, public transparency and accountability, and legal and political risks.\n\n### Are ML\u002FTF evaluation systems flawed?\n\nDoes this mean that systems for evaluating money laundering and terrorist financing (ML\u002FTF) risks – including the Basel AML Index – are fundamentally flawed or biased?\n\nNo. It does mean, however, that when using a risk assessment tool such as the Basel AML Index Expert Edition it is important to understand the [methodology](https:\u002F\u002Fwww.baselgovernance.org\u002Fbasel-aml-index\u002Fmethodology) behind the results, what it can and cannot [measure](https:\u002F\u002Fwww.baselgovernance.org\u002Fbasel-aml-index\u002Fwhat-does-basel-aml-index-measure), and which [indicators](https:\u002F\u002Fwww.baselgovernance.org\u002Fbasel-aml-index\u002Fmethodology\u002Findicators) it relies upon.\n\nThe Basel AML Index is a composite index based on 15 well-established indicators and is not anyone’s personal evaluation. If some overall scores and rankings look implausible – for example, because major money laundering scandals have occurred in supposedly low-risk countries – the key is to analyse both the indicators behind the scores and the reasons why these cases of money laundering occurred.\n\nTools are more powerful when users understand their limitations and not only their uses.\n\n### Red flags in addition to country risk\n\nTools are also more powerful when used in combination with other evidence-based tools and procedures.\n\nAn analysis of recent high-profile money laundering cases shows it is important for financial institutions and companies to check for the following red flags:\n\n*   Politically exposed persons (PEPs). Cases involving illicit money from Russia and former Soviet countries were largely connected to PEPs or powerful businesspeople with vested interests. According to [media](https:\u002F\u002Feuobserver.com\u002Fjustice\u002F144524) reports, for example, EUR 122 million were linked to Russian businessman Iskander Makhmudov. Viktor Yanukovych, the former Ukrainian President, funnelled a suspected bribe of EUR 3.7 million via Swedbank in 2011.\n*   Non-resident legal persons. It is [stated](https:\u002F\u002Fwww.moneylaunderingnews.com\u002F2018\u002F11\u002Fdanske-bank-money-laundering-scandal-the-tip-of-the-icebergs\u002F) that Russian and other non-Baltic customers accounted for a notably high percentage of Danske Bank’s Estonia business, through which over USD 200 billion are estimated to have been laundered between 2007 and 2015.\n*   Beneficial ownership and offshore jurisdictions. Shell companies are used to conceal the true nature of illicit transactions and the identities of those responsible. In the so-called [Russian Laundromat](https:\u002F\u002Fwww.occrp.org\u002Fen\u002Flaundromat\u002Fthe-russian-laundromat-exposed\u002F) scandal, to take one example of many, money entered the scheme via a set of shell companies in Russia that exist only on paper and whose ownership cannot be traced. \n*   Illicit trading. High-risk large transactions related to mis-invoicing and fictitious trade deals are a serious issue. Illicit trading schemes like fraudulent letters of credit, fake invoices, vessels re-routing to pick up illegal goods, and trading in non-existing goods were used frequently in the Russian Laundromat activity. These methods helped to mask movements of illicit money.\n*   Geographical proximity to high-risk countries. As financial crimes are global in nature and the issue of [exporting corruption](https:\u002F\u002Fwww.transparency.org\u002Fwhatwedo\u002Fpublication\u002Fexporting_corruption_2018) is now widely recognised, countries which have borders with high-risk neighbours are vulnerable to increased levels of risk. In the latest Laundromat schemes, Baltic countries served as a gateway for illicit funds from former Soviet countries to enter the Western banking system.\n\n### Measuring money laundering risks\n\nThe 8th edition of the [Basel AML Index](\u002Fnode\u002F229), an independent annual ranking that assesses the risk of money laundering and terrorist financing (ML\u002FTF) around the world, will be released on 19 August 2019.","2019-08-16",[14],"Anti-Money Laundering","what-can-we-learn-from-recent-money-laundering-cases-992",[17,18],"Basel AML Index","Insights",992,[14],[17,18],null,[24,17],"Main page",{"id":26,"storage":27,"filename_disk":28,"filename_download":29,"title":30,"type":31,"created_on":32,"modified_on":33,"charset":22,"filesize":34,"width":35,"height":36,"duration":22,"embed":22,"description":22,"location":22,"tags":22,"metadata":37,"focal_point_x":22,"focal_point_y":22,"tus_id":22,"tus_data":22,"uploaded_on":33},"515a9ba9-91a8-4417-a6e9-333901cd19d3","local","515a9ba9-91a8-4417-a6e9-333901cd19d3.webp","cash-currency-euro-164529.webp","Cash Currency Euro 164529","image\u002Fwebp","2025-12-08T23:00:50.000Z","2025-12-08T23:00:51.000Z",425496,2000,1316,{},[],[40],{"id":41,"news_id":42,"tags_id":57},5938,{"id":5,"status":6,"user_created":43,"date_created":7,"user_updated":44,"date_updated":8,"title":9,"type":10,"body":11,"image":26,"date":12,"topic":45,"slug":15,"activity":46,"nid":19,"topics":47,"activities":48,"programme":22,"area":22,"websites":49,"translation_of":22,"language":22,"countries":50,"tags":51,"authors":52,"images":54,"translations":55,"content":56},"03bebfd8-0b40-4a2a-820d-b9d9c13b9de6","b0662e2a-864d-4888-a1b7-4342b7570b30",[14],[17,18],[14],[17,18],[24,17],[],[41],[53],1261,[],[],[],{"id":58,"name":59},818,"Anti-money laundering",[61],{"id":53,"news_id":62,"authors_id":74},{"id":5,"status":6,"user_created":43,"date_created":7,"user_updated":44,"date_updated":8,"title":9,"type":10,"body":11,"image":26,"date":12,"topic":63,"slug":15,"activity":64,"nid":19,"topics":65,"activities":66,"programme":22,"area":22,"websites":67,"translation_of":22,"language":22,"countries":68,"tags":69,"authors":70,"images":71,"translations":72,"content":73},[14],[17,18],[14],[17,18],[24,17],[],[41],[53],[],[],[],{"id":75,"name":76,"position":22,"image":77},556,"Dr Kateryna Boguslavska","24433c58-4115-4c6c-b220-142b5a1b135b",[],[],[],[82,105,129,156,179,200,227,248,271,292],{"id":83,"body":84,"status":6,"type":10,"date":85,"slug":86,"title":87,"image":88,"countries":89,"topic":90,"activity":92,"tags":94,"nid":95,"topics":96,"activities":97,"authors":98,"images":99,"websites":22,"area":22,"programme":22,"language":100,"translations":101,"translation_of":22,"user_created":43,"date_created":102,"user_updated":22,"date_updated":22,"content":103,"link":104},10617,"As the use of virtual assets accelerates worldwide, so too does their appeal to criminal actors looking to move money faster, hide transactions more effectively and stay one step ahead of enforcement authorities.\n\nAnd it’s natural that when people discuss crypto-related crime, the focus is often on governments, regulators, law enforcement agencies and the private sector – crypto exchanges, financial institutions and blockchain intelligence firms.\n\nWhat about international organisations, non-profits, expert networks and professional associations – what role do they play behind the scenes? And how much impact can they really have when it comes to tackling illicit activity involving virtual assets?\n\nThese questions were at the centre of a [webinar](https:\u002F\u002Fbaselgovernance.org\u002FIOs_virtualassets) co-hosted by the Basel Institute on Governance and the Organization for Security and Co-operation in Europe (OSCE). The discussion brought together experts from the OSCE, the Basel Institute, the Financial Intelligence Unit of Moldova, the United Nations Office on Drugs and Crime (UNODC), and the Global Coalition to Fight Financial Crime.\n\nAcross the discussion, speakers kept circling around the same point: the crypto-crime field does not need more vague talk about cooperation or more one-off awareness workshops. It needs practical, sustained and operational forms of support that help investigators, prosecutors and financial intelligence units respond to increasingly sophisticated criminal activity.\n\n### Beyond awareness raising\n\nA recurring theme throughout the discussion was the gap between recognising the problem and building the capability to address it.\n\nSpeakers noted that crypto-related crime evolves faster than most institutions can adapt. Bots on the Telegram messaging app are now providing money-laundering-as-a-service, as one speaker noted by way of example. Criminal actors – and bots – exploit regulatory gaps, fragmented information-sharing systems and uneven levels of expertise across jurisdictions.\n\nAt the same time, many authorities are still in the early stages of developing operational capacity.\n\nThis is where international organisations and networks can play an important role. Not simply by producing guidance documents or organising workshops and conferences – which are necessary but not sufficient – but by helping countries build practical and lasting capabilities.\n\nThe OSCE shared examples from its regional [project on mitigating the money laundering risks of virtual assets](https:\u002F\u002Fbaselgovernance.org\u002FIOs_virtualassets), which supports participating states across Eastern Europe, the South Caucasus, Central Asia and Mongolia.\n\nOne example was Moldova’s sectoral national risk assessment on virtual assets. Beyond identifying vulnerabilities, the process helped prompt institutional action and legislative development.\n\nThe OSCE also pointed to measurable operational outcomes linked to its capacity-building support. Institutions supported through the programme, for example, traced more than USD 100 million in illicit crypto assets in 2025 alone.\n\n### Why PowerPoint presentations are not enough\n\nSeveral speakers emphasised that complex investigations involving virtual assets and asset recovery require highly specialised expertise that cannot be built through isolated workshops.\n\nInvestigators need opportunities to apply knowledge in real cases. Financial intelligence units need ongoing mentoring and technical support. Prosecutors need to understand not only the technology itself but also how to present complex digital evidence in court.\n\nThe Basel Institute highlighted the importance of long-term engagement with practitioners. The approach of its [International Centre for Asset Recovery (ICAR)](https:\u002F\u002Fbaselgovernance.org\u002Fasset-recovery) includes combining case-centered training with hands-on mentoring, operational support on live cases and efforts to foster collaboration between different government agencies and with the private sector.\n\nTogether with highly effective train-the-trainer programmes, the focus is on helping agencies develop capabilities that can evolve alongside changing technologies and criminal methods, rather than delivering isolated workshops.\n\n### Networks that make cooperation operational\n\nThe webinar also challenged the tendency to talk about “international cooperation” in abstract terms. In practice, it’s difficult to develop trusting relationships between individuals and institutions operating in very different legal and cultural contexts, especially where there are language barriers.\n\nIn this environment, organisations such as the OSCE, Basel Institute, UNODC and the Global Coalition to Fight Financial Crime can act as connectors between sectors, jurisdictions and professional communities. They can:\n\n*   help investigators and practitioners exchange expertise and emerging typologies;\n*   create trusted channels for faster information sharing;\n*   connect authorities facing similar challenges across jurisdictions;\n*   support the development of common standards and approaches; and\n*   bridge gaps between public authorities, financial institutions and technical experts\n\nOne example is the Global Coalition’s proposal to develop a framework for sharing illict crypto wallet attribution data between public authorities – a major need, especially for jurisdictions without the resources to purchase multiple blockchain intelligence tools.\n\n### Research and analysis as a basis for action\n\nAnother important thread running through the webinar was the role of research and evidence-based analysis.\n\nAs technologies and criminal typologies evolve rapidly, policymakers and practitioners need reliable analysis rather than hype or speculation. Speakers discussed how international organisations support countries by analysing emerging threats, identifying trends and helping governments design informed legal and operational responses.\n\nSpeakers highlighted several concrete projects, such as UNODC research into [scam compounds](https:\u002F\u002Ftrack.unodc.org\u002Ftrack\u002Fen\u002Ftrack\u002Fresourcehub\u002F2025\u002Finflection_point_global_implications_of_scam_centres_underground_banking_and_illicit_online_marketplaces_in_southeast_asia.html) and cyber-enabled fraud in Southeast Asia and into the links between [cybercrime and corruption](https:\u002F\u002Ftrack.unodc.org\u002Ftrack\u002Fen\u002Ftrack\u002Fresourcehub\u002F2025\u002Fthe_nexus_between_cybercrime_and_corruption.html), and the Global Coalition’s research on links between gaming and crypto-related financial crime.\n\n### A rapidly evolving challenge\n\nThe webinar closed with a discussion on what aspects of collaboration participants would most like to strengthen in the virtual assets space.\n\nWhile perspectives differed, there was broad agreement that current models of cooperation and capacity building are still not moving fast enough to match the pace of technological change and criminal innovation.\n\nIt’s been said many times, but it warrants saying again: As virtual assets continue to evolve at breakneck speed, so too must the international response.\n\nThe discussion demonstrated that international organisations, non-profits and professional networks can have significant impact – particularly when they focus less on rhetoric and more on operational support, sustained partnerships and measurable outcomes.\n\n### Speakers\n\nWith thanks to our moderator, Vera Strobachova-Budway, Head of the Economic Governance Unit, OSCE, and to our excellent speakers:\n\n*   Erlin Agich, Associate Anti-Corruption Officer, OSCE\n*   Valentin Draganel, Deputy Head, Financial Intelligence Unit Moldova\n*   Alexandru Donciu, Specialist, Financial Investigations – Virtual Assets, Basel Institute on Governance\n*   Fabrizio Fioroni, AML\u002FCFT Advisor, United Nations Office on Drugs and Crime (UNODC)\n*   Michal Gromek, Chair, Digital Assets Task Force, Global Coalition to Fight Financial Crime\n\n### Learn more\n\n*   View the recordings: browse the [full playlist](https:\u002F\u002Fyoutube.com\u002Fplaylist?list=PLYRnhpCcnLP8mqlkcvhkC5kNXuX1M7ax4&si=HeEsEW6u_V9OnsCb) or go straight to individual interventions: [Vera Strobachova-Budway](https:\u002F\u002Fyoutu.be\u002FPyjFVx3Da1I), [Erlin Agich](https:\u002F\u002Fyoutu.be\u002FyxyKjh2qbc0), [Valentin Draganel](https:\u002F\u002Fyoutu.be\u002Ffn-P6Q1Q04Y), [Alexandru Donciu](https:\u002F\u002Fyoutu.be\u002Fi6AoR2bBGGk), [Fabrizio Fioroni](https:\u002F\u002Fyoutu.be\u002FJCET83V2nFk) and [Michal Gromek](https:\u002F\u002Fyoutu.be\u002Fb18ACqpIM64), plus the final [lightning round](https:\u002F\u002Fyoutu.be\u002Fu61VF8rxR5k).\n*   Sign up to the second joint Basel Institute-OSCE webinar on the role of [investigative journalists in tackling crime linked to virtual assets](https:\u002F\u002Fbaselgovernance.org\u002Fjournalism_virtualassets), on 2 June 2026.\n*   Read the OSCE’s [Decoding Crypto Crime – A Guide for Law Enforcement](https:\u002F\u002Foceea.osce.org\u002Foceea\u002F587475) in multiple languages.\n*   Learn more about the [OSCE Virtual Assets project](https:\u002F\u002Fprojects.osce.org\u002Fvirtualassets).\n*   Learn about the Global Coalition’s [Digital Asset Task Force](https:\u002F\u002Fwww.gcffc.org\u002Fsectors\u002Fdigital-asset-task-force-(datf)) and how you can get involved.\n\nThe Basel Institute’s training opportunities are now open to individuals – learn more about short online courses on [crypto and blockchain compliance](https:\u002F\u002Fbaselgovernance.org\u002Fcrypto-aml-training) and [financial investigations and asset recovery](https:\u002F\u002Fbaselgovernance.org\u002Fassetrecovery-openenrolment); plus [postgraduate courses on anti-corruption and asset recovery](https:\u002F\u002Fbaselgovernance.org\u002Fstudy).","2026-05-19","virtual-assets-real-world-crime-and-the-search-for-effective-responses-2967","Virtual assets, real-world crime and the search for effective responses","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fb16bddc0-613b-402f-baca-77cc9a835cd9?width=1000&height=650&format=webp&quality=80",[],[14,91],"Asset Recovery",[93],"Events",[],2967,[14,91],[93],[],[],"English",[],"2026-06-04T21:13:46.000Z",[],"\u002Fresources\u002Fnews\u002Fvirtual-assets-real-world-crime-and-the-search-for-effective-responses-2967",{"id":106,"body":107,"status":6,"type":10,"date":108,"slug":109,"title":110,"image":111,"countries":112,"topic":113,"activity":114,"tags":115,"nid":116,"topics":117,"activities":119,"authors":120,"images":122,"websites":22,"area":22,"programme":22,"language":100,"translations":123,"translation_of":22,"user_created":43,"date_created":124,"user_updated":125,"date_updated":126,"content":127,"link":128},10608,"_Criminal assets can cross borders in hours, while international asset recovery often struggles to keep pace. The INTERPOL Silver Notice is designed to close this gap by enabling earlier identification and tracing of criminal assets across jurisdictions. Can this new instrument fundamentally change how law enforcement responds to the rapid flight of illicit wealth?_\n\nCriminal funds can be moved across jurisdictions, layered through shell companies or converted into digital assets in a matter of hours. By contrast, international legal cooperation frequently moves at a far slower pace. The mismatch between the speed of asset flight and the pace of enforcement is one of the central reasons why several international bodies estimate that a very high proportion of [criminal assets](https:\u002F\u002Fwww.interpol.int\u002Fen\u002FNews-and-Events\u002FNews\u002F2025\u002FINTERPOL-publishes-first-Silver-Notice-targeting-criminal-assets#:~:text=Valdecy%20Urquiza%2C%20INTERPOL%20Secretary%20General,of%20criminal%20assets%20remain%20unrecovered.) ultimately remain unrecovered.\n\nINTERPOL’s Silver Notices seek to narrow this gap. They provide law enforcement with an early, structured mechanism to identify and trace assets across borders, strengthening one of the weakest stages of asset recovery: the initial [identification of criminal assets](https:\u002F\u002Fbaselgovernance.org\u002Fblog\u002Finterpols-silver-notice-paving-way-improved-asset-recovery). For practitioners dealing with fraud, corruption, money laundering and organised crime, Silver Notices reflect a shift toward treating asset recovery as an enforcement priority rather than merely a consequence of criminal conviction.\n\n### The state of play\n\nINTERPOL launched the Silver Notice as a pilot initiative in January 2025, involving 52 jurisdictions across all regions. [As of November 2025, 133 Silver Notices and 35 Diffusions had been published](https:\u002F\u002Fwww.interpol.int\u002FNews-and-Events\u002FNews\u002F2025\u002FTogether-Against-Crime-INTERPOL-General-Assembly-approves-blueprint-for-future) at the request of 39 countries, linked to suspected financial harm exceeding EUR 30 billion, according to INTERPOL.\n\nSwitzerland does not currently participate in the pilot and therefore does not issue Silver Notices. However, Swiss authorities may still receive Silver Notices and share information through existing police cooperation channels.\n\nIn November 2025, during the 93rd INTERPOL General Assembly in Marrakech, delegates approved the extension of the Silver Notice pilot, allowing additional jurisdictions to participate. For practitioners, this expansion matters: broader participation directly increases the likelihood that assets can be identified and preserved before they are moved beyond the reach of enforcement authorities.\n\n### What is the Silver Notice?\n\nINTERPOL Notices enable countries to share critical criminal intelligence and request operational assistance across borders. A Silver Notice is a non-coercive intelligence tool designed to support the identification and tracing of assets linked to serious criminal offences. It does not, by itself, authorise the freezing, seizure or confiscation of assets. Any such measures must be taken in accordance with national law and applicable judicial procedures.\n\nIn practice, Silver Notices may be used to:\n\n*   flag bank accounts, real estate, corporate holdings and digital assets;\n*   identify beneficial owners or persons exercising control over assets;\n*   enable secure and structured intelligence sharing between participating jurisdictions.\n\n### From identification to legal action\n\nOne of the most persistent challenges in cross-border asset recovery lies in the slow and often complex operation of Mutual Legal Assistance (MLA) mechanisms used to gather evidence or freeze assets. Evidentiary thresholds and procedural requirements vary widely across jurisdictions, and delays in cooperation can allow assets to be dissipated.\n\nWhen a Silver Notice leads to the identification of assets, the jurisdiction in which they are located informs the requesting country and INTERPOL, outlines domestic legal options, and acts within its legal framework. Early bilateral engagement allows investigators and prosecutors to align MLA requests with domestic standards, shortening the transition from intelligence to evidence and from tracing to freezing, helping preserve asset value and improving the prospects of confiscation and victim restitution or compensation.\n\n### Safeguards and limits\n\nBefore any Notice is circulated, it must pass a strict legal compliance review to ensure that it complies with INTERPOL’s Constitution, including the prohibition on matters of a political, military, racial or religious character. These safeguards are essential to maintaining trust between member countries and protecting the system from misuse, particularly in sensitive or high-profile cases.\n\nThe Silver Notice is also deliberately designed to avoid coercive overreach. Key safeguards include:\n\n*   restriction to serious criminal offences;\n*   a requirement for a clear factual link between the assets and suspected criminal conduct;\n*   use within the framework of national legal systems, including judicial or prosecutorial oversight where required.\n\nAt the same time, Silver Notices are not without limitations. For example, in politically sensitive cases, careful scrutiny is required to ensure that asset-tracing requests are not used to advance improper objectives. This makes the robustness and independence of INTERPOL’s compliance review mechanisms particularly important.\n\nUltimately, Silver Notices are not a solution to all asset recovery challenges. Their effectiveness depends on domestic legal framework and the willingness and ability of authorities to act on shared intelligence. They enhance international cooperation, but they do not replace the need for strong national asset recovery regimes or effective MLA processes.\n\n### Closing the enforcement gap\n\nThe speed at which criminal assets move across borders continues to outpace traditional enforcement tools. Silver Notices respond to this challenge by enabling earlier asset tracing and more timely operational engagement between jurisdictions.\n\nMore broadly, Silver Notices reflect an evolving approach to financial crime enforcement that prioritises proactive, intelligence-led intervention over reactive asset recovery at the end of lengthy criminal proceedings. Silver Notices are an enabler, not a shortcut. Used effectively and responsibly, they can strengthen the strategic focus on asset recovery and materially improve the prospects of asset confiscation and victim restitution.\n\n_This blog is also published on the [Hochschule Luzern Economic Crime Blog here](https:\u002F\u002Fhub.hslu.ch\u002Feconomiccrime\u002F?p=6536)._","2026-03-16","interpol-silver-notices-speeding-up-the-tracing-of-criminal-assets-2944","INTERPOL Silver Notices: Speeding up the tracing of criminal assets","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fdaf2f81c-8270-46aa-93a2-3a8a469a7420?width=1000&height=650&format=webp&quality=80",[],[14,91],[18],[],2944,[14,118],"Asset Recovery and Enforcement",[18],[121],1371,[],[],"2026-04-15T22:45:19.000Z","3d9ff205-1640-4f34-b5b6-86977f51bbd6","2026-05-29T22:22:40.000Z",[],"\u002Fresources\u002Fnews\u002Finterpol-silver-notices-speeding-up-the-tracing-of-criminal-assets-2944",{"id":130,"body":131,"status":6,"type":10,"date":132,"slug":133,"title":134,"image":135,"countries":136,"topic":137,"activity":138,"tags":139,"nid":146,"topics":147,"activities":148,"authors":149,"images":150,"websites":22,"area":22,"programme":22,"language":100,"translations":151,"translation_of":22,"user_created":43,"date_created":152,"user_updated":125,"date_updated":153,"content":154,"link":155},10602,"_By J. Edward (Ned) Conway, Executive Secretary, The Wolfsberg Group_\n\nAs virtual assets move into the mainstream of traditional finance, tricky questions arise. What does a reasonable, risk-based control framework look like for banks that provide services to virtual asset service providers (VASPs)? And how can compliance teams strengthen private-to-private information sharing to better detect suspicious activity?\n\nThese were some of the questions tackled by the [Wolfsberg Group](https:\u002F\u002Fwolfsberg-group.org\u002F) at the 9th Global Conference on Criminal Finances and Cryptoassets, organised by the Basel Institute on Governance, Europol and UNODC and held in Vienna on 28–29 October 2025.\n\nThe Wolfsberg Group is an association of 12 global banks that develops frameworks and guidance for the management of financial crime risks. Housed at the Basel Institute on Governance, this long-standing initiative brings together senior financial crime compliance leaders through various working groups, including one dedicated to virtual assets.\n\nThis flagship event provided a valuable platform for the Group to explain its [Stablecoin Guidance](https:\u002F\u002Fwolfsberg-group.org\u002Fresources\u002F204\u002F), gauge interest in a specific Due Diligence Questionnaire focused on VASPs, and further advance efforts to break down silos in private-to-private information sharing.\n\nThis blog summarises some of the key discussions – dialogues that are continuing in dedicated meetings and consultations of the Wolfsberg Group with members, regulators and institutional partners.\n\n### Regulatory clarity as a catalyst for TradFi–VASP relationships?\n\nDay 1 of the conference saw Ned Conway, Executive Secretary of the Wolfsberg Group, moderate a high-level panel discussion featuring representatives from Circle, Bullish and Société Générale on the theme _“Bridging the TradFi–DeFi Gap.”_\n\nThe panel discussed the barriers to relationship building between traditional finance (TradFi) institutions such as banks and VASPs such as cryptocurrency exchanges and stablecoin issuers. The speakers noted that a lack of trust and understanding persists, particularly around risks specific to virtual assets.\n\nThat is one reason that TradFi is slow to onboard VASPs as clients and provide them with the banking services they need in order to operate. However, stablecoins are helping bridge this gap by bringing parts of the crypto universe under regulatory frameworks.\n\nTradFi institutions underlined that they would benefit from clearer scenarios from regulators on where collaboration and information sharing would be permissible between regulated entities and VASPs. Recent [guidance issued by regulators on stablecoins and virtual assets in Asia](https:\u002F\u002Fwww.hkma.gov.hk\u002Fmedia\u002Feng\u002Fdoc\u002Fkey-functions\u002Fifc\u002Fstablecoin-issuers\u002FGuideline_on_supervision_of_licensed_stablecoin_issuers_eng.pdf), in particular, could help improve confidence both ways in the TradFi-VASP relationship.\n\n### Aligning risk appetite, due diligence and monitoring for suspicious activity\n\nOn Day 2, a dedicated Wolfsberg side event brought together VASPs, FinTech firms and traditional banks for in-depth discussions. Representatives from several Wolfsberg member banks – Deutsche Bank, Citi, UBS, Société Générale, and Bank of America – joined the sessions.\n\nThe agenda focused on frameworks for information sharing, but the discussions touched upon a range of hot topics including:\n\n*   risk appetite and the risk-based approach;\n*   payment transparency (i.e. the [travel rule](https:\u002F\u002Fwww.eba.europa.eu\u002Fpublications-and-media\u002Fpress-releases\u002Feba-issues-travel-rule-guidance-tackle-money-laundering-and-terrorist-financing-transfers-funds-and)); and\n*   approaches to monitoring for suspicious activity.\n\nDuring the discussions, participants highlighted that one of the main barriers to effective collaboration between traditional financial institutions and VASPs is a lack of mutual trust. Both sectors face difficulties in interacting with each other.\n\nThe [Wolfsberg Correspondent Banking Due Diligence Questionnaire](https:\u002F\u002Fwolfsberg-group.org\u002Fresources?type=cbddq-fccq&category=questionnaires) (CBDDQ) is useful for setting standards, but onboarding challenges could be overcome by framing risk in common language. Many viewed the current onboarding approaches as fragmented, and expressed strong support for the Wolfsberg Group to develop standardised guidance and a due diligence questionnaire for VASPs.\n\nQuestions remain about what is “reasonable” and “risk-based” for VASPs, especially for smaller institutions, and whether banks should monitor blockchain transactions themselves. VASPs need to be able to articulate their risk appetite, and how this changes as they continue to develop innovative products and services.\n\nVASP participants viewed the Wolfsberg Group’s [Stablecoin Guidance](https:\u002F\u002Fwolfsberg-group.org\u002Fresources\u002F204\u002F) as applicable beyond stablecoin issuers to the wider VASP ecosystem. This is particularly true for the tailored questions on the underlying control environment, and the linking of risk appetite directly to monitoring approaches.\n\n### Improving private-private information sharing on suspicious activity\n\nDiscussion on information sharing between TradFi and VASPs highlighted that this can rely heavily on personal relationships across entities, limiting scalability.\n\nVASPs showed concern around sharing wallet addresses under private-to-private information sharing frameworks, given geopolitical trends and concerns around the EU’s General Data Protection Regulation (GDPR). However, consensus emerged that better data sharing both increases the quality of suspicious activity reports (SARs) and reduces SAR volumes.\n\nParticularly on this latter point, activities often thought to be suspicious in a silo are better understood when viewed from multiple perspectives, confirming the importance of information exchange.\n\n### Continuing to build bridges as the financial system evolves\n\nBridging the gap between TradFi and DeFi remains a central theme in the Wolfsberg Group’s strategy. The Vienna events offered a unique opportunity to engage key stakeholders across the sector and advance this important dialogue.\n\nThe side event was opened by Elizabeth Andersen, Executive Director of the Basel Institute on Governance. The Wolfsberg Group extends its sincere thanks to the Basel Institute for the opportunity to co-host this side event and to participate in the 9th Global Conference on Criminal Finances and Cryptoassets.\n\n### Learn more\n\n*   Learn more about the [Wolfsberg Group](https:\u002F\u002Fwolfsberg-group.org\u002F) and explores its guidance and [resources](https:\u002F\u002Fwolfsberg-group.org\u002Fresources) on managing financial crime risk, including its [Stablecoin Guidance](https:\u002F\u002Fwolfsberg-group.org\u002Fresources\u002F204\u002F).\n*   Learn more about the [9th Global Conference](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Fglobal-experts-advance-joint-fight-against-crypto-enabled-crime) and see selected recordings.\n*   Find out about the [10th Global Conference on Criminal Finances and Cryptoassets](https:\u002F\u002Fbaselgovernance.org\u002F10crc) on 15–16 September 2026 in Luxembourg.","2026-02-11","advancing-trust-and-standards-between-banks-and-virtual-asset-service-providers-lessons-from-wolfsberg-group-events-at-the-9th-global-conference-2929","Advancing trust and standards between banks and virtual asset service providers – lessons from Wolfsberg Group events at the 9th Global Conference","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fc0f797c0-3af2-47b9-92aa-20efc3f95cce?width=1000&height=650&format=webp&quality=80",[],[14,91],[93],[140,144],{"tags_id":141},{"id":142,"name":143},854,"Virtual assets",{"tags_id":145},{"id":58,"name":59},2929,[14,118],[93],[],[],[],"2026-02-27T15:07:18.000Z","2026-05-29T22:22:39.000Z",[],"\u002Fresources\u002Fnews\u002Fadvancing-trust-and-standards-between-banks-and-virtual-asset-service-providers-lessons-from-wolfsberg-group-events-at-the-9th-global-conference-2929",{"id":157,"body":158,"status":6,"type":159,"date":160,"slug":161,"title":162,"image":163,"countries":164,"topic":166,"activity":167,"tags":169,"nid":170,"topics":171,"activities":172,"authors":173,"images":174,"websites":22,"area":22,"programme":22,"language":100,"translations":175,"translation_of":22,"user_created":43,"date_created":176,"user_updated":125,"date_updated":153,"content":177,"link":178},10603,"The fight against criminal misuse of cryptoassets enters its next chapter.\n\nJoin us on 15–16 September 2026 for the 10th Global Conference on Criminal Finances and Cryptoassets – held this year in Luxembourg at the European Convention Centre and online.\n\nThis landmark edition will be hosted by Luxembourg’s [Bureau de gestion des avoirs](https:\u002F\u002Fbga.gouvernement.lu\u002Ffr.html) (BGA), alongside the Basel Institute on Governance, Europol and UNODC as co-organisers.\n\nRenowned as a leading global forum, the conference brings together practitioners from across sectors and regions to tackle the evolving threats posed by criminal exploitation of cryptoassets and related services.\n\nExpect cutting-edge insights, candid exchanges and practical solutions aimed at safeguarding individuals, businesses and the integrity of financial systems worldwide.\n\n*   Day 1 – 15 September: Open to experts from all sectors, with a strong focus on public–private collaboration, emerging risks and real-world practice.\n*   Day 2 – 16 September: Reserved for public authorities, including law enforcement, prosecutors, financial intelligence units, asset management offices and regulators, with in-depth case studies and operational insights.\n\n### Learn more\n\n*   See more information on the official [10th Global Conference event page](https:\u002F\u002Fbaselgovernance.org\u002F10crc).\n*   Sign up to the [conference mailing list](http:\u002F\u002Feepurl.com\u002FiCwSMo) to be notified when registration opens.\n*   If you would like to submit a proposal to present, moderate a panel discussion or lead a breakout session, [please use this form](https:\u002F\u002Fforms.gle\u002FvXZjotdYgxbk1oRT6).","News","2026-02-10","save-the-date-10th-global-conference-on-criminal-finances-and-cryptoassets-2932","Save the date: 10th Global Conference on Criminal Finances and Cryptoassets","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F7048f59e-5619-4a67-a552-67d57cbf2cb5?width=1000&height=650&format=webp&quality=80",[165],7805,[14,91],[93,168],"Partnerships",[],2932,[14,118],[93,168],[],[],[],"2026-02-27T15:07:20.000Z",[],"\u002Fresources\u002Fnews\u002Fsave-the-date-10th-global-conference-on-criminal-finances-and-cryptoassets-2932",{"id":180,"body":181,"status":6,"type":10,"date":182,"slug":183,"title":184,"image":185,"countries":186,"topic":22,"activity":22,"tags":187,"nid":22,"topics":188,"activities":189,"authors":190,"images":191,"websites":192,"area":193,"programme":22,"language":100,"translations":195,"translation_of":22,"user_created":196,"date_created":197,"user_updated":22,"date_updated":22,"content":198,"link":199},10592,"\u003Cp>In a world that feels increasingly unsettled, with rising concerns over corruption, organised crime and illicit finance, it is encouraging to see that the Basel AML Index does not show global money laundering risks getting worse. The average score across all jurisdictions has even improved slightly – and in today’s climate even a modest hint of progress is worth noting.&nbsp;\u003C\u002Fp>\n\n\u003Cp>Still, we all know that global averages are hardly meaningful. What matters is what people experience in their own countries and regions, where threats like corruption, fraud, environmental crime and drug trafficking continue to evolve fast and affect their everyday lives.&nbsp;\u003C\u002Fp>\n\n\u003Cp>I have spent more than two decades working to strengthen governance and the rule of law around the world, and I have seen firsthand the power of data and evidence to drive change. With respect to complex topics such as corruption, money laundering and other financial crimes, this is no simple task. They are difficult to define, to quantify and to track over time. But unless we make a sincere effort to assess the risks, and acknowledge where the gaps and uncertainties lie, policymakers and practitioners are left working in the dark.&nbsp;\u003C\u002Fp>\n\n\u003Cp>This is the purpose of the Basel AML Index. It is not a simple score to be copy-pasted into a risk assessment or put out in a press release. It is a tool to explore what lies behind a jurisdiction’s risk profile. Many users rely on the headline Public Edition score, but there is much to be gained by looking deeper. The Expert Edition, free for the public sector, non-profits, academia and the media, and reasonably priced for private firms, gives an overview of all 17 indicators and supports more informed decisions.&nbsp;\u003C\u002Fp>\n\n\u003Cp>Look behind the curtain and you will see that the Basel AML Index recognises that tackling money laundering is not only about laws, regulations and enforcement. It also depends on independent political and legal systems, a free and active media and real accountability in the public sector. These elements are essential to a jurisdiction’s resilience to financial crime, so the Basel AML Index incorporates measures of these as well as other factors more commonly associated with financial crime.&nbsp;\u003C\u002Fp>\n\n\u003Cp>Measurement alone, however, is not enough; it is just the starting point for progress. That is why the Basel Institute works directly with partner countries to help them understand their risks and strengthen their resilience to money laundering and related financial crimes. We often undertake this work in the context of preparations for Financial Action Task Force (FATF) evaluations or ongoing efforts to leave the FATF grey list.\u003C\u002Fp>\n\n\u003Cp>Last month we welcomed Mozambique’s exit from the grey list after intensive work by our team and other partners to support improvements in the country’s anti-money laundering framework and asset recovery capacity. Similar assistance is underway with other partner countries, and we continue to engage with FATF-style regional bodies such as GAFILAT and ESAAMLG as an active observer member.&nbsp;\u003C\u002Fp>\n\n\u003Cp>If we can say one thing for sure about the future, it is that financial crime will continue to evolve at speed. But I remain hopeful, because progress in tackling it is possible when decisions are rooted in solid evidence. By shedding light on the underlying factors driving money laundering risks at the jurisdiction level, the Basel AML Index aims to help focus attention and resources where they matter most.&nbsp;\u003C\u002Fp>\n\n\u003Cp>\u003Ca href=\"https:\u002F\u002Findex.baselgovernance.org\u002F\">Explore the Basel AML Index\u003C\u002Fa>&nbsp;and \u003Ca href=\"https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fbasel-aml-index-2025\">download this year's report\u003C\u002Fa>.\u003C\u002Fp>\n","2025-12-11","elizabeth-andersen-foreword-to-the-basel-aml-index-report","Elizabeth Andersen: Foreword to the Basel AML Index report","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fed3f18dd-4ed7-474a-911d-3048d406faf7?width=1000&height=650&format=webp&quality=80",[],[],[14],[17],[],[],[17],[194],"Asset Recovery & Enforcement",[],"545a204d-e41b-4882-afda-481ecf3fd971","2025-12-11T09:55:09.000Z",[],"\u002Fresources\u002Fnews\u002Felizabeth-andersen-foreword-to-the-basel-aml-index-report",{"id":201,"body":202,"status":6,"type":10,"date":203,"slug":204,"title":205,"image":206,"countries":207,"topic":22,"activity":22,"tags":208,"nid":22,"topics":212,"activities":213,"authors":214,"images":216,"websites":217,"area":218,"programme":220,"language":100,"translations":222,"translation_of":22,"user_created":196,"date_created":223,"user_updated":44,"date_updated":224,"content":225,"link":226},10588,"\u003Cem>The following are key findings of the 14th Basel AML Index Public Edition &ndash; an independent, data-based ranking of money laundering and related financial crime risks worldwide.&nbsp;\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 &ndash; 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&ndash;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&rsquo;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&rsquo;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 &ndash; particularly in Africa &ndash; 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 &ndash; such as the use of virtual assets (see page 19) &ndash; 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 &ndash; Burkina Faso and C&ocirc;te d&rsquo;Ivoire &ndash; moved from the higher to the medium risk category.\n\n\u003Ctable>\n\u003Ctbody>\n\u003Ctr>\n\u003Ctd>\n\u003Cstrong>Top 10 improvers (score &darr;)&nbsp;\u003C\u002Fstrong>\n\u003C\u002Ftd>\n\u003Ctd>\n\u003Cstrong>Top 10 decliners (score &uarr;)&nbsp;\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, C&ocirc;te d&rsquo;Ivoire, \u003C\u002Fstrong>\u003Cstrong>Armenia, \u003C\u002Fstrong>\u003Cstrong>Philippines, \u003C\u002Fstrong>\u003Cstrong>Croatia&nbsp;\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&nbsp;\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 &ldquo;medium risk&rdquo; category and improves comparability between jurisdictions.\u003C\u002Fp>","2025-12-08","key-findings","Key findings of the Basel AML Index 2025","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F989a19a3-3c43-42e7-a7eb-b716058a6c3f?width=1000&height=650&format=webp&quality=80",[],[209],{"tags_id":210},{"id":211,"name":17},1346,[14],[17],[215],1363,[],[17],[194,219],"Business Integrity & Governance",[221],"International Centre for Asset Recovery",[],"2025-12-05T11:07:25.000Z","2026-06-03T21:58:45.000Z",[],"\u002Fresources\u002Fnews\u002Fkey-findings",{"id":228,"body":229,"status":6,"type":10,"date":203,"slug":230,"title":231,"image":232,"countries":233,"topic":22,"activity":22,"tags":234,"nid":22,"topics":235,"activities":236,"authors":237,"images":239,"websites":240,"area":241,"programme":242,"language":100,"translations":243,"translation_of":22,"user_created":196,"date_created":244,"user_updated":196,"date_updated":245,"content":246,"link":247},10589,"This feature appears in the 2025 Basel AML Index Public Edition report. \u003Ca href=\"https:\u002F\u002Findex.baselgovernance.org\u002Fdownloads\">Download the full report and related resources\u003C\u002Fa>.\n\n\u003Cblockquote>\n\u003Ch3>Key takeaways&nbsp;\u003C\u002Fh3>\n\n\u003Cul>\n\t\u003Cli>\u003Cstrong>A risk-based approach has long been at the core of efforts to mitigate risks of financial crimes \u003C\u002Fstrong>like money laundering and terrorist financing. But application of the approach has been uneven, often focusing too heavily on high-risk areas while paying too little attention to where risks are lower.&nbsp;\u003C\u002Fli>\n\t\u003Cli>\u003Cstrong>Global AML\u002FCFT standards now place stronger emphasis on applying the risk-based approach \u003C\u002Fstrong>\u003Cstrong>\u003Cem>proportionately\u003C\u002Fem>\u003C\u002Fstrong>, encouraging the use of simplified measures in lower-risk situations.&nbsp;\u003C\u002Fli>\n\t\u003Cli>\u003Cstrong>Many financial institutions and authorities find it difficult to assess or provide guidance on what constitutes lower risks \u003C\u002Fstrong>in specific contexts. This limits the use of simplified measures and adds to compliance burdens.&nbsp;\u003C\u002Fli>\n\t\u003Cli>\u003Cstrong>The Basel AML Index’s updated risk classification offers a more nuanced, data-driven way \u003C\u002Fstrong>to identify lower-risk jurisdictions and to support the application of a proportionate risk-based approach.&nbsp;\u003C\u002Fli>\n\u003C\u002Ful>\n\u003C\u002Fblockquote>\n\n\n### Proportionality: why clarity on lower-risk jurisdictions matters\n\nThe \u003Ca href=\"https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Ftopics\u002Ffatf-recommendations.html\">risk-based approach\u003C\u002Fa> has become the backbone of efforts to prevent money laundering, terrorist financing and related financial crimes. Its logic is straightforward: understand the different levels of risk, then apply stronger or lighter controls as appropriate.\n\nYet in many jurisdictions as well as in the private sector, the risk-based approach is not used as effectively as intended. Most attention is placed on identifying \u003Cem>high-risk \u003C\u002Fem>clients, products or jurisdictions – for example, through the FATF’s black and grey lists, international sanctions regimes or high-risk lists. By contrast, there has been much less discussion about what should count as \u003Cem>lower risk\u003C\u002Fem>.\n\nThis gap matters because lower-risk situations are where simplified measures should be used by financial institutions. If they are not, resources are not used efficiently and people or organisations can be unjustifiably \u003Ca href=\"https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Fpublications\u002FFinancialinclusionandnpoissues\u002Fguidance-financial-inclusion-aml-tf-measures.html\">excluded from accessing financial services\u003C\u002Fa>. Yet financial institutions often hesitate to use simplified measures out of fear that they may not be accepted by supervisors, which may not have clearly articulated their own risk tolerance.\n\nThe FATF, which sets global AML\u002FCFT standards, has recognised this imbalance and the unintended consequences. \u003Ca href=\"https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Fpublications\u002FFatfrecommendations\u002Fupdate-standards-promote-financial-conclusion-feb-2025.html\">Updates to its Recommendations\u003C\u002Fa> this year encourage jurisdictions not only to \u003Cem>consider \u003C\u002Fem>allowing simplified measures for lower-risk situations but to actually \u003Cem>allow and encourage \u003C\u002Fem>them.\n\nThe FATF has also shifted to using the word \u003Cem>proportionate \u003C\u002Fem>instead of \u003Cem>commensurate \u003C\u002Fem>to describe how controls should be applied. While this may sound like semantics, it does signal a stronger expectation that AML\u002FCFT measures should not be uniform or mechanistic, but carefully calibrated in a way that ensures effectiveness and reduces compliance burdens.\n\n### The missing piece: what exactly is “lower risk”?\n\nEven with this shift, many authorities and financial institutions find it difficult to decide what genuinely counts as lower risk. According to our review of several recent national risk assessments from different regions, and from discussions with public and private-sector experts, several factors contribute to this uncertainty:\n\n- \u003Cstrong>Lack of clear definitions\u003C\u002Fstrong>. The \u003Ca href=\"https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Ftopics\u002Ffatf-recommendations.html\">FATF distinguishes\u003C\u002Fa> between \u003Cem>low risk \u003C\u002Fem>or (where isolated exemptions from AML\u002FCFT measures may be possible) and \u003Cem>lower risk \u003C\u002Fem>(where simplified measures may be appropriate). Most national risk assessments do not draw this distinction.\n- \u003Cstrong>Different approaches\u003C\u002Fstrong>. Some jurisdictions use structured risk scales in their national risk assessments. \u003Ca href=\"https:\u002F\u002Famlcft.bnm.gov.my\u002Fpublications\">Malaysia’s\u003C\u002Fa> national risk assessment, for example, uses a four-band model: high, medium-high, medium and low. Others, such as that of the \u003Ca href=\"https:\u002F\u002Fhome.treasury.gov\u002Fnews\u002Fpress-releases\u002Fjy2080\">U.S.\u003C\u002Fa>, describe risks in narrative form without assigning categories.&nbsp;\n- \u003Cstrong>Unhelpful shortcuts\u003C\u002Fstrong>. Jurisdiction risk models sometimes rely mainly on sanctions lists or lists of offshore centres, which offer a limited picture of financial crime risk.\n\n### Why clearer lower-risk categories support better outcomes\n\nWhen lower-risk jurisdictions and other situations are clearly identified, the benefits are significant:\n\n- \u003Cstrong>Better resource allocation and reduced compliance burdens\u003C\u002Fstrong>. Staff and systems can be better directed towards higher-risk areas instead of being spread thinly.\n- \u003Cstrong>Improved quality of suspicious activity reports\u003C\u002Fstrong>. Financial intelligence units often complain of defensive reporting, i.e. reporting entities submitting large numbers of suspicious activity reports mainly to protect themselves from possible criticism, rather than because the activity is genuinely suspicious. Specifically allowing simplified measures in lower-risk situations would help to reduce this.\n- \u003Cstrong>Less de-risking\u003C\u002Fstrong>. When risk is assessed more accurately, financial institutions are less likely to withdraw services from whole countries or sectors based on broad assumptions.\n- \u003Cstrong>Public authorities \u003C\u002Fstrong>can also distinguish between jurisdictions or regions requiring intense scrutiny in terms of cross-border financial crime risks and those where less close attention is justified.\n\nTo achieve these outcomes, financial institutions need a clear internal framework and risk assessment methodologies, as well as reliable data sources, on which to base their decisions.\n\n### How the Basel AML Index’s updated classification helps\n\nThe \u003Ca href=\"https:\u002F\u002Findex.baselgovernance.org\u002Fexpert-edition\">Expert Edition\u003C\u002Fa> of the Basel AML Index has long provided an independent, data-driven assessment of money laundering and related financial crime risks across jurisdictions.\n\nPreviously it used three fixed risk bands: low, medium and high. This straightforward approach offers stability and simplicity, but may no longer capture the granularity needed by financial institutions and policymakers, especially where the rating drives due diligence or monitoring processes.\n\nFollowing our annual expert review meeting (see page 12), the Expert Edition will now use \u003Cstrong>Jenks natural breaks\u003C\u002Fstrong>, a statistical method that groups jurisdictions according to natural patterns in the data rather than fixed cut-off points. This results in the following categories:\n\n- \u003Cstrong>Lower risk\u003C\u002Fstrong>: &lt; 4.70\n- \u003Cstrong>Medium ris\u003C\u002Fstrong>k: 4.70–6.08\n- \u003Cstrong>Higher risk\u003C\u002Fstrong>: &gt; 6.08\n\n![](https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F9b974fd1-47e9-49f8-9d2c-9f2ec25bd99c)\n\nThe categories have also been renamed “lower”, “medium” and “higher” to emphasise that risk is relative. This new approach produces a clearer spread across categories and helps users see which jurisdictions fall meaningfully below the global risk pattern.\n\nThe purpose is not to label any jurisdiction as “safe” or “unsafe” but to offer a practical tool that supports geographic risk assessments and the application of proportionate measures. The Index’s underlying data remain available to subscribers. Users can then consider specific indicators relevant to their company’s risk appetite.\n","streamlining-the-risk-based-approach-to-anti-money-laundering-compliance","Streamlining the risk-based approach to anti-money laundering compliance","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fd0c794ab-f975-4521-9333-579c5d947048?width=1000&height=650&format=webp&quality=80",[],[],[14],[17],[238],1364,[],[17],[194],[221],[],"2025-12-05T11:16:34.000Z","2025-12-08T07:09:33.000Z",[],"\u002Fresources\u002Fnews\u002Fstreamlining-the-risk-based-approach-to-anti-money-laundering-compliance",{"id":249,"body":250,"status":6,"type":10,"date":203,"slug":251,"title":252,"image":253,"countries":254,"topic":22,"activity":22,"tags":255,"nid":22,"topics":256,"activities":259,"authors":261,"images":263,"websites":264,"area":265,"programme":266,"language":100,"translations":267,"translation_of":22,"user_created":196,"date_created":268,"user_updated":125,"date_updated":153,"content":269,"link":270},10590,"This feature appears in the 2025 Basel AML Index Public Edition report. \u003Ca href=\"https:\u002F\u002Findex.baselgovernance.org\u002Fdownloads\">Download the full report and related resources\u003C\u002Fa>.\n\n\u003Cblockquote>\n\u003Ch3>Key takeaways\u003C\u002Fh3>\n\n\u003Cp>\u003Cstrong>Understanding national risks linked to virtual assets is now essential\u003C\u002Fstrong>, as their use has moved from niche to mainstream and is increasingly exploited for financial crime.&nbsp;\u003C\u002Fp>\n\n\u003Cp>\u003Cstrong>Risk assessments are inherently challenging \u003C\u002Fstrong>as (a) virtual assets are borderless by design, (b) large parts of the ecosystem fall outside regulation and (c) reliable national-level data remains limited.&nbsp;\u003C\u002Fp>\n\n\u003Cp>\u003Cstrong>Illicit activity involving virtual assets does not take place in isolation\u003C\u002Fstrong>: offenders exploit the same weaknesses – corruption, fraud, weak supervision and poor enforcement – that already undermine the wider financial system.&nbsp;\u003C\u002Fp>\n\n\u003Cp>\u003Cstrong>The Basel AML Index provides valuable indicators to assess both a jurisdiction’s structural vulnerabilities and its capacity to counter threats \u003C\u002Fstrong>related to financial crimes in general, including those related to virtual assets, even though it does not include a dedicated virtual assets risk indicator.&nbsp;\u003C\u002Fp>\n\u003C\u002Fblockquote>\n\n\u003Cem>Note: in this article we use the term virtual assets in line with the FATF’s \u003Ca href=\"https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Ftopics\u002Fvirtual-assets.html\">definition\u003C\u002Fa> of “any digital representation of value that can be digitally traded, transferred or used for payment”. The terms crypto, cryptoassets, digital assets, digital currencies, etc. form part of this loose family, though they are often defined differently in different contexts – a factor that also complicates risk assessments and data analysis.\u003C\u002Fem>\n\n\u003Ch3>\u003Cstrong>Why assessing risks related to virtual assets matters&nbsp;\u003C\u002Fstrong>\u003C\u002Fh3>\n\nGovernments and private firms alike are under growing pressure to understand the risks associated with virtual assets. What was once a niche is becoming a mainstream part of financial markets and a common feature in all forms of financial crime.\n\nAs the virtual assets industry continues to mature, national authorities that lack a clear understanding of the risks find themselves on the back foot when drafting legislation, supervising market participants or countering financial crime.\n\nFor financial institutions, a clear picture of jurisdiction-level risk is essential for customer due diligence, transaction monitoring, calibrating controls and taking strategic decisions about where or where not to operate. Financial institutions that misjudge these risks leave themselves exposed to illicit finance, reputational harm and potential regulatory action.\n\n\u003Ch3>Why jurisdiction-level risk assessments are difficult\u003C\u002Fh3>\n\n\u003Ch4>1. A borderless system by design\u003C\u002Fh4>\n\nUnlike bank accounts or trust funds, virtual asset wallets or addresses do not have a meaningful jurisdictional location. There is no crypto equivalent of “a bank account in Switzerland”. A wallet can be accessed anywhere and may be controlled by a person or entity whose location is unknown or easily obscured. Large parts of the virtual asset ecosystem also fall outside the boundaries of traditional financial regulation. Self-hosted wallets, peer-to-peer transfers, decentralised finance (DeFi) protocols and informal over-the-counter (OTC) brokers create pockets of activity that are largely invisible. Any jurisdiction-level assessment will inevitably be incomplete.\n\nThe activities of virtual asset service providers (VASPs) further complicate matters. A VASP may be established in one jurisdiction while primarily serving customers in another. In the absence of harmonised legislation or cooperation among supervisors, many operate across numerous markets with minimal physical presence or regulatory engagement.\n\n\u003Ch4>2. Data is limited, patchy and uncertain\u003C\u002Fh4>\n\nReliable quantitative data on financial crime risks related to virtual assets at the national level is scarce. In addition to the issue of contrasting definitions and the technology’s borderless nature, several factors contribute to this lack.\n\nFirst, commercial blockchain analytics providers publish broad indicators of virtual asset adoption and estimates of illicit usage. These can be helpful for spotting trends but require careful interpretation. They rely on estimates and proxies, including web traffic to exchanges or intermediaries, and do not provide precise amounts or reliably distinguish licit from illicit activity.\n\nSecond, it is reasonable to assume that where adoption rises, illicit activity will also increase, simply because criminals use the same infrastructure as legitimate users. However, such relationships cannot be measured with confidence.\n\nThird, at the government level, many jurisdictions still lack a coordinated approach across authorities to collect, share and analyse statistics on money laundering and related financial crimes. In many jurisdictions, data on virtual assets is either not gathered consistently or not collected at all.\n\nWithout reliable data on virtual assets usage and risks, national risk assessments may become detached from real-world threats. The result: regulation and supervision that is either insufficient or unnecessarily burdensome.\n\n### How the Basel AML Index can be used\n\nFor the above reasons, the Basel AML Index does not offer a dedicated indicator for virtual assets. Nevertheless, the Index data is still useful because illicit activity involving virtual assets typically exploits the same underlying weaknesses that enable money laundering, corruption, fraud and other financial crimes in the traditional financial system. Where protections against fraud are weak, for example, where supervision is lacking or where enforcement of regulations is inconsistent or politically compromised, opportunities to misuse virtual assets for illegal purposes tend to expand.\n\n\u003Cblockquote>\n\u003Cstrong>Two components of risk&nbsp;\u003C\u002Fstrong>\n\nIn line with the holistic methodology of the Basel AML Index and most AML\u002FCFT risk assessment frameworks, evaluating jurisdiction-level risk related to virtual assets centres on two elements:\n\n\u003Cp>a) \u003Cem>vulnerability \u003C\u002Fem>to the illicit use of virtual assets; and b) \u003Cem>capacity to mitigate \u003C\u002Fem>and respond to these threats.&nbsp;\u003C\u002Fp>\n\u003C\u002Fblockquote>\n\n### Relevant indicators\n\nThe following graphic highlights indicators of the Basel AML Index that are relevant for assessing either \u003Cem>structural vulnerabilities \u003C\u002Fem>that illicit actors may exploit, or a jurisdiction’s \u003Cem>capacity to counter \u003C\u002Fem>threats. These can be viewed individually in the Expert Edition.\n\n![](https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F7f446525-136f-4018-a322-8a4e8872f23b) *Indicators visible in the Basel AML Index Edition that are particularly relevant to assessing national risks relating to virtual assets.*\n\n\n#### FATF data\n\nUsing the Expert Edition Plus subscription and its quantitative analysis of the latest FATF mutual evaluation and follow-up reports, Basel AML Index users can gain rapid insights into whether a jurisdiction’s AML\u002FCFT framework provides it with the capacity to \u003Cem>counter threats \u003C\u002Fem>related to financial crimes generally, including those involving virtual assets. FATF Recommendations that may be highly relevant for this include:\n\n- R.15 (new technologies)\n- R.16 (payment transparency)\n- R.26 &amp; 27 (regulation and supervision)\n- R.29–31 (law enforcement)\n- R.36–40 (international cooperation)\n\nAn additional useful source of information for jurisdiction-level risk assessments is the FATF’s \u003Ca href=\"https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Fpublications\u002FFatfrecommendations\u002Ftargeted-update-virtual-assets-vasps-2025.html\">\u003Cem>2025 Targeted Update on Implementation of the FATF Standards on Virtual Assets and Virtual Asset Service Providers\u003C\u002Fem>\u003C\u002Fa>. This report summarises progress in implementing FATF Recommendation 15 by FATF members and additional jurisdictions with materially important global virtual asset activity. “Materially important” refers to the presence of large VASPs (accounting for more than 0.25 percent of global trading) and\u002For a large virtual asset user base.\n\n### Where to start\n\nFor jurisdictions at an early stage of assessing national risks related to virtual assets, the World Bank’s \u003Cem>\u003Ca href=\"https:\u002F\u002Fopenknowledge.worldbank.org\u002Fentities\u002Fpublication\u002Fbb5a7475-ac52-4697-afdc-5f618a550623\">AML\u002FCFT National Risk Assessment on Virtual Assets and Virtual Asset Service Providers: Guidance Manual\u003C\u002Fa> \u003C\u002Fem>(published in October 2025) is a strong starting point. It covers both threats and vulnerabilities, as well as the effectiveness of mitigation measures.\n\nAdditional useful resources include:\n- \u003Ca href=\"https:\u002F\u002Fbaselgovernance.org\u002F9crc-crypto-regulation\">\u003Cstrong>Practical recommendations from regulators and supervisors\u003C\u002Fstrong>\u003C\u002Fa>, developed at the 9th Global Conference on Criminal Finances and Cryptoassets, on understanding financial crime risks linked to virtual assets and designing effective regulatory and supervisory frameworks.\n- \u003Cstrong>Structured public–private partnerships\u003C\u002Fstrong>, such as the \u003Ca href=\"https:\u002F\u002Fefippp.eu\u002F\">Europol Financial Intelligence Sharing Public Private Partnership\u003C\u002Fa>, which offer opportunities to learn from peers and obtain early insights into emerging threats and financial crime typologies involving virtual assets.\n","assessing-national-risks-related-to-virtual-assets","Assessing national risks related to virtual assets","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F78f8a1ec-bf8d-469a-ab92-228e79ddd8f2?width=1000&height=650&format=webp&quality=80",[],[],[14,118,257,258],"Business Integrity Ethics and Compliance","Corruption Prevention and Public Governance",[17,260],"Research",[262],1365,[],[17],[194,219],[221],[],"2025-12-05T11:43:36.000Z",[],"\u002Fresources\u002Fnews\u002Fassessing-national-risks-related-to-virtual-assets",{"id":272,"body":273,"status":6,"type":159,"date":203,"slug":274,"title":275,"image":276,"countries":277,"topic":22,"activity":22,"tags":278,"nid":279,"topics":280,"activities":281,"authors":283,"images":284,"websites":285,"area":286,"programme":287,"language":100,"translations":288,"translation_of":22,"user_created":44,"date_created":289,"user_updated":125,"date_updated":153,"content":290,"link":291},10591,"**The 14th Public Edition of the [Basel AML Index](https:\u002F\u002Findex.baselgovernance.org) shows a world where money laundering risks are levelling out, with improvements in some high-risk countries balanced by declines in traditionally low-risk ones.**\n\nDeveloped and maintained by the Basel Institute on Governance since 2012, the Basel AML Index is an independent, data-based ranking and risk assessment tool for money laundering and related financial crime risks around the world.\n\nAt the heart of the Basel AML Index is a ranking of countries and jurisdictions according to their vulnerability to money laundering and related financial crimes and their capacity to counter these threats. This year, 177 countries are included in the Public Edition. Myanmar, Haiti and the Democratic Republic of the Congo receive the highest risk scores, while Finland, Iceland and San Marino have the lowest.\n\n## Key trends\nThis year’s Basel AML Index report highlights current trends and debates around the fight against financial crime, including:\n\n- **The global average Basel AML Index risk score nudged down slightly from 5.30 to 5.28.** The shift is statistically insignificant. However, it gives hope that efforts to curb money laundering are not yet being fully overtaken by emerging threats, such as the use of virtual assets and artificial intelligence for crime.\n- **More than half of jurisdictions improved their scores while 43 percent worsened.** The pattern points to a drift towards the middle, as progress in several higher-risk jurisdictions is offset by slippage among long-standing strong performers.\n- **Results across risk domains are mixed:** modest improvements in the quality of anti-money laundering frameworks and small reductions in corruption overall, but weaker financial transparency, rising concerns over public accountability and wide regional variation in political and legal risks.\n- **Regional trends diverge too.** North America, the EU and Western Europe, Eastern Europe and Central Asia, and the Middle East and North Africa all saw higher average risks. Other regions saw slight improvements, most notably Sub-Saharan Africa, with six African countries leaving the Financial Action Task Force grey list and seven among the top ten global improvers.\n\n## Emerging challenges\nThis year’s report includes two deep-dive features examining specific challenges facing anti-financial crime practitioners in both the public and private sectors:\n\n### *Identifying lower-risk jurisdictions*\n\nThough global standards increasingly call for more proportionate use of the risk-based approach to reduce compliance burdens and avoid unintended consequences for financial inclusion, many financial institutions still struggle to assess what constitutes a lower-risk jurisdiction.\n\nThe report explains why this remains difficult and how the Expert Edition of the Basel AML Index now applies a more balanced three-part risk categorisation to help users consider their own risk categories and risk appetite.\n\n### *Assessing risks related to virtual assets*\n\nAs crypto or virtual assets move from niche to mainstream, understanding their risks has become essential. Yet assessment remains difficult because the ecosystem is largely borderless, only partly regulated and supported by limited data.\n\nThe report emphasises that illicit activity involving virtual assets typically exploits the same weaknesses – such as corruption, fraud, weak supervision and poor enforcement – that already undermine the wider financial system. It outlines how users can assess structural vulnerabilities and a jurisdiction’s overall capacity to counter financial crime threats relevant to virtual assets, even without a dedicated virtual assets indicator.\n\n## Shining a light\nElizabeth Andersen, Executive Director of the Basel Institute on Governance, comments:\n\n> Tackling money laundering and related financial crimes – crimes like corruption, fraud, environmental crime and drug trafficking that have drastic impacts on people's lives – begins with understanding the risks. That is what the Basel AML Index is for. More than a simple score, it is a tool to explore the factors that underlie a jurisdiction’s risk profile. We hope it continues to guide policymakers and practitioners as they concentrate attention and resources where they can have the most impact.\n\n## About the Basel AML Index\nThe Basel AML Index is an independent, data-based ranking and risk assessment tool for money laundering and related financial crime risks around the world. It provides risk scores based on data from 17 publicly accessible sources. The risk scores cover five domains relevant to assessing risks of money laundering at the country or jurisdiction level:\n\n - Quality of AML\u002FCFT\u002FCPF framework\n- Corruption and fraud\n- Financial transparency and standards\n- Public transparency and accountability\n- Legal and political risks\n\nThe Basel AML Index is developed and maintained by the Basel Institute on Governance through its International Centre for Asset Recovery (ICAR). ICAR benefits from core funding from the Governments of Jersey, Liechtenstein, Norway, Switzerland and the UK.\n\n\u003Ch3>Learn more\u003C\u002Fh3>\n\n\u003Cul>\n\t\u003Cli>Visit the \u003Ca href=\"https:\u002F\u002Findex.baselgovernance.org\u002F\">Basel AML Index website\u003C\u002Fa>\u003C\u002Fli>\n\t\u003Cli>View the \u003Ca href=\"https:\u002F\u002Fwww.youtube.com\u002Fwatch?v=qUv7DEBYEO0\">launch event on YouTube\u003C\u002Fa> and \u003Ca href=\"https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2025-12\u002FTranscript%20of%20Basel%20AML%20Index%20launch%202025.pdf\">download the transcript\u003C\u002Fa>\u003C\u002Fli>\n\u003C\u002Ful>\n","basel-aml-index-2025-reveals-uneven-progress-global-fight-against-financial-crime","Basel AML Index 2025 reveals uneven progress in the global fight against financial crime","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F675491bf-33d4-4a28-adef-70539426660b?width=1000&height=650&format=webp&quality=80",[],[],2892,[14,118],[17,260,282,18],"Reports",[],[],[17,24],[194],[221],[],"2025-12-08T08:35:06.000Z",[],"\u002Fresources\u002Fnews\u002Fbasel-aml-index-2025-reveals-uneven-progress-global-fight-against-financial-crime",{"id":293,"body":294,"status":6,"type":10,"date":203,"slug":295,"title":296,"image":297,"countries":298,"topic":299,"activity":300,"tags":301,"nid":302,"topics":303,"activities":304,"authors":305,"images":307,"websites":22,"area":22,"programme":22,"language":100,"translations":308,"translation_of":22,"user_created":43,"date_created":309,"user_updated":43,"date_updated":309,"content":310,"link":311},10622,"In a world that feels increasingly unsettled, with rising concerns over corruption, organised crime and illicit finance, it is encouraging to see that the Basel AML Index does not show global money laundering risks getting worse. The average score across all jurisdictions has even improved slightly – and in today’s climate even a modest hint of progress is worth noting. \n\nStill, we all know that global averages are hardly meaningful. What matters is what people experience in their own countries and regions, where threats like corruption, fraud, environmental crime and drug trafficking continue to evolve fast and affect their everyday lives. \n\nI have spent more than two decades working to strengthen governance and the rule of law around the world, and I have seen firsthand the power of data and evidence to drive change. With respect to complex topics such as corruption, money laundering and other financial crimes, this is no simple task. They are difficult to define, to quantify and to track over time. But unless we make a sincere effort to assess the risks, and acknowledge where the gaps and uncertainties lie, policymakers and practitioners are left working in the dark. \n\nThis is the purpose of the Basel AML Index. It is not a simple score to be copy-pasted into a risk assessment or put out in a press release. It is a tool to explore what lies behind a jurisdiction’s risk profile. Many users rely on the headline Public Edition score, but there is much to be gained by looking deeper. The Expert Edition, free for the public sector, non-profits, academia and the media, and reasonably priced for private firms, gives an overview of all 17 indicators and supports more informed decisions. \n\nLook behind the curtain and you will see that the Basel AML Index recognises that tackling money laundering is not only about laws, regulations and enforcement. It also depends on independent political and legal systems, a free and active media and real accountability in the public sector. These elements are essential to a jurisdiction’s resilience to financial crime, so the Basel AML Index incorporates measures of these as well as other factors more commonly associated with financial crime. \n\nMeasurement alone, however, is not enough; it is just the starting point for progress. That is why the Basel Institute works directly with partner countries to help them understand their risks and strengthen their resilience to money laundering and related financial crimes. We often undertake this work in the context of preparations for Financial Action Task Force (FATF) evaluations or ongoing efforts to leave the FATF grey list.\n\nLast month we welcomed Mozambique’s exit from the grey list after intensive work by our team and other partners to support improvements in the country’s anti-money laundering framework and asset recovery capacity. Similar assistance is underway with other partner countries, and we continue to engage with FATF-style regional bodies such as GAFILAT and ESAAMLG as an active observer member. \n\nIf we can say one thing for sure about the future, it is that financial crime will continue to evolve at speed. But I remain hopeful, because progress in tackling it is possible when decisions are rooted in solid evidence. By shedding light on the underlying factors driving money laundering risks at the jurisdiction level, the Basel AML Index aims to help focus attention and resources where they matter most. \n\n[Explore the Basel AML Index](https:\u002F\u002Findex.baselgovernance.org\u002F) and [download this year's report](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fbasel-aml-index-2025).","foreword-to-the-basel-aml-index-2025-report-2898","Foreword to the Basel AML Index 2025 report","\u002Fpics\u002Fimg-placeholder.png",[],[14,91],[17],[],2898,[14,91],[17],[306],1377,[],[],"2026-06-04T21:13:51.000Z",[],"\u002Fresources\u002Fnews\u002Fforeword-to-the-basel-aml-index-2025-report-2898",{"left":313,"top":313,"width":314,"height":314,"rotate":313,"vFlip":315,"hFlip":315,"body":316},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>",1780676405016]