Alternatives to the Current Plan A – Fighting FC & ML/TF/PF the FATF Way

Exploring alternative approaches to FATF's current AML/CTF strategy

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What are the alternatives to the current Plan A led by FATF? Should we stay calm and carry on as FATF continues with the 5th round of country evaluations looking for improvements in effectiveness to 2030? What if effectiveness remains underwhelming—what then? The following represent potential ideas to supplement and/or replace the current approach and are presented to reflect diverse opinion and bold thinking.

Here are 5 scenarios summarised in brief:

  1. Plan A – FATF led current approach.

  2. Plan A+ – FATF led approach plus mandate to lead on Fraud and Scams.

  3. Plan B – Pair back on “All Crimes” & Prioritise.

  4. Plan C – Consider Radical Measures.

  5. Plan D – Deregulate AML/CTF/CPF and replace with general failure to combat AML/CTF/CPF offences.

The GCFFC does not endorse or recommend any of these approaches but provides these for information and encourages and promotes informed discussion.

Key Priority:
A paper will be expected to be delivered for publication just prior to the GCFFC Annual Conference in September 2025.

more work groups

Threat Assessment and Priorities in Fighting FC & ML/TF/PF

Prioritizing major financial crimes for global attention. Establishes a ranking of key financial crimes based on harm, financial impact, and global relevance. The model is intended for use by governments and international organizations to align threat responses.

Threat Assessment and Priorities in Fighting FC & ML/TF/PF

Prioritizing major financial crimes for global attention. Establishes a ranking of key financial crimes based on harm, financial impact, and global relevance. The model is intended for use by governments and international organizations to align threat responses.

Threat Assessment and Priorities in Fighting FC & ML/TF/PF

Prioritizing major financial crimes for global attention. Establishes a ranking of key financial crimes based on harm, financial impact, and global relevance. The model is intended for use by governments and international organizations to align threat responses.

AML Country Risk Review

Designing an aspirational country risk model. Explores what a next-generation AML country risk model could look like, based on ideal data sets. Step one involves concept design; step two would address data availability and collection.

AML Country Risk Review

Designing an aspirational country risk model. Explores what a next-generation AML country risk model could look like, based on ideal data sets. Step one involves concept design; step two would address data availability and collection.

AML Country Risk Review

Designing an aspirational country risk model. Explores what a next-generation AML country risk model could look like, based on ideal data sets. Step one involves concept design; step two would address data availability and collection.

The History of Fighting Financial Crime – Including FATF

Historical analysis of FATF’s evolution and impact. A reflective study to derive lessons from the FATF’s formation and development. Will make recommendations on how to adapt its mission for modern threats and integrate SDG goals.

The History of Fighting Financial Crime – Including FATF

Historical analysis of FATF’s evolution and impact. A reflective study to derive lessons from the FATF’s formation and development. Will make recommendations on how to adapt its mission for modern threats and integrate SDG goals.

The History of Fighting Financial Crime – Including FATF

Historical analysis of FATF’s evolution and impact. A reflective study to derive lessons from the FATF’s formation and development. Will make recommendations on how to adapt its mission for modern threats and integrate SDG goals.

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