Uniting gatekeepers against illicit financial flows

The Unifying Framework is a value‑based self‑regulatory framework for private sector intermediaries who are strategically positioned to prevent or interrupt illicit financial flows – collectively referred to as “gatekeepers”. The framework consists of five core practices and is intended to realize three fundamental principles within and across gatekeeping industries worldwide. The framework was designed by gatekeepers for gatekeepers, be they individuals, entities, or professional associations. It provides a mechanism for recognition, ownership, consensus building and collaboration within a diverse community of private sector professionals, from art advisers to bankers to real estate agents, among others. While no replacement for binding regulation, value‑centred self‑regulation is essential for the realization of true integrity, transparency and accountability – above and beyond compliance.

Part A of this document explains the scope and role of the gatekeeping universe, the need for and goals of the Unifying Framework, and a brief glimpse of the requisite next steps for gatekeepers and regulators alike. Part B outlines the five core practices of the Unifying Framework itself.

This cross‑sectoral, transnational approach to gatekeeper self‑regulation presents an exciting opportunity to stunt the flow of illicit funds worldwide. To realize this potential, all gatekeepers are invited to publicly endorse the Unifying Framework and to begin or continue to take concrete steps toward implementation of the framework’s five core practices. Professional associations are particularly well situated to propel these efforts by setting behavioural and ethical norms within their industries and by imposing self‑regulatory measures, even in the absence of government enforcement. Though the mechanics of implementation may differ, commensurate to the scale of each entity and the particularities of each industry, the recommended practices are broadly applicable.

We believe that the globalized nature of illicit financial flows demands a global response – across industries and borders. We hope that the Unifying Framework can spur further recognition of gatekeepers’ role in the movement and management of illicit funds, the broad scope of the gatekeeping universe, and, most importantly, the essentiality of (and the real possibilities for) cross‑sectoral, transnational collaboration.

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