FATF ¦ 2022 Procedures for the FATF Fifth Round of AML/CFT/CPF Mutual Evaluations, Follow-Up and ICRG (updated June 2025)

FATF ¦ 2022 Procedures for the FATF Fifth Round of AML/CFT/CPF Mutual Evaluations, Follow-Up and ICRG (updated June 2025)

FATF Unveils Enhanced Procedures for Mutual Evaluations and Monitoring to Strengthen Global Fight Against Financial Crime

The Financial Action Task Force (FATF), an independent inter-governmental body, plays a critical role in safeguarding the global financial system from money laundering, terrorist financing, and the financing of proliferation of weapons of mass destruction. Its updated Procedures for Anti-Money Laundering, Countering the Financing of Terrorism, and Countering the Financing of Proliferation (AML/CFT/CPF) Mutual Evaluations, Follow-Up, and International Cooperation Review Group (ICRG) processes, last revised in June 2025, provide a comprehensive framework for assessing and monitoring countries’ compliance with FATF Standards. At the core of FATF’s work are mutual evaluations (MEs), which rigorously assess countries’ technical compliance with AML/CFT/CPF laws and regulations and the effectiveness of their systems in achieving defined outcomes. These evaluations involve a detailed review process where assessment teams, composed of legal, financial, and law enforcement experts from FATF members and other bodies, analyze the legal frameworks, institutional arrangements, and operational effectiveness. Countries undergoing evaluation are expected to provide full cooperation, including access to relevant information and stakeholders.

The evaluation process is carefully structured, starting with preparation well in advance of on-site visits which typically last between 13 and 16 working days. During these visits, assessors engage with government authorities, financial institutions, non-financial businesses, virtual asset service providers, and other relevant actors to verify compliance and effectiveness. Post-visit, draft reports — comprising the Mutual Evaluation Report (MER), Key Recommended Actions (KRA) Roadmap, and Executive Summary — are developed collaboratively between assessors and the evaluated country. These drafts undergo a rigorous quality and consistency review involving mutual evaluation reviewers to ensure objectivity and adherence to FATF standards before final adoption by the FATF Plenary.

Bastian Schwind-Wagner
Bastian Schwind-Wagner "The updated FATF Procedures establish a robust and dynamic system for evaluating global efforts against financial crimes related to money laundering and terrorist financing. Through comprehensive assessments, ongoing monitoring, peer collaboration, and public accountability measures, FATF strives to strengthen international financial integrity and discourage illicit activities worldwide."

Following adoption, countries enter structured follow-up phases that monitor their progress in addressing identified deficiencies. Regular follow-up involves self-assessment reports focusing on progress against KRAs and requests for technical compliance re-ratings where applicable. Enhanced follow-up applies to countries with significant compliance or effectiveness gaps and involves expert analysis and more intensive monitoring. For countries with fundamental systemic weaknesses, the ICRG provides a more direct peer review mechanism with tailored action plans, political commitment requirements, and public statements highlighting risks associated with these jurisdictions.

The procedures emphasize transparency, peer review principles, confidentiality, and timely adherence to reporting deadlines to maintain fairness and credibility. The FATF Secretariat facilitates coordination among countries, assessment teams, reviewers, and ICRG members throughout all stages. Additionally, the FATF collaborates with regional bodies (FSRBs), the International Monetary Fund (IMF), and the World Bank to align assessments and share information effectively.

To ensure continuous improvement and maintain high standards, the FATF employs mechanisms for post-adoption quality and consistency reviews that can halt publication if serious issues arise. Publication policies promote transparency by making reports publicly accessible with appropriate media outreach to communicate key findings clearly.

The information in this article is of a general nature and is provided for informational purposes only. If you need legal advice for your individual situation, you should seek the advice of a qualified attorney.
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  • FATF ¦ 2022 Procedures for the FATF AML/CFT/CPF Mutual Evaluations, Follow-Up, and ICRG ¦ Link
Bastian Schwind-Wagner
Bastian Schwind-Wagner Bastian is a recognized expert in anti-money laundering (AML), countering the financing of terrorism (CFT), compliance, data protection, risk management, and whistleblowing. He has worked for fund management companies for more than 24 years, where he has held senior positions in these areas.
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