FATF ¦ Learning and Development Forum February 2026 - Meeting Insights

FATF ¦ Learning and Development Forum February 2026 - Meeting Insights

Risk-Based Supervision Must Focus on Effectiveness to Reduce Harm

The Financial Action Task Force Learning and Development Forum held in London on 25–26 February 2026 brought together more than 100 practitioners from supervisors, financial intelligence units, law enforcement, policy makers, and major international banks to tackle a central problem in the fight against financial crime: turning the risk-based approach from principle into effective practice. The meeting underscored that the next phase of global anti–money laundering and counter–terrorist financing (AML/CFT) work must shift emphasis from compliance checkboxes toward demonstrable effectiveness – allocating resources and supervisory attention to the highest risks to better protect communities and reduce victimisation.

Risk-based supervision – not just rhetoric

Participants agreed that the FATF’s continued focus on the risk-based approach is the right course, but noted that implementation needs to evolve. Over recent years jurisdictions refined law and policy, but outcomes have been mixed when it comes to actually deterring criminal actors and preventing harm. The Forum highlighted the need to move from asking whether rules are being followed to asking whether the highest risks are being addressed. This reframing requires supervisors, FIUs, LEAs and the private sector to adopt a shared view of national and cross-border priorities and to allocate effort accordingly. When resources are concentrated on high-value, high-impact activity, supervision becomes both more effective and less burdensome for legitimate customers.

Trust and continuous communication underpin proportionality

A recurring theme was that trust is foundational to effective risk-based supervision. Continuous, two-way communication between regulators and industry enables proportionality by building mutual understanding and confidence. Participants urged a cultural shift away from a “zero-failure” mindset that treats all conduct as equally unacceptable, and toward a pragmatic focus on those interventions that will most reduce risk and harm. Supervisors should prioritise measures with the greatest potential for preventing and detecting crime, and be ready to accept some managed risk where the trade-offs justify it.

Bastian Schwind-Wagner
Bastian Schwind-Wagner

"The global AML/CFT community must move from box-checking to measured action that targets the highest risks and delivers real reductions in harm. Clear national priorities, sustained dialogue between regulators and industry, and better use of public–private intelligence are essential to sharpen focus and allocate resources where they matter most.

Supervisors should adopt outcome-focused approaches that leverage technology and accept managed trade-offs to concentrate on impactful interventions. Recognising and encouraging innovative, evidence-based practices will help systems stay adaptive and protect legitimate customers while disrupting criminal networks."

Aligning national priorities to sharpen focus

Forum attendees emphasised that AML/CFT regimes work best when governments clearly set national priorities and supervisors align their oversight to those priorities. Clear national guidance gives financial institutions the confidence to reallocate resources toward high-risk activities and scale back low-value work. Several speakers noted the benefits of dynamic, ongoing risk assessment processes rather than static, cyclical reviews. In many jurisdictions the threat picture evolves quickly, and understanding that landscape requires continuous information-sharing and closer public–private collaboration.

Public–private partnerships as operational force multipliers

The Forum highlighted the value of public–private partnerships (PPPs) in surfacing operational intelligence that produces higher-quality reports to FIUs and LEAs. PPPs can increase the signal-to-noise ratio of disclosures, improving disruption of criminal networks and, in some jurisdictions, moving beyond detection toward prevention. Participants proposed that information and insights produced by PPPs be used proactively as risk management tools by both supervisors and firms, reinforcing a feedback loop that sharpens detection and reduces unnecessary reporting burdens.

Supervisory methods must evolve with technology and purpose

Supervisory techniques are changing as new technologies enable offsite monitoring, data analytics and more targeted examinations. The Forum encouraged a “function over form” mindset – focusing on outcomes rather than rigid processes – which would give supervisors confidence to adopt technology-driven approaches that concentrate effort on real risks. Embracing such tools can make supervision more sustainable, timely and relevant. Supervisors also have a role in incentivising the private sector to innovate responsibly, ensuring the benefits of new models are realised without undermining safeguards.

Roadmap for improving global implementation

The Forum will feed into a FATF roadmap to strengthen implementation of the risk-based approach and risk-based supervision.

Participants proposed several practical directions:

  • develop greater alignment across stakeholders on what a risk-based approach means in operational terms while respecting regional differences;
  • create regular exchanges to share lessons among supervisors, FIUs, LEAs and industry;
  • ensure FATF evaluations recognise forward-leaning and innovative approaches that deliver effectiveness; and
  • promote use of technology and information sharing mechanisms so public and private authorities can keep pace with evolving threats.

Conclusion

The Learning and Development Forum reinforced that the global AML/CFT community is ready to move from formal compliance to demonstrable effectiveness. Achieving that requires clearer national priorities, sustained trust and dialogue between supervisors and industry, smarter use of information through PPPs, and supervisory methods built around impact rather than process. If implemented, these changes will better concentrate scarce resources on the risks that matter most and reduce the harms caused by money laundering and terrorist financing – while lowering unnecessary burdens on legitimate customers.

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 lawyer.
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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.