FATF ¦ R.2 Na­ti­o­nal Co­o­pe­ra­tion and Co­or­di­na­tion

Recommendation 2: Strengthening National Cooperation and Coordination in AML/CFT/CPF

Effective national responses to money laundering, terrorist financing and the financing of proliferation require more than individual laws or isolated agency efforts. Recommendation 2 focuses on creating and maintaining national anti-money laundering, counter-financing of terrorism and counter-proliferation of weapons of mass destruction (AML/CFT/CPF) policies that are risk-informed, regularly reviewed and driven by clear leadership. Without a designated authority or an established coordination mechanism, gaps arise: intelligence does not reach investigators in time, supervisors miss emerging threats, and policy-makers lack a holistic view of national vulnerabilities. A structured inter-agency framework closes those gaps by aligning priorities, clarifying responsibilities, and enabling timely operational cooperation.

Designating leadership and building the framework

Countries should designate one or more authorities responsible for setting national AML/CFT/CPF policy and ensuring cooperation across agencies. That leadership can take the form of a single coordinating body or several specialized frameworks tailored to ML, TF and PF risks. The designated authority must have the mandate to convene relevant stakeholders, drive periodic reviews of risk assessments and policies, and monitor implementation across the whole national framework. Leadership is not merely symbolic: it must include authority to set priorities, resolve jurisdictional frictions, and ensure accountability for delivering operational outcomes.

Who belongs in the national architecture

A functioning national framework brings together the full range of competent authorities whose mandates intersect with financial crime risks. Typical participants include central government departments (finance, trade, justice, home affairs, foreign affairs), law enforcement, asset recovery and prosecution offices, the financial intelligence unit, security and intelligence services, customs and border agencies, financial and non-financial supervisors and self-regulatory organizations, tax authorities, import/export control bodies, company registries and beneficial ownership registries where they exist. Inclusion should be risk-based and flexible: countries must ensure the set of participants reflects national institutional arrangements and the specific threats identified in the national risk assessment.

Bastian Schwind-Wagner _Follow "Recommendation 2 calls for a designated national authority and robust inter‑agency frameworks to ensure coordinated, risk‑informed AML/CFT/CPF policy and operations. Clear leadership, secure information‑sharing mechanisms, and regular review aligned with data protection obligations are essential to detect and disrupt financial crime effectively."

Mechanisms for timely operational cooperation and information exchange

Recommendation 2 emphasizes not only policy coordination but practical, operational cooperation. Mechanisms must support both proactive information sharing and rapid responses to requests. Effective arrangements include clear articulation of each agency’s role, the information they need and the sources they can access; standardized formats and secure channels for data exchange; and practical tools such as joint task forces, shared data platforms or co-located teams for case work. These mechanisms reduce delays, prevent duplication, and enable combined use of financial intelligence, investigative capabilities and regulatory oversight.

Ensuring compatibility with data protection and other legal frameworks

Cooperation must operate within the boundaries of privacy, data protection, and other national legal constraints such as data localisation rules. Recommendation 2 requires authorities to build coordination arrangements that are compatible with those rules, ensuring that information sharing is lawful, proportionate and secure. This means designing protocols for classification, retention, access control and cross-agency queries that satisfy both operational needs and legal privacy obligations. Where necessary, legal or procedural adjustments should be made to remove barriers while safeguarding fundamental rights.

Keeping policies risk-informed and regularly reviewed

National AML/CFT/CPF policies should be informed by up-to-date risk assessments and subject to regular review. Risk intelligence evolves as criminal methods change, technologies develop and geopolitical conditions shift. The coordinating authority must ensure that new risks are incorporated into policy, that resource allocations reflect prioritization, and that stakeholders adapt operational practices accordingly. Regular reviews of the framework’s effectiveness — including testing information flows, joint exercises and after-action reviews of operations — help identify weaknesses and drive continuous improvement.

Practical steps for implementation

Countries can take several practical steps to implement Recommendation 2. First, formally designate the authority or mechanism responsible for national policy and coordination. Second, map the relevant agencies and establish clear mandates and points of contact. Third, develop legal and procedural instruments to enable timely, secure information exchange consistent with data protection rules. Fourth, create practical cooperation channels such as joint task forces, secure shared platforms and standard data formats. Finally, institutionalize periodic review cycles tied to the national risk assessment so policy and operations remain aligned with emerging threats.

Conclusion

Recommendation 2 places national cooperation and coordination at the heart of an effective fight against financial crime. By establishing a designated leadership role, bringing together the relevant authorities, building secure and lawful information-sharing mechanisms, and keeping policies risk-driven and regularly reviewed, countries can transform fragmented capabilities into an integrated, responsive system. That system improves detection, enhances prosecution and strengthens resilience against money laundering, terrorist financing and proliferation financing.

Dive deeper

• FATF ¦ The FATF Recommendations ¦ Link
• FATF ¦ Luxembourg’s measures to combat money laundering and terrorist financing ¦ Link