Guidance on Proliferation Financing Risk Assessment and Mitigation

On June 29, 2021, the Financial Action Task Force (FATF) released guidelines for national supervisors, banks, and other businesses on how to detect and reduce their exposure to the financing of weapons of mass destruction.


The guideline comes after the intergovernmental body formally adopted modifications to its Recommendation 1 and a related Interpretative Note in October, urging member governments and private-sector firms to increase their efforts to combat proliferation financing (PF) connected to sanctions targets. Banks and other financial institutions are no longer required to create independent PF programs, but they must have systems in place to identify, analyze, monitor, manage, and mitigate such risks, according to the changes.


According to the FATF, preventing network trafficking in weapons of mass destruction would necessitate increased private-public sector collaboration. The FATF also encouraged governments and companies to start their risk assessment process before the end of the year by making a list of key identified threats; key sectors, items, or services that have been manipulated; types and activities that assigned individuals/entities engaged in; and the primary reasons why assigned persons and organizations have not been disadvantaged of their assets or identified. While perceived vulnerabilities to proliferation financing will vary widely across industries and counties, governments and businesses that believe they are unlikely to be exposed to such transactions should consider the probability that advanced PF networks have effectively managed to evade detection in the past, according to the FATF. 


According to the advisory paper, the lack of incidents involving confirmed or suspected PF-TFS breaches, non-implementation, or evasion in a given nation does not always imply that a government or a private sector business has minimal or no proliferation funding risk. Designated people and companies have used a variety of techniques to conceal their illegal actions, and the networks they oversee have purposefully dispersed their operations across numerous jurisdictions.


In accordance with the FATF Standards, the FATF has prepared a risk-based Guidance to analyze and define how supervisors should adopt a risk-based approach to their supervision and/or monitoring of financial organizations, Designated Non-Financial Businesses and Professions (DNFBPs), and Virtual Asset Service Providers (VASPs) in evaluating and managing ML/TF risk. While the Guidance is focused primarily on AML/CFT, supervisors should consider incorporating relevant parts of the Guidance into their supervisory techniques for the evaluation and mitigation of proliferation funding risk by their supervised organizations.


Assessing and Mitigating Proliferation Financing

Financial institutions and DNFBPs should be compelled to take the necessary procedures to analyze and identify their proliferation funding concerns. This might be done as part of their current targeted financial sanctions and/or compliance programs. They should record such assessments so that they can be proven, maintain them up to date, and have suitable systems in place to communicate risk assessment information to relevant authorities and SRBs. The form and scope of any examination of proliferation funding risks should be suitable for the business's nature and scale. Financial institutions and DNFBPs should constantly be aware of their proliferation financing vulnerabilities, although competent authorities or SRBs may decide that particular recorded risk assessments aren't necessary if the sector's unique dangers are well-understood.


Financial institutions and DNFBPs should have rules, controls, and procedures in place to effectively manage and reduce risks. This might be done as part of their current targeted financial sanctions and/or compliance programs. They should be held accountable for overseeing the execution of such measures and, if necessary, improving them. Upper management should approve the policies, controls, and processes, and the actions are taken to manage and mitigate the risks (whether larger or smaller) should be in line with national standards and recommendations from relevant authorities and SRBs. In every risk situation, countries should guarantee complete compliance with Recommendation 7. 


Countries should compel financial institutions and DNFBPs to implement appropriate risk management and mitigation procedures in areas where there are higher hazards. Where the risks are smaller, they should ensure that the actions are proportionate to the degree of risk while nevertheless ensuring that the targeted financial sanctions are fully implemented as required by Recommendation 7.


FATF Recommendations on Counter Proliferation Financing

Countries should identify, analyze, and comprehend their country's proliferation financing threats. The term "proliferation finance risk" in the context of Recommendation 1 refers solely to the possibility of a violation, non-implementation, or evasion of the targeted financial sanctions requirements referred to in Recommendation 7. Countries should take similar steps to ensure that these risks are successfully managed, such as establishing authority or a system to coordinate risk assessments and allocating resources efficiently for this purpose. Where increased hazards are identified, governments must ensure that they are appropriately addressed. Where nations find lesser risks, they should ensure that the actions taken are proportionate to the degree of proliferation finance risk while nevertheless ensuring that the targeted financial sanctions are fully implemented, as required by Recommendation 7.

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