NIBAF AML & CFT study materials
NIBAF AML & CFT study resources

NIBAF AML & CFT: FATF Recommendations

NIBAF AML & CFT · Work through your exam, one topic at a time.

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FATF Recommendations

Domain 4 is the FATF 40 Recommendations. The exam tests recommendation numbers and the control each one requires, often through a scenario rather than a definition.

Core rules

  • R.1 is the risk-based approach; R.3 criminalises ML; R.4 covers confiscation; R.5 criminalises TF; R.6 requires targeted financial sanctions.
  • R.10 is CDD; R.11 record keeping (at least five years); R.12 PEPs; R.13 correspondent banking; R.16 wire transfers.
  • R.20 requires STRs to the FIU with no threshold; R.21 prohibits tipping off; R.22 extends AML/CFT to DNFBPs.
  • R.23-25 cover transparency and beneficial ownership of legal persons and arrangements.
  • R.36-40 cover international cooperation, including mutual legal assistance and extradition.

Worked example

A foreign PEP opens an account through an introducer. R.10 requires CDD, but R.12 adds senior-management approval, source-of-wealth and source-of-funds checks, and enhanced ongoing monitoring. R.13 is not engaged unless this is a correspondent banking relationship. The correct answer is not 'file an STR automatically'; suspicion still needs a factual basis.

Traps

  • Assuming R.20 has a monetary threshold; it does not.
  • Treating R.6 as the same as criminalising TF under R.5.
  • Applying R.12 only to foreign PEPs; domestic and international-organisation PEPs are included.
  • Forgetting that R.11 is a minimum, not a maximum, retention period.