Worldwide, with nineteen markets mapped in depth

Bahrain

In Bahrain, the supervisor depends on your licence. The AML/CFT law is Decree-Law No. (4) of 2001, as amended.

Reporting: Financial institutions licensed by the CBB file suspicious transaction reports through the Online STR system, to Bahrain's financial intelligence unit and to the CBB. Dealers in gold and jewellery, auditors and real estate brokers also report suspicious transactions to the financial intelligence unit.

The MLRO seat: At a conventional bank, the MLRO is a member of senior management, and the CBB must approve the appointment.

Banks: Conventional banks and Islamic banks each have their own volume of the CBB Rulebook. The Financial Crime module of each volume holds the detailed AML/CFT requirements, the MLRO's role and duties included.

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Kuwait

In Kuwait, the supervisor depends on your licence. The AML/CFT law is Law No. (106) of 2013, as amended, and Ministerial Resolution No. (37) of 2013 issued its executive regulation.

Reporting: Financial institutions and designated non-financial businesses and professions (DNFBPs) report to the Kuwait Financial Intelligence Unit (KwFIU) any transaction or attempted transaction, whatever its value, that they suspect, or have reasonable grounds to suspect, involves the proceeds of crime or funds linked to money laundering or terrorism financing. The law asks for the report without delay, and its executive regulation sets a limit of two working days after the suspicion forms. The KwFIU receives reports electronically through goAML.

The MLRO seat: Kuwaiti law calls the seat the compliance officer. Every financial institution and DNFBP designates one at senior management level, responsible for implementing the law, under Article 10 of Law No. (106) of 2013. A bank gives the CBK the details of its compliance officer and deputy, and informs the CBK of any change.

Virtual assets: Circulars of the CBK and the CMA of 17 July 2023 ban the use of virtual assets for payment or investment, and all virtual asset mining, in Kuwait, and no licence is issued for virtual asset services. Securities regulated by the CBK, and other securities and financial instruments regulated by the CMA, are outside the ban. The firms the circulars address must keep their customers informed of the risks of virtual asset dealings carried out outside Kuwait.

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Oman

In Oman, the supervisor depends on your licence. The AML/CFT law is the Law on Combating Money Laundering and Terrorism Financing, promulgated by Royal Decree No. 30/2016.

Reporting: Suspicious transaction reports go to the National Centre for Financial Information (NCFI) immediately, attempted transactions included. Reporting entities registered with the NCFI file through its electronic reporting system.

The MLRO seat: Oman's AML/CFT instructions call the seat the compliance officer, appointed at senior management level, with AML/CFT experience and qualifications and the authority to act independently. The institution gives the officer's details to its supervisor and to the NCFI, and reports any change promptly.

Recent change: Royal Decree No. 20/2024 established the FSA and transferred to it the assets, rights and obligations of the Capital Market Authority. A programme that still names the Capital Market Authority needs its references mapped to the FSA.

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Qatar

Qatar has two perimeters. Firms in the Qatar Financial Centre (QFC) answer to the Qatar Financial Centre Regulatory Authority (QFCRA), and firms onshore answer to national supervisors. Both are subject to Law No. (20) of 2019 on Combating Money Laundering and Terrorism Financing, amended by Law No. (18) of 2025, and to its Implementing Regulations, promulgated by Council of Ministers' Decision No. (41) of 2019.

Reporting: Financial institutions and DNFBPs in both perimeters report suspicious transactions to the Qatar Financial Information Unit (QFIU) promptly, whatever the value, attempted transactions included. The QFIU takes reports through its electronic system, ESTR, from firms with an electronic link to it, and by hand at its headquarters.

The MLRO seat: Every financial institution and DNFBP appoints a compliance officer at management level as part of its AML/CFT programme. A financial institution licensed by the QCB needs the QCB's approval to appoint or remove its MLRO and its Deputy MLRO.

Recent change: On 1 September 2024, the Qatar Financial Centre Authority (QFCA) and the QFCRA launched the QFC Digital Assets Framework 2024, for digital assets in the QFC and their tokenisation. The framework brought token service providers that are not financial institutions under the AML/CFTR. A token service provider in the QFC needs a programme written to those rules.

Funds and corporate service providers: In the QFC, a firm that undertakes portfolio management, or invests, administers or manages funds for others, is a financial institution under the AML/CFTR, and the QFCRA supervises it. A trust and company service provider in the QFC is a DNFBP with a QFCA licence and is supervised by the QFCRA; onshore, the Ministry of Commerce and Industry supervises it.

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Saudi Arabia

In Saudi Arabia, the supervisor depends on your licence. Money laundering duties come from the Anti-Money Laundering Law, issued by Royal Decree No. (M/20) in 2017 and since amended, and from its implementing regulation. Terrorist financing falls under a separate law, issued by Royal Decree No. (M/21).

Reporting: Financial institutions and designated non-financial businesses and professions, persons who provide legal or accounting services included, report to the General Directorate of Financial Intelligence immediately and directly when they suspect, or have reasonable grounds to suspect, that funds are proceeds of crime or linked to money laundering, attempts included. The duty applies whatever the amount, and the report follows the form the Directorate has approved.

The MLRO seat: The implementing regulation calls the seat the anti-money laundering compliance officer. Financial institutions and designated non-financial businesses and professions appoint one at senior management level.

Recent change: An update of the implementing regulation adds the Insurance Authority to the supervisory authorities. A firm that reports a suspicion about a complex or large transaction must now also suspend its execution, under guidelines the Directorate issues with the supervisory authorities. The Directorate decides on such a report within two working days and may order the transaction suspended for up to seven working days from the date of the report.

Payments: Under the Law of Payments and Payment Services of 2021, no one may operate a payment system or provide payment services in Saudi Arabia without a licence from SAMA. Money changers hold a separate licence, and SAMA supervises them as well.

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United Arab Emirates

In the UAE, the supervisor depends on your licence and on where you hold it. The federal AML/CFT law is Federal Decree-Law No. 10 of 2025, and Cabinet Resolution No. 134 of 2025 sets out its executive regulations.

Reporting: Suspicious transaction reports go to the UAE FIU alone. Virtual asset firms and DNFBPs register on goAML, the FIU's reporting system.

The MLRO seat: In the DIFC and in ADGM, the MLRO must be resident in the UAE. In ADGM the FSRA approves the appointment.

Recent change: Federal Decree-Law No. 10 of 2025 repealed Federal Decree-Law No. 20 of 2018, the previous AML/CFT law. A programme written to the 2018 law needs mapping to the new texts.

Virtual assets: In the DIFC, updated Crypto Token rules apply from 12 January 2026. The DFSA keeps no list of recognised tokens, and each firm assesses on a documented basis whether a token is suitable.

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Egypt

In Egypt, the supervisor depends on your licence or your business. The AML/CFT law is the Anti-Money Laundering Law promulgated by Law No. 80 of 2002, with its amendments, and its executive regulations were issued by Prime Ministerial Decision No. 951 of 2003.

Reporting: Suspicious transaction reports go to the Egyptian Money Laundering and Terrorist Financing Combating Unit (EMLCU), Egypt's FIU, established at the CBE. Financial institutions and DNFBPs notify it as soon as their AML/CFT manager becomes suspicious, whatever the value, attempted transactions included. Banks notify it through its electronic system.

The MLRO seat: Every financial institution and DNFBP appoints a manager responsible for AML/CFT and a substitute for absences, and gives the EMLCU their names and contact details. In a bank, both are senior staff with suitable academic qualifications and sufficient practical experience.

Recent change: In September 2026, the EMLCU's board of trustees approved new customer due diligence procedures for customers of banks, exchange companies and money transfer companies. A programme written to the earlier procedures needs its due diligence steps mapped to the new texts.

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Jordan

In Jordan, the supervisor depends on your licence or your business. The AML/CFT law is Law No. (20) of 2021.

Reporting: Financial institutions and designated non-financial businesses and professions notify the Anti Money Laundering and Counter Terrorist Financing Unit immediately of any transaction or activity, attempts included, when they suspect, or have reasonable grounds to suspect, that funds are the proceeds of money laundering, an associated predicate offence or terrorist financing. The duty applies whatever the amount.

The MLRO seat: Under the Central Bank's instructions for banks, a bank names a money laundering reporting officer and a deputy, and keeps the Unit and the Central Bank informed of both names.

Recent change: Law No. (14) of 2025 regulates dealing in virtual assets. Only a legal person licensed by the Jordan Securities Commission may carry on virtual asset activities for others, or promote them, in Jordan, and the Commission supervises their compliance with AML/CFT requirements on a risk basis. A company the Central Bank supervises may, with the Central Bank's prior approval, exchange virtual assets for Jordanian or foreign currency or hold them in custody, and the Central Bank supervises that activity.

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Ghana

In Ghana, the supervisor depends on your licence or your business. The AML/CFT law is the Anti-Money Laundering Act, 2020 (Act 1044).

Reporting: Suspicious transaction reports go to the Financial Intelligence Centre within twenty-four hours. Attempted transactions are reported too, whatever the amount.

The MLRO seat: Section 50 of Act 1044 requires each accountable institution to appoint an Anti-Money Laundering Reporting Officer. Under the guidelines that the Bank of Ghana and the SEC each issued with the Centre, the officer sits at key management level, with sufficient authority, independence and seniority, and reports to the board or a sub-committee of the board. The same guidelines make the firm ensure that the officer acquires a professional qualification in anti-money laundering and financial crime.

Recent change: Under the Virtual Asset Service Providers Act, 2025 (Act 1154), persons and entities that carry on virtual asset activities need a licence or registration from the Bank of Ghana or the SEC, depending on the activity.

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Kenya

In Kenya, the Financial Reporting Centre (FRC) supervises all reporting institutions, and each supervisory body also supervises the firms it regulates. The AML/CFT law is the Proceeds of Crime and Anti-Money Laundering Act, Cap. 59A (POCAMLA), with the Proceeds of Crime and Anti-Money Laundering Regulations, 2023 (Legal Notice 153 of 2023).

Reporting: Suspicious transaction reports go to the FRC, Kenya's financial intelligence unit, through goAML, within two days after the suspicion arose. Every reporting institution must register with the FRC. The law lets advocates, notaries and other independent legal professionals report through the Law Society of Kenya, which is to set up reporting channels to the FRC.

The MLRO seat: Every reporting institution appoints a Money Laundering Reporting Officer at management level, under regulation 12 of the 2023 Regulations.

Recent change: The Virtual Asset Service Providers Act, 2025, assented to on 15 October 2025, requires a licence for virtual asset services in or from Kenya and made providers reporting institutions under the POCAMLA. A provider needs its licence from the CMA or the CBK, by activity, and an AML/CFT programme that answers to that authority.

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Nigeria

In Nigeria, the supervisor depends on your licence or your business. The AML/CFT law is the Money Laundering (Prevention and Prohibition) Act, 2022.

Reporting: Suspicious transaction reports go to the Nigerian Financial Intelligence Unit within twenty-four hours, mainly through goAML. The duty applies whether the transaction is complete or not.

The MLRO seat: Section 10 of the Act requires every financial institution and designated non-financial business or profession to designate compliance officers at management level. The regulations of the SEC and of SCUML, each for its own firms, require an officer with the competence, authority and independence to implement the compliance programme.

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South Africa

In South Africa, the supervisor depends on your business. The AML/CFT law is the Financial Intelligence Centre Act, 2001 (Act 38 of 2001), the FIC Act, amended by the General Laws (Anti-Money Laundering and Combating Terrorism Financing) Amendment Act, 2022 (Act No. 22 of 2022). Schedule 2 of the FIC Act names a supervisory body for some kinds of accountable institution, and the Financial Intelligence Centre (FIC) supervises the others.

Reporting: Suspicious and unusual transaction reports go to the FIC under section 29 of the FIC Act, which applies to anyone who carries on, manages or is employed by a business. A person who knows or suspects, or ought reasonably to have known or suspected, one of the matters section 29 lists reports the grounds and the prescribed particulars within the prescribed period after the knowledge was acquired or the suspicion arose. Every accountable institution registers with the FIC on goAML, under the correct items of Schedule 1 and in some cases more than one.

The MLRO seat: Under section 42A of the FIC Act, an accountable institution that is a legal person has a compliance function and assigns a person with sufficient competence and seniority to ensure that the function is effective. The board of directors, or senior management where there is no board, must ensure compliance with the Act and with the Risk Management and Compliance Programme that section 42 requires.

Recent change: FIC Directive 9, in operation since 30 April 2025, applies the travel rule to crypto asset transfers by crypto asset service providers under items 12 and 22 of Schedule 1. The ordering provider must transmit to the recipient provider information on the originator and the beneficiary of a qualifying transfer, and both must include risk-based policies and procedures for transfers that involve unhosted wallets in their Risk Management and Compliance Programme. A programme written before it needs those procedures added.

Virtual assets: Since 19 December 2022, a business that exchanges or transfers crypto assets for a client, holds them in safekeeping or administers them, or provides financial services for an issuer's offer or sale of a crypto asset, is an accountable institution and registers with the FIC. In October 2022, the FSCA declared crypto assets a financial product under the FAIS Act, and it licenses crypto asset service providers for the advice and intermediary services they render on crypto assets.

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Azerbaijan

In Azerbaijan, the supervisor depends on your licence or your profession. The AML/CFT law is Law No. 781-VIQ of 30 December 2022.

Reporting: Suspicious transaction reports go to Azerbaijan's Financial Monitoring Service (FMS), whatever the amount, attempts included. Where the suspicion concerns a transaction linked to a high-risk customer profile, a transaction at or above a threshold the FMS sets, or a withdrawal of funds from an account, a financial institution holds the transaction for two working days and reports it before carrying it out. If the FMS gives no instruction to stop it within that time, the transaction goes ahead.

The MLRO seat: Law No. 781-VIQ requires each obliged person to set up an independent and effective compliance system, with a compliance officer at management level and a deputy who acts in the officer's absence. The FMS sets the minimum requirements for the internal control programme, and each supervisor may add requirements for the firms it supervises.

Recent change: Law No. 240-VIIQD of 8 July 2025 made organisers and operators of casino games obliged persons under Law No. 781-VIQ.

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Georgia

In Georgia, the supervisor depends on your licence or your profession. The AML/CFT law is the Law of Georgia on Facilitating the Prevention of Money Laundering and the Financing of Terrorism, of 30 October 2019.

Reporting: Suspicious transaction reports go to the Financial Monitoring Service of Georgia (FMS) through its online system on the day a reasonable suspicion forms, whatever the amount, attempts included. Each firm needs a software system, proportionate to its business and risks, to identify suspicious transactions and report them. A firm that starts operating registers with the FMS through its web portal within 10 business days of receiving its licence, registration or permission.

The MLRO seat: Georgian law puts the person who runs the compliance system, or the head of the unit that runs it, at senior management level. That person answers to a member of the governing body, or a person with managing authority, whom the firm makes responsible for the system's effectiveness. The compliance officer decides independently whether to file a report, and the firm protects the officer against threats, discriminatory treatment and other unlawful influence.

Recent change: Law No. 1460 of 1 April 2026 makes factoring companies and factoring platforms obliged entities supervised by the NBG, from 1 January 2027. From that date, the reporting and compliance duties above apply to them.

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Kazakhstan

Kazakhstan has two perimeters. Firms in the Astana International Financial Centre (AIFC) answer to the Astana Financial Services Authority (AFSA) under the AIFC AML rules, and firms onshore answer to national supervisors. The national AML law is Law No. 191-IV of 28 August 2009.

Reporting: AIFC firms send threshold transaction reports and suspicious transaction reports to the Financial Intelligence Unit of the Republic of Kazakhstan.

The MLRO seat: In the AIFC, the MLRO must as a rule be resident in Kazakhstan.

Recent change: From 1 May 2026, the National Bank of Kazakhstan licenses onshore exchanges for unsecured digital assets and keeps the register of digital asset trading platforms. The change came with Law No. 259-VIII of 16 January 2026, which amended the Law "On digital assets".

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Kyrgyzstan

In Kyrgyzstan, the supervisor depends on your licence, and the government sets which body examines which firm. The AML/CFT law is Law No. 87 of 6 August 2018 "On countering the financing of criminal activity and the legalisation (laundering) of criminal proceeds", and Cabinet of Ministers Resolution No. 739 of 14 November 2025 approved the regulations that implement it.

Reporting: Suspicious transaction reports go to the State Financial Intelligence Service under the Ministry of Finance within five hours of the transaction being recognised as suspicious, whatever the amount, attempts included. Firms also report transactions with persons from high-risk countries, and cash and non-cash transactions at or above the threshold amount, in the procedure the Cabinet of Ministers sets.

The MLRO seat: At a bank, the officer responsible for AML/CFT internal control is a bank employee.

Recent change: Law No. 26 of 23 January 2025 renamed the law from the financing of terrorist activity to the financing of criminal activity. The law defines that term as the financing of terrorist activity, extremist activity, the proliferation of weapons of mass destruction, and organised groups or criminal communities. A programme written to the old title needs its terms and risk assessment mapped to the new definition.

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Uzbekistan

In Uzbekistan, the supervisor depends on your licence. The AML/CFT law is Law No. 660-II of 26 August 2004.

Reporting: Suspicious transaction reports go to the Department for Combating Economic Crimes under the General Prosecutor's Office, which acts as Uzbekistan's financial intelligence unit. They are due no later than one working day after the day the transaction is identified, attempts included.

The MLRO seat: At a commercial bank, the head of the internal control service must be a member of the management board. At a payment organisation, a payment system operator or an electronic money system operator, the internal control officer must be a member of the executive body or a deputy head.

Recent change: Law No. ZRU-1057 of 17 April 2025 added the Central Securities Depository to the organisations the AML/CFT law covers.

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Turkey

In Turkey, the supervisor depends on your licence, and MASAK, the Financial Crimes Investigation Board of the Ministry of Treasury and Finance, receives suspicious transaction reports and imposes fines. Under the anti-money laundering law, Law No. 5549 of 11 October 2006 on Prevention of Laundering Proceeds of Crime, compliance is examined by the examiners it lists, among them experts of the Banking Regulation and Supervision Agency (BDDK) and the Capital Markets Board (CMB) and auditors and experts of the Central Bank of the Republic of Türkiye.

Reporting: Suspicious transactions, attempted ones included, go to MASAK on its suspicious transaction report form within ten working days of the date the suspicion arises.

The MLRO seat: Banks, capital markets intermediaries, insurance and pension companies, electronic money institutions, crypto-asset service providers and the other financial firms the compliance regulation lists appoint a compliance officer and at least one deputy on the same conditions. Both must be Turkish citizens with at least five years as a manager, specialist or auditor at a financial institution that regulation lists, as one of the examiners Law No. 5549 lists, or as a manager or Treasury and Finance Expert at MASAK. The compliance officer reports to the board of directors or to the board members it delegates its authority to.

Recent change: Since 25 December 2025, a compliance officer or deputy must hold an authorisation, which requires passing an exam, and be entered in the compliance officer registry MASAK keeps. The condition was added to the compliance regulation in December 2024.

Virtual assets: A crypto-asset service provider needs the CMB's permission to be set up and to start operating, and it has been an obliged party under the anti-money laundering rules since 1 May 2021. Its customers' crypto-asset transfers must carry the sender and recipient information that the CMB's and MASAK's rules require.

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Pakistan

In Pakistan, your AML/CFT supervisor depends on your licence or your profession. Schedule IV of the Anti-Money Laundering Act, 2010 (the AML Act) names the regulators and self-regulatory bodies that act as AML/CFT regulatory authorities, and the Virtual Assets Act, 2026 set up a regulator to license and supervise virtual asset service providers.

Reporting: Suspicious transaction reports go to the Financial Monitoring Unit (FMU), Pakistan's FIU, through goAML. A reporting entity registers on goAML before it can file.

The MLRO seat: Every reporting entity appoints a compliance officer at a management level, under section 7G of the AML Act. Under the Virtual Assets Act, 2026, the money-laundering reporting officer is a Key Individual, and the definition covers a post held on a full-time, part-time, acting or outsourced basis. At least one Key Individual ordinarily resident in Pakistan must hold operational and decision-making authority.

Recent change: The Virtual Assets Act, 2026 (Act No. XIII of 2026) is dated 4 March 2026, came into force at once and established PVARA. Virtual asset service providers licensed under it are deemed financial institutions for the purposes of the AML Act, and they report suspicious transactions to the FMU.

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Virtual assets and crypto

For: Exchanges, brokers, custodians, wallet providers, transfer services and token issuers.

The standard: Recommendation 15 of the FATF requires virtual asset service providers to be licensed or registered, at a minimum where they are created, and supervised for AML/CFT by a competent authority, which cannot be a self-regulatory body. The preventive measures of Recommendations 10 to 21 apply to them. Under Recommendation 16 as applied to virtual asset transfers, known as the travel rule, the originating provider sends the required originator and beneficiary information to the beneficiary provider immediately and securely.

In our markets:

What we build: the business risk assessment by product, customer, token and channel; customer due diligence with source of funds and source of wealth; wallet screening and transaction monitoring rules written for the analytics system you use; the travel rule procedure; and sanctions screening of customers, wallets and counterparties.

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Payments and MSBs

For: Payment institutions, electronic money issuers, remittance providers and money service businesses.

The standard: Recommendation 14 requires providers of money or value transfer services to be licensed or registered and monitored for AML/CFT compliance, and to include their agents in their AML/CFT programme and monitor them. Under Recommendation 16, the required originator and beneficiary information goes with a payment or value transfer and stays with it through the payment chain. A provider that controls both sides of a transfer considers both before deciding whether to file a suspicious transaction report, and files it in any country affected.

In our markets:

What we build: the risk assessment by product, corridor and channel; agent due diligence and oversight; transaction monitoring rules set for your volumes; the payment transparency procedure; and sanctions screening of payments.

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Banks and financial institutions

For: Retail, corporate and correspondent banks, and other financial institutions.

The standard: Under Recommendation 10, a financial institution identifies and verifies its customer, identifies the beneficial owner and takes reasonable measures to verify that person's identity, and keeps the relationship under ongoing due diligence. Under Recommendation 13, a bank that opens a cross-border correspondent relationship first understands the respondent's business, reputation and quality of supervision, obtains senior management approval, and keeps no relationship with a shell bank. Recommendation 18 requires internal controls with a compliance officer at management level, employee screening, ongoing training and an independent audit function, applied across the group, foreign branches and majority-owned subsidiaries included.

In our markets:

What we build: the business risk assessment; customer and beneficial owner due diligence; correspondent and nested relationship reviews; sanctions screening and transaction monitoring rules; and group-wide policies for branches and subsidiaries.

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Funds and corporate service providers

For: Fund managers, fund administrators, and trust and company service providers.

The standard: The FATF defines portfolio management, and investing, administering or managing funds for others, as financial institution activities. Trust and company service providers apply customer due diligence and report suspicious transactions when they act for a client as formation agent, director, secretary, partner, trustee of an express trust or nominee shareholder, arrange for another person to act so, or provide a registered office (Recommendations 22 and 23). Recommendations 24 and 25 require adequate, accurate and up-to-date beneficial ownership information on legal persons and on express trusts, which competent authorities can obtain in a timely manner.

In our markets:

What we build: due diligence on investors and beneficial owners through every layer of a structure; source of wealth checks; procedures for formation, director, nominee and trustee services; and the beneficial ownership records a supervisor can ask for.

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Gold, precious metals and stones

For: Dealers in precious metals and stones, refiners and bullion traders.

The standard: Recommendations 22 and 23 require dealers in precious metals and dealers in precious stones to apply customer due diligence and report suspicious transactions when they engage in a cash transaction with a customer at or above the designated threshold. Under Recommendation 28, a supervisor or a self-regulatory body monitors them for AML/CFT compliance on a risk-sensitive basis. Under Recommendations 6 and 7, countries require every natural and legal person to freeze, without delay and without prior notice, the funds or other assets of designated persons and entities.

In our markets:

What we build: customer and supplier due diligence; supply chain checks on origin and transport; cash transaction controls; sanctions screening of counterparties; and suspicious transaction reporting.

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Gaming

For: Land-based and online gaming operators, casinos included.

The standard: Under Recommendation 28, casinos are licensed and subject to a comprehensive regulatory and supervisory regime, and competent authorities keep criminals and their associates from owning a significant or controlling interest in a casino, managing it or operating it. Under Recommendation 22, casinos apply customer due diligence on financial transactions at or above the designated threshold, and must be able to link each customer's due diligence information to that customer's transactions in the casino. References to casinos in the FATF Standards include internet- and ship-based casinos.

In our markets:

What we build: player due diligence linked to each player's transactions; source of funds checks; monitoring rules for cash and chip conversion and for online accounts; and the reporting procedure.

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Real estate and DNFBPs

For: Real estate agents and developers, lawyers, notaries, accountants and the other designated non-financial businesses and professions.

The standard: Under Recommendation 22, real estate agents apply customer due diligence to both purchaser and vendor when they act for a client in buying or selling real estate. Lawyers, notaries, other independent legal professionals and accountants apply it in five activities for a client, from buying and selling real estate and managing client money or assets to creating legal persons and buying and selling businesses, and report suspicious transactions when they engage in a financial transaction in those activities (Recommendation 23). They are not required to report information obtained under professional secrecy or legal professional privilege, and dissuading a client from illegal activity does not amount to tipping-off.

In our markets:

What we build: buyer and seller due diligence; beneficial ownership checks on the companies and trusts in a deal; third-party payment controls; and a reporting procedure with a privilege test for lawyers and accountants.

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Defence and dual-use

For: Defence firms, makers and traders of dual-use goods, and firms in export-sensitive trade.

The standard: Under Recommendations 6 and 7, countries require every natural and legal person to freeze, without delay and without prior notice, the funds or other assets of persons and entities designated under the UN Security Council resolutions, those on the proliferation of weapons of mass destruction and its financing included. Since October 2020, Recommendation 1 has required financial institutions and designated non-financial businesses and professions to identify, assess and mitigate their proliferation financing risk, which means strictly the potential breach, non-implementation or evasion of those sanctions. UN Security Council resolution 1540 (2004) separately requires every State to establish domestic controls against the proliferation of nuclear, chemical or biological weapons and their means of delivery, national export and trans-shipment controls included, and the Participating States of the Wassenaar Arrangement implement export controls through national legislation.

What we build: sanctions screening of customers, end users and counterparties; end-use and diversion checks; the proliferation financing risk assessment; and the link between your export control function and your financial crime controls.

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Art and high-value assets

For: Dealers in art, collectibles and other high-value goods, auction houses, and the intermediaries who handle their sales.

The standard: The FATF list of designated non-financial businesses and professions names casinos, real estate agents, dealers in precious metals and stones, lawyers, notaries, other independent legal professionals and accountants, and trust and company service providers. Where a country's risk assessment finds businesses at risk outside the definitions of financial institution and of those professions, the country should consider applying AML/CFT requirements to them (interpretive note to Recommendation 1). Under Recommendations 6 and 7, countries require every natural and legal person to freeze, without delay and without prior notice, the funds or other assets of designated persons and entities.

In our markets: In South Africa, the Financial Intelligence Centre supervises dealers in high-value goods.

What we build: provenance and ownership checks; due diligence on buyers, sellers and intermediaries; sanctions screening; and a risk assessment that shows a bank or a supervisor how you control high-value sales.

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