Mutual Evaluation of AML/CFT - FATF

 Mutual Evaluation(ME)

FATF mutual evaluations are in-depth country reports analysing the implementation and effectiveness of measures to combat money laundering, terrorist and proliferation financing. The reports are peer reviews, where members from different countries assess another country. Mutual evaluations provide an in-depth description and analysis of a country’s anti-money laundering and counter-terrorist financing system, as well as focused recommendations to further strengthen its system.

During a mutual evaluation, the assessed country must demonstrate that it has an effective framework to protect the financial system from abuse.

Mutual Evaluations have two main components, effectiveness and technical compliance.

  • The most important part of a mutual evaluation is a country’s effectiveness ratings. This is the focus of an on-site visit by a team of experts to the assessed country. During this visit, the assessment team will require evidence that demonstrates that the assessed country’s measures are working and delivering the right results. What is expected from a country differs, depending on the money laundering, terrorist financing and other risks it is exposed to.
  • The assessment of technical compliance is also an important part of a mutual evaluation. The assessed country must provide information on the laws, regulations and any other legal instruments it has in place to combat money laundering and the financing of terrorism and proliferation. 

The mutual evaluation report is an assessment of a country’s measures to combat money laundering and the financing of terrorism and proliferation of weapons of mass destruction. This includes an assessment of a country’s actions to address the risks emanating from designated terrorists or terrorist organisations.  The mutual evaluation report is without prejudice to the status or justification that led to the designation of an entity as a terrorist or terrorist group or organisation. 

The FATF conducts peer reviews of each member on an ongoing basis to assess levels of implementation of the FATF Recommendations, providing an in-depth description and analysis of each country’s system for preventing criminal abuse of the financial system.

FATF - Style Regional Bodies


Nine FATF-Style Regional Bodies have been established.  The FATF-style regional bodies are:

·         Asia/Pacific Group on Money Laundering (APG) based in Sydney, Australia;

·         Caribbean Financial Action Task Force (CFATF) based in Port of Spain, Trinidad and Tobago;

·         Eurasian Group (EAG) based in Moscow, Russia;

·         Eastern & Southern Africa Anti-Money Laundering Group (ESAAMLG) based in Dar es Salaam, Tanzania;

·         Central Africa Anti-Money Laundering Group (GABAC) based in Libreville, Gabon;

·         Latin America Anti-Money Laundering Group (GAFILAT) based in Buenos Aires, Argentina;

·         West Africa Money Laundering Group (GIABA) based in Dakar, Senegal;

·         Middle East and North Africa Financial Action Task Force (MENAFATF) based in Manama, Bahrain;

·         Council of Europe Anti-Money Laundering Group (MONEYVAL) based in Strasbourg, France (Council of Europe).

The APG, in conjunction with the FATF and the other eight regional bodies, constitute a global network to combat money laundering, the financing of terrorism and the financing of proliferation of weapons of mass destruction. The FATF's 40 recommendations are the principal standards to combat these crimes.

The ME Process

A mutual evaluation involves a team of experts drawn together from FATF - Style Regional Bodies of the  member jurisdictions (specially trained and qualified in the FATF's assessment methodology). The team consists of:

  • Legal experts;
  • Financial and regulatory experts; and
  • Law enforcement experts (including FIU experts).

 

Technical Compliance

A desk-based technical compliance analysis assesses compliance by an APG member with the specific requirements of each of the 40 FATF recommendations - the relevant legal and institutional framework of the jurisdiction, and the powers and procedures of competent authorities. These recommendations represent the building blocks of an AML/CFT system.

The technical compliance analysis is undertaken by an assessment team prior to an on-site visit of the member being evaluated. 

Effectiveness Analysis

An effectiveness analysis assesses the extent to which an APG member achieves a defined set of outcomes that are central to a proper functioning and effective AML/CFT system with expected results based on the ML and TF risk profile of that jurisdicition.  Experts forming the assessment team use "11 immediate outcomes," including core issues for each outcomes, in the 2013 methodology.

The effectiveness analysis is not just based on information exchanged with the assessment team. After the information is exchanged the team will visit the member under evaluation (usually for two weeks, sometimes longer) and interview government and private sector officials to gain a comprehensive understanding of how the AML/CFT system is working. Private sector participation is central to gaining this understanding.

FATF and India:

India became a member of FATF in 2010. India is also a member of two FATF Style Regional Bodies (FSRBs)- Asia Pacific Group (APG) and Eurasian Group of Combating Money Laundering and Financing of Terrorism (EAG). The core work of FATF is to conduct Mutual Evaluation of its Members and to guide and assist SRBs to conduct Mutual evaluationof their respective member jurisdictions. India’s last Mutual Evaluation was conducted in the year 2010 and the next Mutual Evaluation is scheduled to begin in the year 2020-21 based on the revised standards of FATF(40 recommendations and 11 Immediate Outcomes). The Mutual Evaluation is a very comprehensive and in tense exercise and evaluates the antimony laundering and combating terror financing (AML/CFT) ability of a country’s financial sector.

The India & Mutual Evaluation AML/CFT

Function of FATF Cell:

1. Consequent to the decision taken by the Cabinet Secretariat, , work relating to Financial Action Task Force (FATF) and the related Inter-Ministerial Coordination has been transferred from Department of Economic Affairs (DEA) to Department of Revenue(DOR) (vide GOI Gazette Notification dated 9th Nov, 2017).

2. FATF Cell was constituted in DoR in 2017 and currently has four OSDs, 1 Director and four ASOs working under the supervision of and reporting to Join Secretary (Revenue) .

3. Coordination of work related to FATF Secretariat is the main functionof FATF Cell. As part of this, FATF Cell coordinated with agencies of India’s ML/TF infrastructure namely ED,FIU-IND,RBI, SEBI,IRDAL,MHA,NIA,MEA etc.

 4. The Cell receives, circulates and discusses various papers/proposals related to FATF, .APG, EAG with all the concerned stakeholders within the country and comments of India are sent on these issues, keeping national interests in view.

 5. The FATF Cell also nominates Indian delegates for foreign deputation concerning plenary/meetings namely plenaries and other important meetings of FATF, APG and EAG. Officers of the FATF Cell also participate in; these meetings and the delegation takes part oin the multilateral discussions on various issues.

6. Currently, the FATF Cell is coordinating the work related to India’s upcoming mutual evaluation. JS (Revenue) is the national coordinator and Director (FATF) is the Deputy national coordinator or the Mutual evaluation exercise.

 7. An important part of FATF mutual evaluation is to conduct National Risk Assessment where risk of various sectors of the economy like banking, Insurance, Capital Markets, Designated Non-Financial Business and Profession sectors etc. are assessed periodically. FATF Cell, DoR functions as the coordinator for conducting India’s ML/TF NRA.

8. An Inter-Ministerial Coordination Committee has been constituted under the Chairpersonship of Revenue Secretary under S.72A of PMLA with the mandate of macro-level policy decision making on AML/CFT matters, operational co-operation between the Government, law enforcement agencies, the financial Intelligence Unit-India and the regulators or supervisors, and supervision of National Risk Assessment (NRA).

 9. An AML/CFT Join Working Group has been created under the chairpersonship of Additional Secretary (revenue) for enhancing operational co-ordination among all stakeholders.


The India ME Report(MER) 2024

The India MER 2024  summarises the AML/CFT measures in place in India as at the date of the on site visit from 6 to 24 November 2023. It analyses the level of compliance with the FATF 40 Recommendations and the level of effectiveness of India’s AML/CFT system and provides recommendations on how the system could be strengthened



Happy Reading,


Those who read this, also read:


1. AML/CFT International Cooperation: APG Group

2. National Risk Assessment - India 



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