Developing and Implementing AML/CFT Measures Using a Risk-Based Approach for New Payments Products and Services

31 Pages Posted: 21 Jun 2014 Last revised: 10 Sep 2014

See all articles by Louise Malady

Louise Malady

University of New South Wales (UNSW) - Faculty of Law

Ross P. Buckley

University of New South Wales (UNSW) - Faculty of Law

Douglas W. Arner

The University of Hong Kong - Faculty of Law

Date Written: June 19, 2014

Abstract

The use of new payment methods by the previously unbanked or underbanked holds out much hope for improved financial inclusion and consequently improved standards of living. It is important that new payment methods that enhance financial inclusion not be weighed down by overly burdensome regulation due to financial integrity concerns.

The Financial Action Taskforce (FATF), the global standards setting body for Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT), continues to work toward the objective of aligning financial integrity and financial inclusion objectives. To this end, FATF encourages countries and institutions to adopt proportionate regulations for AML/CFT purposes by providing greater clarity and understanding on the use of a risk-based approach to implementing AML/CFT measures for new payment methods.

Developing and implementing AML/CFT measures using a risk-based approach for new payment methods is still in the early stages of development. Countries and institutions need to be supported to be confident to embrace international efforts on proportional regulation and not be unduly conservative.

This paper analyses and explains FATF’s Risk-Based Approach (RBA) for new payment methods to support countries and institutions in their efforts to use a RBA to improve financial inclusion.

Suggested Citation

Malady, Louise and Buckley, Ross P. and Arner, Douglas W., Developing and Implementing AML/CFT Measures Using a Risk-Based Approach for New Payments Products and Services (June 19, 2014). CIFR Paper No. 028/2014; University of Hong Kong Faculty of Law Research Paper No. 2014/021. Available at SSRN: https://ssrn.com/abstract=2456581 or http://dx.doi.org/10.2139/ssrn.2456581

Louise Malady

University of New South Wales (UNSW) - Faculty of Law ( email )

Kensington, New South Wales 2052
Australia

Ross P. Buckley (Contact Author)

University of New South Wales (UNSW) - Faculty of Law ( email )

Sydney, New South Wales 2052
Australia

Douglas W. Arner

The University of Hong Kong - Faculty of Law ( email )

Pokfulam Road
Hong Kong, Hong Kong
China

HOME PAGE: http://hub.hku.hk/rp/rp01237

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