Complying with the regulators: Counter-Proliferation Financing

The Financial Action Task Force (FATF) amended Recommendation 1 on 23rd October 2020 to strengthen the global response to Weapons of Mass Destruction (WMD) proliferation financing. This amendment outlines the importance of ‘proliferation financing risk’ which is defined as ‘a potential breach, non-implementation or evasion of targeted financial sanctions related to proliferation financing’. In order to comply with this, countries must take appropriate action to ensure that these risks are mitigated. FATF have advised that they should ‘designate an authority or mechanism to coordinate actions to assess risks, and allocate resources efficiently for this purpose’. They have also stated that where countries identify a higher risk, they should address these risks accordingly. By no means do these new obligations substitute the existing strict requirements with regards to the implementation of United Nations (UN) targeted financial sanctions but they instead aim to assess and mitigate the risks of proliferation financing.


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