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The participation of low and middle-income countries in the Financial Action Task Force

The FATF standard setting process on AML/CFT is mainly established by FATF members, which consist primarily of higher income countries, though lower- and middle-income countries (LMIC) participate through the FATF-style regional bodies (FSRBs). However, relevant literature questions the extent of the inclusion of LMIC in the standard setting and mutual evaluation processes, arguing that the FATF is not fully transparent regarding the level of influence these countries have and that the agenda is still driven by higher income jurisdictions.

11 September 2023
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The participation of low and middle-income countries in the Financial Action Task Force

Main points

  • The FATF‘s members consist primarily of higher income countries, and participation of most lower and middle-income countries in its standard setting process is through the FATF-style regional bodies (FSRBs).
  • This, as the FATF states, enables LMICs to influence the development of FATF standards and participate in FATF mutual evaluations (FATF 2019 a), which assess the compliance of countries’ AML/CTF measures with the FATF Recommendations. This process can carry significant implications, including influencing FATF’s decision to identify a jurisdiction as one under increased monitoring (the “grey list”) or a high-risk jurisdiction subject to a call for action (“the black list”).
  • However, a limited body of literature contends that the FATF is not transparent in the precise level of influence the FSRBs have over the standard setting and review process. Some argue that the FATF is still largely driven by the agenda of higher income countries.
  • Recommendations put forward include increasing transparency in the process of grey or black listing a jurisdiction, giving greater consideration to lower capacity of lower and middle-income countries and enabling stronger rights of LMICs in the FATF Plenary.

Cite this publication


Maslen, C. (2023) The participation of low and middle-income countries in the Financial Action Task Force. Bergen: U4 Anti-Corruption Resource Centre, Chr. Michelsen Institute (U4 Helpdesk Answer 2023:20)

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