Antoine Bouveret

Maksym Markevych

Ms. Grace Jackson

Pierre Bardin

Alexander S Malden

Santiago Texidor Mora

Indulekha Thomas

In their efforts to strengthen the effectiveness of Anti-Money Laundering/Countering the Financing of Terrorism Frameworks across the Nordic-Baltic Region (Denmark, Estonia, Finland, Iceland, Latvia, Lithuania, Norway, and Sweden), the Governors of the Nordic-Baltic Central Banks reached out to the IMF to request technical assistance. The request stems from various international money laundering banking scandals (ABLV, Danske Bank, Nordea, Swedbank), involving cross-border payments by non-residents that exposed financial integrity risks in the financial sector of the region, attracting international scrutiny on the level of non-resident Money Laundering/Terrorist Financing ML/TF risks and highlighting the vulnerabilities related to AML/CFT risk-based supervision of banks in the region. The flagship project relied on a novel methodology to leverage data analysis to understand ML/TF threats and vulnerabilities and their potential impact on financial stability, and developed country and regional recommendations. Notably, the project involved an analysis of (i)potentially high-risk financial flows to and from the region; (ii) the AML/CFT domestic and regional supervisory landscape related to banks and virtual assets; and (iii) the potential implications of financial integrity shocks on financial stability.

Nordic-Baltic Technical Assistance Project – Financial Flows Analysis, AML/CFT Supervision, and Financial Stability

Project Summary:

Nadine Schwarz

Ms. Ke Chen

Ms. Kristel Poh

Kathleen Kao

Ms. Francisca Fernando

The purpose of this note is to assist countries in their understanding and mitigation of the money laundering (ML), terror financing (TF), and financing of the proliferation of weapons of mass destruction (PF) risks related to virtual assets (VAs). This is the first of two Fintech Notes dedicated to VAs and anti-money laundering and combating the financing of terrorism (AML/CFT). This first note is broad in scope. It explains why VAs are vulnerable for misuse for ML/TF/PF purposes and clarifies which assets and service providers should be subject to AML/CFT measures. It discusses the measures that all countries should take, and the type of action necessary in instances of criminal misuse of VA. A second Fintech note focuses on the AML/CFT regulatory and supervisory framework for virtual asset service providers (VASPs). Both notes are based on Financial Action Task Force (FATF) standards and draw heavily on the FATF’s 2019 “Guidance for a Risk-Based Approach to Virtual Assets and Virtual Asset Service Providers.” They aim at providing policy makers and authorities with AML/CFT responsibilities with an overview of the legal and operational considerations that the implementation of a sound AML/CFT framework for VAs and VASPs raises. In some instances, the notes make reference to specific types of VAs, VASPs, and related products. These references are made for illustrative purposes only, and do not constitute an endorsement of the specific VAs, VASPs, and related products. Finally, at the time of drafting, no country had been assessed against the new standards and many country authorities were in the process of establishing how best to incorporate the new standards in their AML/CFT framework. For these reasons, this note does not refer to specific country examples.

Some Legal and Practical Considerations

Virtual Assets and Anti-Money Laundering and Combating the Financing of Terrorism (1)

Ms. Grace Jackson

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