2011年-IMF国际货币组织全球_Anti_97页_1mb

Summary of the IMF AML/CFT Program Review

Core Content

The International Monetary Fund (IMF) has significantly contributed to the global effort to combat money laundering and the financing of terrorism (AML/CFT) over the past decade. This report reviews the evolution and effectiveness of the IMF's AML/CFT program, focusing on assessments and technical assistance, and outlines future directions for the program.

The AML/CFT program includes assessments under the ROSC (Regional Surveillance and Country Assessment) and FSAP (Financial Sector Assessment Program), as well as the provision of technical assistance and research. The program has become more strategic and is now primarily funded by external resources, with the establishment of the AML/CFT Topical Trust Fund (TTF) in 2009 playing a central role.

Main Points

AML/CFT Assessments

• Comprehensiveness and Scope: The FATF AML/CFT standard is broad and includes a wide range of issues such as financial sector regulation, criminal law, and international cooperation. The assessments are detailed and cover over 285 criteria, often resulting in reports exceeding 300 pages.
• Compliance Levels: Compliance with the FATF standard is generally low, with only 12.3% of assessed countries achieving full compliance. Countries with higher income levels and better regulatory frameworks tend to perform better.
• Cost and Time: Conducting an AML/CFT assessment is time-consuming and expensive. The average cost for an IMF assessment is around $310,000, although the burden-sharing model with the World Bank and other assessors has reduced this cost to about $112,000 per assessment.
• Burden Sharing: The IMF collaborates with the World Bank, FATF, and FSRBs (FATF-style regional bodies) to share the burden of assessments. This model has generally worked well, but inconsistencies in the quality of assessment reports have been noted.

Technical Assistance (TA)

• Shift to External Funding: The IMF's TA program has transitioned from internal funding to external funding, largely due to the AML/CFT TTF. This fund is supported by 12 donors and has provided significant resources for TA activities.
• Strategic Focus: The TTF supports a four-pronged strategy for TA delivery, including long-term planning, regional and country strategies, use of external resources, and combining staff expertise with field experts.
• Successes and Challenges: The TA program has had notable successes, such as the project in Thailand. However, challenges remain in aligning donor priorities with IMF objectives and ensuring internal commitment to the program.

Key Issues for the Future

1. Risk-Focused AML/CFT Assessments

• The paper proposes a shift from comprehensive assessments to risk-focused ones, which would allow for more targeted evaluations of countries with the highest risk of money laundering or terrorist financing.
• This approach would align AML/CFT assessments with other standards and make the process more cost-effective.
• The Executive Board of the IMF and the World Bank may consider revising the current policy requiring all FSAPs to include AML/CFT components.

2. Criteria for AML/CFT Risk Assessment

• The paper suggests establishing criteria to determine when AML/CFT issues may affect financial or external stability.
• These criteria would consider the member's circumstances, including the relative importance of AML/CFT versus other issues, and the potential spillover effects on other members.
• These criteria would guide Article IV surveillance and modular financial stability assessments.

Conclusion

The AML/CFT program has evolved significantly, becoming more strategic and reliant on external funding. While it has achieved notable successes, challenges remain in terms of compliance, cost, and the effectiveness of assessments. Moving forward, the IMF should consider adopting a risk-focused approach to assessments and establishing clear criteria for determining when AML/CFT issues pose a threat to financial stability. This would enhance the program's relevance, efficiency, and alignment with international standards.