2008年-IMF国际货币组织全球_Offshore_Financial_Centers_35页_649kb

Summary of the IMF Offshore Financial Centers (OFC) Program and Proposal for Integration with the Financial Sector Assessment Program (FSAP)

Core Content

The International Monetary Fund (IMF) has been conducting assessments of Offshore Financial Centers (OFCs) since 2000, in response to concerns about financial supervision weaknesses and lack of transparency in these centers. The OFC program has evolved through three phases, with the second phase beginning in 2005. The report proposes integrating the OFC program with the Financial Sector Assessment Program (FSAP) to enhance financial surveillance and resource allocation.

Main Points

1. Program Overview

• The OFC program was initiated in 2000 following concerns from the Financial Stability Forum (FSF) about the lack of information and weak supervision in OFCs.
• The program involves three modules:
  • Module 1: Self-assessments with external expert support.
  • Module 2: Stand-alone assessments of compliance with international standards (Basel Core Principles, IAIS, IOSCO, and FATF 40+9).
  • Module 3: Comprehensive assessments of risks and vulnerabilities, similar to FSAP.

2. Progress in the Second Phase

• By 2008, 13 second-phase assessments had been completed, with three in progress.
• Most jurisdictions have published their assessment reports, with 9 of the 13 having published main reports (FSSAs and AFSSRs).
• Compliance with prudential standards (Basel, IAIS, and IOSCO) has improved, particularly in high-income OFCs.
• AML/CFT compliance remains a concern, with OFCs showing relatively low levels in areas such as customer identification and international cooperation.

3. Transparency Efforts

• The Information Framework Initiative was launched in 2004 to standardize data collection.
• 28 jurisdictions have submitted data, with 7 indicating intent to participate but not yet submitting, and 3 still to confirm participation.
• The initiative complements the Coordinated Portfolio Investment Survey (CPIS) and provides valuable data for cross-country comparisons.

4. Technical Assistance

• Technical assistance (TA) has been provided to 37 jurisdictions, mostly middle-income.
• TA has focused on bank supervision, AML/CFT, and the governance of supervisory bodies.
• The assistance has been delivered through regional centers and supported by donor governments and agencies like the JSA.

5. Cooperation with Other Agencies

• The IMF has collaborated with the FSF's Offshore Review Group and IOSCO to improve cooperation and information exchange.
• The Fund has also worked with FATF and FSRBs to coordinate AML/CFT assessments and strengthen their capacity.

Key Information

6. Case for Integration

• Risk-Based Approach: Integration would allow for a more uniform and risk-based approach to financial sector surveillance, improving coordination across jurisdictions.
• Resource Allocation: It would enable more efficient allocation of resources, focusing on the small number of OFCs that account for most offshore activity.
• Elimination of Discrimination: Maintaining a separate OFC list is potentially discriminatory and outdated. Integration would reduce stigma and promote a more inclusive approach.
• Systemic Risks: Integration would ensure that systemic risks are considered in assessments, especially for jurisdictions with significant cross-border financial flows.
• Operational and Budgetary Implications: Integration would require careful planning to align the assessment cycles and budget allocations.

Operational Considerations

• Integration would involve aligning the OFC program with the broader FSAP framework, which includes a wider range of issues related to financial stability and systemic risks.
• It would also require a more refined prioritization process based on systemic importance and vulnerability rather than a mechanical approach.
• Coordination with standard-setters and supervisors would be essential to maintain consistency and improve information exchange.

Budgetary Implications

• The report notes that the estimated annual cost of OFC assessments is comparable to Module 2 assessments.
• Integration would help optimize resource use by aligning the assessment cycle and focus with the FSAP, which is more resource-efficient.

Issues for Discussion

• The need to maintain a separate OFC list is questioned due to its potential for discrimination.
• The effectiveness of the current AML/CFT assessments and the need for further improvements.
• The feasibility of integrating the OFC program with the FSAP in terms of operational and budgetary logistics.
• The importance of continued technical assistance and cooperation with other agencies.

Conclusion

The OFC program has made progress in improving compliance and transparency, but integration with the FSAP is proposed to enhance the effectiveness of financial surveillance, reduce stigma, and better align with international standards. This integration would require careful planning and coordination to ensure that all jurisdictions, including OFCs, are assessed based on their systemic importance and vulnerability.