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FATF’s National Risk Assessment Toolkit

October 1, 2025

FATF

On 28 August 2025, the Financial Action Task Force (FATF) unveiled a major new resource to help countries identify, assess, and manage their risk of money laundering (ML). This is the Money Laundering National Risk Assessment (NRA) Toolkit, designed to support nations in applying the FATF Standards more effectively and in a risk-based manner.

In today’s globally connected financial landscape, illicit flows of money, whether from corruption, fraud, drug trafficking, or other predicate offences are rapidly evolving. FATF’s toolkit aspires to give governments, regulators, the private sector, and other stakeholders better instruments to confront these complex challenges.

The Need of this Toolkit

The FATF emphasises that crime generates vast illicit revenues every year, running into the trillions of U.S. dollars. When laundered, those funds enable criminals to reinvest in more wrongdoing, erode trust in institutions, distort economies, and undermine both national and international security.

The Role of National Risk Assessments (NRAs)

A National Risk Assessment is not just a theoretical exercise. It is a structured, evidence-based process through which a country systematically evaluates its threats, its vulnerabilities, and then uses that understanding to decide where to focus resources and regulatory controls. The FATF’s Standards expect countries to take such a risk-based approach.

The Components of the Toolkit

The toolkit packs a range of features intended to help jurisdictions make NRAs more practical, richer in insight, and more aligned with global best practices.

Some of its key components include:

  • Cross-country insights

The toolkit includes data and examples across nations: estimated proceeds of crime, common predicate offences (i.e. types of underlying crimes whose proceeds are laundered), and typologies of ML both domestically and across borders. This helps countries benchmark their own situation and understand how global or regional trends may affect them.

  • Four priority risk areas

FATF has chosen four domains which often pose particular challenges in risk assessment, either because data is limited, the risks evolve quickly, or they cross multiple domains. These are:

  • Corruption
  • Virtual Assets and Virtual Asset Service Providers (VASPs)
  • Legal persons and legal arrangements (e.g. companies, trusts, shell companies)
  • The informal economy (cash-based, non-formal, or unregulated sectors)

  • Good practices and examples

The toolkit doesn’t just give guidance; it also provides real-world examples of how jurisdictions have handled tricky risk areas, including how to assess beneficial ownership, how to evaluate risks from virtual assets, and how to approach the informal economy. These case studies are meant to help countries overcome common challenges.

  • Quick guides / Annexes

To make the toolkit more usable, FATF has included quick guides (Annexes A-C) – these are tools for dealing with specific challenging risk areas. They help countries identify gaps in data, design risk assessment models, and plan mitigation actions.

  • Updated Guidance

Alongside the toolkit, FATF has updated its National Risk Assessment Guidance, taking into account recent amendments to FATF’s Standards (especially Recommendation 1) and the updated Guidance on Financial Inclusion and AML/CFT measures. The updated guidance helps ensure that the toolkit and related policies are consistent with FATF’s evolving expectations.

Application of the Toolkit

The toolkit is meant to be flexible and adaptable. It can be used for:

  • Full national assessments (NRAs), covering all sectors and risk-types in a country.
  • Sectorial or thematic risk assessments, for example focusing just on virtual assets, or on informal economy sectors in a particular region.
  • Supporting work in regulatory reform, e.g. where governments need to enhance legal frameworks, oversight mechanisms, etc.

A successful NRA (with the help of this toolkit) generally involves several stages:

  • Preparation and setup, including getting political commitment, identifying the actors involved (government bodies, private sector, other stakeholders), defining objectives, collecting relevant data.
  • Threats and vulnerabilities assessment, evaluating which predicate crimes are most prevalent, how illicit funds move, what legal entities and arrangements might mask beneficial ownership, etc.
  • Risk analysis, combining threats + vulnerabilities to understand how and where money laundering is most likely or most harmful.
  • Mitigation planning, designing policies, regulations, supervision, law enforcement, financial intelligence units, customs/border controls, etc., to reduce risks.
  • Communication and monitoring, making sure findings are shared, relevant parties understand them, and the NRA is updated periodically.

Implications and Benefits

What difference can using this toolkit make? Here are several of the likely effects:

  • More targeted policies
  • Enhanced international cooperation
  • Improved regulatory compliance and standard alignment
  • Private sector awareness and engagement
  • Transparency and accountability

Potential Limitations and Considerations

While the toolkit is a major advance, there are several challenges or caveats to its application:

  • Data limitations
  • Capacity constraints
  • Rapidly changing typologies
  • Balancing regulation with development / inclusion

Fitting into FATF’s Broader Strategy

The launch of the toolkit is part of wider ongoing reforms and updates by FATF:

  • FATF recently adopted amendments to Recommendation 1, which deals with the risk-based approach itself. The updated guidance helps clarify expectations for jurisdictions in how to apply risk assessments.
  • FATF has also updated guidance related to financial inclusion and AML/CFT measures, aiming to ensure that measures to fight money laundering do not hinder access to financial services for legitimate users.

The toolkit complements recent mutual evaluation processes and peer reviews, which increasingly look not just at whether rules exist, but how well a country understands its risks and acts upon them. Countries with weak risk assessments are more likely to be identified with strategic deficiencies.

What Comes Next for Countries

To benefit fully from FATF’s NRA Toolkit, countries will likely need to undertake several actions:

  • Political commitment should be mobilised
  • Data collection efforts must be strengthened
  • Stakeholder involvement
  • Re-design mitigation strategies
  • Monitoring, evaluation, and updating the assessments periodically to adapt to changes (new technologies, new types of crime, shifting economic conditions).
  • Enhance proper transparency and reporting keeping the trends in mind.

The FATF’s “Money Laundering National Risk Assessment Toolkit” represents a pivotal step forward in enabling countries to see clearly where their greatest money laundering threats lie, and to respond more precisely. It builds on existing guidance and recent updates to FATF standards, while placing special focus on areas that often pose difficulties such as corruption, virtual assets, legal persons/arrangements, and the informal economy.

In an age when financial crime is increasingly transnational, technologically sophisticated, and adaptive, tools that allow better risk understanding are indispensable. While the success of this toolkit will depend heavily on political will, resource allocation, data availability, and collaboration, its design makes it well suited to helping countries strengthen their AML/CFT regimes in meaningful and measurable ways.

If governments use this toolkit well, integrating its findings into regulation, oversight, law enforcement, and public policy, the result should be a more resilient global system that makes it harder for illicit money to hide, move, or corrupt institutions.

To navigate to the official website, click here.

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