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SFMA adds guidance on money laundering risk analysis

SFMA has reviewed numerous money laundering risk analyses again and has added observations to Guidance 05/2023 for banks and FinIA institutions.

SFMA has again assessed a wide range of money laundering risk analyses and has supplemented Guidance 05/2023 with further observations for banks and FinIA institutions. The review recognised progress, while also showing where institutions can make the analysis more effective.

After Guidance 05/2023 was published, SFMA rechecked selected risk analyses from more than 30 banks inspected in spring 2023 and examined analyses from other banks and FinIA institutions. Banks had improved the way they define risk tolerance and structure risk analysis. Some FinIA institutions were already applying parts of the earlier guidance by analogy.

The methodological principles for preparing risk analyses are relevant for these institutions too, although the required level of detail can differ because their risk exposure is generally lower.

SFMA still found areas needing improvement. Some institutions did not clearly exclude specific countries, client groups, services or products, or the exclusions did not fit the business model closely enough. In other cases, methodological principles were not applied consistently when the risk analysis was prepared.

A money laundering risk analysis is a central management tool. It defines risk tolerance, sets binding direction for the anti-money laundering framework and helps ensure that resources, processes and controls are aligned with the institution's risks and legal duties.