Lessons Learned from the Fourth Round of Mutual Evaluations

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This Policy Brief examines the common challenges of the mutual evaluation process and provides recommendations for jurisdictions, the FATF and FATF-style regional bodies to improve the next round.

In February 2022, the Financial Action Taskforce (FATF) – the global standard setter for countering money laundering, terrorist financing and proliferation financing – will conclude its Strategic Review. The Strategic Review is an exercise which analyses what can be learned from the latest, fourth round of mutual evaluations and considers what could be improved ahead of the fifth round, which is due to start in 2025.

As the FATF undertakes its own evaluation of this process via the Strategic Review, the authors of this Policy Brief have sought to conduct a complementary exercise. They have set out to consider whether jurisdictions experience common practical challenges during the ME process, how they impact the outcome of their ME and whether these challenges can be overcome to ensure that they do not distract from the ME’s core purpose – determining the effectiveness of a jurisdiction’s anti-financial crime regime. In doing so, they hope to supplement the study undertaken by the FATF and demonstrate that in addition to being a technical exercise, the ME is also a practical one.


Isabella Chase

Associate Fellow; Former CFCS Senior Research Fellow, RUSI

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Maria Sofia Reiser

Former Research Analyst

Centre for Financial Crime and Security Studies

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