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Version date: 4 March 2021 - onwards

3.1. What is a supervisory strategy?

55. A supervisory strategy sets clear objectives for AML/CFT supervision, explains how supervisors will address the ML/TF risks they have identified across their sector(s) and how they will respond to emerging risks [In developing such strategies, supervisory authorities should ensure that there is an understanding of broader supervisory considerations. For example, authorities should share information and communicate with prudential or other relevant supervisors regularly to ensure that any areas of concern are raised and incorporated into the supervisory plan (as required) and that there is a shared awareness of the respective supervisory programs (planned inspections, desk-based reviews, etc.).]. The strategy should not only focus on the highest risk entities or sectors, but should also set out adequate supervisory coverage (including monitoring where relevant) of all entities or sectors, including those associated with lower ML/TF risks. The supervisory strategy sets out the approach the supervisor will take in applying its tools to address the risks identified. The strategy and the output of the risk assessment are used to plan supervisory activity (commonly including 12 or 24 month supervision or inspection plans). In some cases, supervisors may include inspection plans in their strategy, however a supervision strategy should set out how the supervisor will address each category of risk, including how other non-inspection supervisory tools will be employed to address risks. Importantly, the strategy should also address the information, support and guidance the supervisor plans to provide regulated entities to address identified risks. The supervisory strategy is developed in line with the supervisory risk assessment and should be revised as needed.