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Version date: 4 March 2021 - onwards

3.4. How can supervisors use a combination of off-site and on-site tools to strengthen their risk-based approach?

65. As set out above, there is a range of supervisory tools that supervisors can use individually or in combination to achieve the intended supervisory outcomes. These tools when used in combination could have mutually reinforcing effects in strengthening supervisory effectiveness.

66. Off-site monitoring helps keep supervisors up-to-date on the ML/TF risk landscape, inherent risk profiles of regulated entities, and potential control weaknesses in these entities. The insights gained from performing off-site monitoring would thus guide the approach and focus of supervisors' on-site reviews. For example, the results of preliminary evaluations [The relied-upon risk assessments and independent audits should properly consider and test all risk areas, including products, services, customers, delivery channels and the geographic locations in which the financial institution or DNFBP operates and conducts business, used in determining review procedures and any testing that should be performed.] can be used to tailor the nature, frequency, intensity and focus of supervision, as well as guide the supervisory authority to how to pivot attention to higher-risk areas. Effective off-site monitoring entails collecting and analysing data and information to enable ongoing monitoring of an entire sector, instead of a snapshot of one or several entities. As an example, risk surveillance (a supervisor's monitoring of relevant data and information including STR/CTR information where available) could help detect emerging risk areas in the sector being supervised, as well as indications of significant AML/CFT control issues in regulated entities.