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Version date: 4 March 2021 - onwards

3.6. How can supervisors develop a more robust risk-based approach over time?

76. Supervisors should ensure that their supervisory strategies are kept under regular review. In implementing the strategy, supervisors will develop a better understanding of the quality of the supervised entities' AML/CFT controls and the ML/TF risk profiles of the business models, as well as the effectiveness of various supervisory tools. This knowledge should be utilised to enhance the overall ML/TF risk understanding at both the sectoral and the individual entity levels along with consideration of any new/emerging ML/TF risks. Building and maintaining the institutional memory is key to achieve this.

77. Further, supervisory authorities should use the experience garnered from carrying out supervisory tasks to enhance the effectiveness of their supervisory strategies and to continuously refine and enhance these methods. In addition, on an ongoing basis, the risk assessment (along with supervisory planning process) should not be conducted in isolation, but in close co-ordination with prudential supervision and other relevant departments (or other supervisors). Any changes to the ML/TF risk understanding and/or proposals for refinement or enhancement of the mix of supervisory tools to be applied should be considered in the context of the review of the overall strategy with the aim of continuing to improve and strengthen the supervisory approach to ensure it remains effective.