5.1. Disconnect from, or misalignments with, the NRA
119. National Risk Assessments (NRAs) are intended to inform the national AML/CFT policy and strategies and implementation of a risk-based approach to both AML/CFT regulation and supervision. They provide a point in time view of the risks of ML/TF that the country is exposed to. NRAs should be regularly reviewed and kept up to date. If the ML/TF risks at national or sectoral level are not assessed comprehensively, or there is a disconnect or misalignment between the NRA findings and the AML/CFT supervision framework, AML/CFT supervision cannot be effectively risk-based. For example, while working on the design and development of risk-based AML/CFT supervisory frameworks, some jurisdictions have noticed gaps and deficiencies in their NRAs, as the NRAs did not comprehensively identify all the ML/TF risks or provide the necessary insights and information on the risks. This has led these jurisdictions to revisit their NRAs and supplement them with additional analysis, particularly on sectoral risks. Another example of possible issues in NRAs is the lack of information on medium-risk and low-risk areas/sectors, and ML/TF risks in the DNFBP sectors, which are also essential for effective risk-based approach to AML/CFT supervision. The NRA and the SRA do not have align perfectly in terms of risk scoring etc., but there should be a general coherence between the findings of both assessments.
120. Strategies to address this challenge: