141. There may be a lack of, or inadequately trained staff, to conduct a proper risk-based supervision. Teams conducting AML/CFT supervision may be new or covering new sectors or AML/CFT responsibilities newly assigned to existing regulators. There may be a lack of supervisory tools and technologies.

142. Strategies to address this challenge:

• Allocate the limited supervisory resources based on sector's/entities' risks in an effective manner. In allocating resources, based on the outcome-focused approach (See Section 3.4), supervisors should focus not only on the headcount but also the capability and training of the AML/CFT staff.

• Ensure that there is requisite senior management support and buy in within the supervisory body. Use the results of the risk assessment to secure additional resources by demonstrating the risks that remain unmitigated. For those who are part of a larger agency, consider designating specific resources for AML/CFT to build expertise and support other supervisory staff. If staff lack AML/CFT expertise, or expertise in relation to a particular sector, develop strategies to build capacity and consider appropriate use of other experts. Consider seconding staff from more experienced AML/CFT supervisory authorities to transfer knowledge and expertise. Consider appropriate use of third parties or consultants as an interim measure (see section 4.3 for more detail).