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Version date: 4 March 2021 - onwards

6.7. Lack of clarity in the division of supervisory roles and responsibilities

150. In many jurisdictions, there is a lack of clarity in the division of the labour and responsibilities between AML/CFT supervisory authorities, particularly between the FIU and the other supervisors but also between prudential and AML/CFT supervisors or AML/CFT supervisors that are responsible for the AML/CFT supervision of different aspects of the same entity's activities. In those cases, it is not always clear which agency has the primary role and responsibility for AML/CFT supervision.

151. Strategies to address this challenge:

Ideally, the law should clearly identify which agency has the primary responsibility of AML/CFT supervision of a sector. To this end, any ambiguities in the laws should be addressed, and the overlaps and conflicts between AML/CFT laws and sectoral supervision laws should be examined and eliminated, as necessary. In addition, as appropriate, memoranda of understandings can help define the respective roles the authorities and the principles for collaboration and information sharing among them. Such arrangements and clear division of AML/CFT supervision roles and responsibilities becomes particularly essential when a multinational authority and/or a federal authority have AML/CFT supervisory responsibilities over domestic or local entities.

Set up mechanisms to ensure co-operation and a consistent approach between those agencies and ensure that information flows freely and in a timely manner.