298. Disruption to supervisory authorities and regulated entities have highlighted the importance of the risk-based approach in the context of the COVID-19 pandemic. In some cases, FATF members have continued onsite inspections or hybrid or virtual on-sites, prioritising high-risk sectors or entities. Some supervisory authorities have indicated they have provided risk-based flexibility on the filing of annual reports and other data returns and have delayed issuing new licenses, particularly for some sectors that are not permitted to operate due to lockdowns.

299. Communication, guidance and outreach has played an important role in balancing access and controls. The FATF's report on COVID-19 Risks and Policy Response s includes a range of examples at Annex B. As a further example in the context of COVID-19, banking supervisors in the United States reminded banks that offer financial services to NPOs to avoid viewing the charitable sector as a whole as presenting uniform or unacceptably high ML/TF risks [FinCEN and Federal Banking Agencies Clarify BSA Due Diligence Expectations for Charities and Non-Profit Customers]. Consistent with a risk-based approach, banks should evaluate NPOs according to their particular characteristics to determine whether they can effectively mitigate the potential ML/TF risk. Banking supervisors provided non-binding guidance of factors that banks should consider in identifying the AML/CFT risk profile of NPOs.

10.1.1. Saudi Arabia: COVID-19 Monthly Reporting and Monitoring of Financial Institution AML/CFT Control Environment