The Swiss Financial Market Supervisory Authority FINMA has once again reviewed numerous money laundering risk analyses and is supplementing Guidance 05/2023 with further observations and insights for both banks and FinIA institutions. In doing so, it recognised the progress made, but also identified further room for improvement.
Since Guidance 05/2023 was published, FINMA has re-examined some of the risk analyses of over 30 banks inspected in spring 2023 and analysed the risk analyses of numerous other banks and FinIA institutions. In doing so, it concluded that the banks had made progress in defining their risk tolerance and in structuring their risk analysis. It also noted that some FinIA institutions are already applying aspects of Guidance 05/2023 by analogy. For these institutions, the methodological principles governing the preparation of risk analyses are just as applicable as they are for banks. However, the level of detail may vary, as these institutions generally face lower risks.
FINMA identified further room for improvement at both banks and FinIA institutions, so that risk analysis can serve as an even more effective key control and management tool for combating money laundering. In some cases, there were no explicit exclusions of certain countries, client segments, services and/or products, or these did not align sufficiently with the institution’s business model. Furthermore, there was a failure to apply methodological principles correctly when carrying out the risk analysis.
The money laundering risk analysis is a key tool for the strategic management of a financial institution and forms the basis of its risk management. It defines the risk tolerance and sets out the binding guidelines for the structure, organisation and day-to-day management of the anti-money laundering framework. In this way, it ensures that resources, processes and controls are designed with a focus on risk and that regulatory requirements can be effectively met.
