Think of the National Risk Assessment or NRA for short, as the operating system for a country’s AML/Compliance strategy. The FATF 2025 guidance tells governments (and by extension FIUs, supervisors, and obliged entities) how to organise the right people, collect the right data, and assess threats and vulnerabilities. It also says how to rate inherent vs. residual risk, and hard-wire the results into laws, supervision, budgets, and outreach.
Done well, it’s a living cycle and not jsut a five-year PDF. Guess what? That’s exactly how you turn risk talk into real fincrime outcomes.
When “more STRs” equals “better AML,” quality suffers and FIUs drown.
The 7 High-Impact Pitfalls to Watch
- Politicisation risk
High-level commitment is great until it nudges ratings toward a pre-agreed narrative. Two signals to watch are sudden downgrades of sensitive sectors just before evaluations, and unexplained edits that flatten dissenting views. - Resource drag & box-ticking
Continuous cycles, deep dives, and data stacks demand capacity. If you don’t have it, the NRA can devolve into pretty heat-maps with soft evidence, soaking time and money that should target real money laundering risks. - False precision from scoring workshops
Heat-maps and consensus scoring look scientific and they’re not, unless assumptions and data gaps are explicit. When everyone compromises to amber, supervision loses the sharp edge that risk-based approaches need. - Goodhart’s Law on STR/SAR metrics
When “more STRs” equals “better AML,” quality suffers and FIUs drown. Calibrate for actionable, well-narrated reports and measure hit-rates, not just volumes—yes, you guessed it, quantity without impact is theatre. - De-risking ricochet
Focusing on higher risk approach can become exit messy customers and corridors entirely. That hurts financial inclusion and pushes flows to informal rails where detection is worse and harm is higher. - Publication knife-edge
Release too little and the private sector can’t recalibrate controls and release too much and criminals get a roadmap. Your comms plan must split public narratives from restricted indicators, or you’ll pay for it later. - Data-sharing vs. privacy and security
Yes, cross-agency datasets and Memorandum of Understandings unlock insights but also widen the attack surface. Weak legal bases, uneven cyber hygiene, and unclear access logs can turn the NRA data lake into a liability.
Additionally mentioned in the document were outsourcing-by-stealth, hype cycles (AI and crypto overshadowing) path dependence from the initial “environment scan,” conflicting sectoral vs. supranational ratings, green lanes that attract abuse, and vendor lock-in can all amplify the risks above.
From Assessment to Action: Keep It Honest and Useful
Treat the NRA like a management system, not a report. Publish a plain-English methodology, keep minority notes, and pair output metrics like STR quality, supervisory actions with outcome metrics like FIU hit-rates and asset recovery. Build “anti-de-risking” checks before you tighten controls; design early-warning tripwires wherever you simplify. Guess what? That’s how you keep the guidance honest, the ecosystem aligned, and the bad guys uncomfortable.
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