FATF’s 2025 NRA part.2: Ways to Turn the FATF NRA into a Real AML Advantage

This is the second part of article FATF’s 2025 NRA part.1: What It Is and the Biggest Ways It Can Go Sideways. If you haven’t read that one, we invite you to check it out.

In the previous article, we walked through the FATF’s 2025 National Risk Assessment or NRA guidance and put on a sceptic’s hat. We flagged the big threats like politicisation, resource drain, spurious precision, de-risking, publication risks, privacy issues, and metrics that reward volume over impact. It wasn’t all doom and gloom, but let’s be honest here… there were plenty of traps.

This time, let’s flip it. Let’s look at the opportunities inside the same framework and more importantly, how to turn those into strengths. Because the truth is, the NRA doesn’t have to be a box-ticking exercise. Done right, it’s a lever to sharpen AML/Compliance, empower FIUs, and actually disrupt financial crime.

Guess what? Most of the things we worried about last time are also the tools that can make the system stronger—if you set them up right.

When the FATF National Risk Assessment becomes your country’s operating system, strategic clarity emerges: budgets move, supervision aligns, FIU tasking sharpens, and private-sector controls point at the right problems.

AML campaign guided by NRA priorities
Regulators and compliance leads reviewing typologies, KPIs, and quarterly actions derived from the National Risk Assessment

The 6 Moves That Actually Change Outcomes

  1. Lock in independence with a published method
    Write a short and public methodology such as data sources, how you rate inherent vs. residual risk, and how disagreements are recorded. When sunlight hits the method, politicisation and false consensus drop fast and yes, transparency is a performance tool.
  2. Balance output and outcome KPIs
    Track STR quality (and not just count), FIU hit-rates, priority cases opened, and asset-recovery realised. Teams deliver what you measure and a balanced scorecard keeps Compliance effort tied to crime impact, not slideware.
  3. De-risking guardrails by design
    Before turning the dial on high-risk sectors and corridors, run inclusion and displacement tests. If you simplify in lower-risk niches, add tripwires (velocity spikes, mule clusters, merchant rings) so “green lanes” don’t become autobahns. Yes, you guessed it -> smart simplification beats blanket exits.
  4. Smarter transparency & targeted outreach
    Publish a decision-useful public NRA, for example, risk narratives, red flags, sector priorities and keep sensitive indicators in a restricted annex. Hold sector briefings for banks, VASPs, DNFBPs, and fintechs so compliance teams can actually recalibrate.
  5. A small, ruthless “NRA data hub”
    Stand up a version-controlled store where national, sectoral, sub-national, and supranational findings live together. Tag each rating with provenance (“who, when, method”). If that’s done correctly it’ll resolve conflicts quickly and update without a full reboot.
  6. Coordinated supervisory campaigns
    Translate priorities into quarter-long, multi-agency plans (banks + PIs + real estate + TCSPs) against one typology at a time. Shared sampling, feedback memos, and aligned messaging generate fewer mixed signals and probably even more fincrime disruption.

Additionally, there are other opportunities that are worth mentioning like horizon scanning without hype (rank threats by magnitude and tractability), smarter vendor procurement, quarterly sectoral deep dives, and tighter LEA alignment all round out the opportunity set etc. But not to make this post too long, you can always reference the source material – FATF National Risk Assessment toolkit.

From Assessment to Action

How to Make the NRA Work fo You? When the FATF NRA becomes your country’s operating system, strategic clarity emerges: budgets move, supervision aligns, FIU tasking sharpens, and private-sector controls point at the right problems. Make dissent visible, data reusable, and KPIs about impact and not only effort. And yes, that’s how you convert a guidance document into better cases, better recoveries, and fewer blind spots.

Source: https://www.fatf-gafi.org/en/publications/Fatfgeneral/FATF-launches-National-Risk-Assessment-toolkit-to-help-countries-identify-greatest-money-laundering-risks.html

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