Measuring Effectiveness:
How the VI would be assessed
Issues that will be considered
•
Extent to which FIs and DNFBPs meet reporting
obligations on suspected proceeds of crime and TF
•
How well FIs and DNFBPs:
•
Understand their ML/TF risks and obligations
•
Apply mitigating measures commensurate with their risks
•
Apply CDD and record keeping measures, and extent to
which business is refused when CDD is incomplete
