The Financial Action Task Force (FATF) published in June 2019 a “Guidance for a Risk-Based Approach for Trust and Company Services Providers” (FATF Guidance). The FATF Guidance can be found at the FATF website: .
2 The FATF Guidance supports the implementation of a risk-based approach and provides specific guidance for the trust and company service providers (TCSP)
3 The FATF Guidance outlines the key elements involved in applying the RBA, including the need for TCSPs to have sound ML/TF risk assessment, examples of risk factors, the design of policies and procedures to ensure that due diligence measures effectively address ML/TF risk exposures at onboarding and ongoing monitoring, and the extent to which TCSPs should identify and verify beneficial owners of their customers. Given the wide range of TCSP customers with different trust and corporate structures, the FATF Guidance also provides examples of standard, simplified and enhanced CDD measures based on the ML/TF risk of the TCSP customers and structures.