FINMA publishes guidance on money laundering risk analysis

28 August 2023
Knowledge Base

The Swiss Financial Market Supervisory Authority (FINMA) has on 24 August published guidance on the money laundering risk analysis. By doing so, it is creating transparency about its observations and experiences gained from supervisory practice in this area. FINMA has repeatedly identified shortcomings in the area of the money laundering risk analysis during on-site supervisory reviews. This prompted it to conduct an in-depth review of the money laundering risk analyses of more than thirty banks in spring 2023.

This revealed that many of the risk analyses examined did not meet the requirements. For example, an adequate definition of the money laundering risk tolerance, i.e. set limits to reduce risks, was lacking in some cases. Furthermore, a lack of various structural elements that are required for an effective and robust risk analysis could be observed.

The money laundering risk analysis is an important tool for the strategic management of banks and other financial intermediaries. They use this to identify and mitigate the risks in the area of money laundering and determine the relevant risk criteria for the financial institution’s activities. The money laundering risk analysis also stipulates which money laundering risks are not within the institution’s risk tolerance.

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