Across recent FATF mutual evaluations — Malaysia, Kuwait, and Belgium among them — the same pattern keeps surfacing: strong legal frameworks exist on paper, but effectiveness is rated only moderate once assessors look at implementation. A risk assessment that reads well but that staff can't explain, a beneficial ownership register that relies on customer declarations, or suspicious activity reports filed defensively rather than analytically — all of these are the specific gaps inspections and mutual evaluations are now designed to find.
That shift applies whether the review in question is a Central Bank of Barbados or Financial Services Commission inspection, a FINTRAC examination, or a full FATF/CFATF mutual evaluation. Preparation that starts once a date is confirmed is preparation that starts too late — effectiveness has to be built and evidenced over time, not assembled in the weeks before assessors arrive.
We built our audit and inspection preparation work directly around this shift, informed by our own ongoing analysis of what FATF assessors are finding across recent reviews.
