Regulation Around the World – Issue 19: Anti-money laundering

In this latest edition of Regulation Around the World, we examine the anti-money laundering and counter-terrorist financing (AML/CFT) landscape through the lens of eight questions, drawing on insights from Norton Rose Fulbright practitioners across our global network.

The questions are:

1. What are the most significant recent or forthcoming changes to your jurisdiction’s AML/CFT framework, and how are they expected to affect compliance programmes for regulated entities?
2. Are there any areas where local AML/CFT requirements diverge materially from international standards (e.g. FATF Recommendations or, where applicable, EU Anti-Money Laundering Directives), and what practical implications does this have for multinational businesses?
3. How does your local supervisory authority approach risk-based supervision of AML/CFT obligations in practice, and what sectors or risk areas has it identified as current priorities?
4. What is your supervisory authority’s practical stance on the use of new technologies — such as AI-driven transaction monitoring, digital identity verification, or blockchain analytics — within AML/CFT compliance programmes? Has it issued any specific guidance or expectations in this area?
5. How does your jurisdiction approach AML/CFT obligations in the context of virtual assets, decentralised finance, and other emerging financial products or services, and are there areas where regulatory expectations remain unclear or are evolving?
6. What are the key challenges and regulatory expectations around beneficial ownership transparency in your jurisdiction, particularly in relation to complex corporate structures, trusts, and nominee arrangements?
7. What is your supervisory authority’s approach to de-risking — that is, the wholesale termination or restriction of business relationships with entire categories of customers (such as money service businesses, correspondent banking relationships, or non-profit organisations)? Has the authority issued any guidance discouraging blanket de-risking, and how does it expect firms to balance financial inclusion objectives against AML/CFT risk management?
8. What are the practical expectations for group-wide AML/CFT compliance programmes operating across borders, and what challenges arise in your jurisdiction around reliance on third-party or group-level due diligence, information sharing within corporate groups, and managing conflicting regulatory requirements?

Read the full update here.