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Mutual evaluation preparation, follow-up support & action plans

  • Mutual evaluations are the cornerstone of efforts to combat ML/TF. They are the main tool to identify shortcomings within domestic legal and institutional frameworks.

  • The new round of mutual evaluations will place an even greater focus on assessing effectiveness of implementation of the FATF Standards. There will also be a greater emphasis on major risks and context. Ensuring that a jurisdiction’s preparation is adequately aligned to their specific risks will be critical.

  • An effectiveness assessment differs fundamentally from the assessment of technical compliance. It seeks to assess the adequacy of the implementation of the FATF Standards and identify the extent to which a jurisdiction achieves a defined set of outcomes central to a robust AML/CFT/CPF system. The focus of an effectiveness assessment is therefore on the extent to which the legal and institutional framework of a jurisdiction is producing the expected results.

  • Recommendations in mutual evaluation reports in the new round will be more results orientated.

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About this service

  • Training stakeholders and raising awareness of the mutual evaluation process.
  • Assisting with preparation of technical compliance and effectiveness questionnaires, and other jurisdiction reporting templates.
  • Preparing competent authorities and private sector entities for on-site interviews.
  • Developing action plans to address mutual evaluation recommendations.
  • Providing strategic advice at national coordination meetings.
“The 4th round of mutual evaluations thus-far show that countries have made progress for technical compliance. However, on effectiveness, just 10% of countries have effectively implemented supervisory measures”
– FATF, Report on the State of Effectiveness and Compliance with the FATF Standards (2022)
“Global financial integrity is critical for financial stability, inclusion and for peace and security. It can only be achieved through the robust and effective implementation of ML and TF standards”
– Former FATF President T. Raja Kumar (2024)
“We emphasise that AML/CFT measures, when implemented correctly and effectively, are an important defence against threats to the rule of law, to democratic governance and to the integrity of financial systems”
– Declaration of Ministers and high-level delegates of MONEYVAL members (2023)
“Effective AML/CFT/CPF regimes protect financial systems and the integrity of financial and non-financial sectors to prevent or minimise economic and social harm”
– APG Strategic and Planning Documents 2024 to 2028 (2025)
“Despite significant progress made, there continue to be gaps in effective implementation of the FATF Standards and we commit to swiftly implement measures to improve effectiveness of outcomes in tackling ML, TF and PF and we urge all jurisdictions to do so”
– Declaration of Ministers of the FATF (2024)
“Further effort is required on supervision and preventive measures, beneficial ownership transparency, investigating and prosecuting ML, and confiscating the proceeds of crime”
– Declaration of Ministers of the FATF (2024)
“When considering monitoring outcomes, it is clear that MONEYVAL members continue to encounter a number of challenges in effective implementation of the FATF Standards on combating ML/TF/PF… weaknesses remain in financial sector supervision, compliance of private entities, transparency of legal persons, money laundering convictions and confiscations, and financial sanctions for TF and PF”
– MONEYVAL Chair (2024)
“We recognise mutual evaluations as the key driving force to build domestic AML/CFT capacities. We understand that government ownership and engagement in the mutual evaluation process is a key factor and a basic and irreplaceable element of the national AML/CFT mechanism in this regard”
– Declaration of Ministers and high-level delegates of MONEYVAL members (2023)
“Supervision or monitoring of DNFBPs is generally less developed than that of financial institutions and remains a serious weakness in many countries’ AML/CFT regimes”
– FATF Methodology (2025)
Low effectiveness
0 %

Percentage of jurisdictions worldwide demonstrating low or moderate levels of effectiveness for preventing ML and TF in the private sector in the previous round.

Jurisdictions
0 %

Percentage of jurisdictions worldwide demonstrating only low or moderate levels of effectiveness on asset recovery in the previous round.

High effectiveness
0 %

Percentage of jurisdictions worldwide demonstrating high or substantial levels of effectiveness in implementing targeted financial sanctions on proliferation in the previous round.

Our Experts in Action

Meet the team leading this service

Ian Matthews
Associate Expert
Risk, Supervision, Beneficial Ownership
Ian Matthews
Associate Expert Linkedin

Ian Matthews is a legal and financial crime expert with significant experience in AML/CFT supervision, beneficial ownership, and international evaluations. A qualified solicitor (England & Wales), Ian brings a unique combination of legal drafting skill and practical regulatory insight, shaped by more than two decades of international engagement.

Ian served as Co-Chair of the FATF Evaluations and Compliance Group (2015-2020) playing a central role in shaping the global approach towards mutual evaluations and assessment. Equally, as part of the UK delegation to the FATF, he participated in both third and fourth round mutual evaluations and was seconded to the European Commission to work on the drafting of the EU’s Fourth AML Directive.

In recent years, Ian has worked closely with a wide variety of jurisdictions to improve risk-based supervision regimes, helping authorities tailor their frameworks to sector-specific risks and demonstrate tangible supervisory outcomes to assessment teams. This work has also involved acting as an expert for the IMF, being a scientific expert to MONEYVAL and working for the World Bank.

Kamal Abou El Nasr
Associate Expert
Risk, Supervision and Financial Intelligence
Kamal Abou El Nasr
Associate Expert Linkedin

Kamal Abou El Nasr is a seasoned financial crime and compliance expert with over 20 years of experience with notable skills in risk, supervision and financial intelligence.

Throughout his career, he has held significant leadership roles in both the public and private sectors, including within financial intelligence units, major financial institutions, and regulatory bodies.

As a FATF/MENAFATF assessor, Kamal contributed to the UAE’s 2020 mutual evaluation and re-rating assessment, playing a critical role in regulatory compliance evaluations. He has also served as a certified trainer and keynote speaker, leading international workshops on risk-based supervision, customer due diligence (CDD), enhanced due diligence (EDD), and financial investigations.

Kamal holds an MBA and CAMS certification and has been recognised for his expertise in shaping AML/CFT policies and strengthening compliance frameworks worldwide.

Julian Lamb
Associate Expert
Registries, Beneficial Ownership and Risk
Julian Lamb
Associate Expert Linkedin

Julian Lamb is a leading expert on corporate registries and beneficial ownership frameworks, with over 40 years of experience in financial regulation and digital transformation. He currently works with Governments and international bodies, including the World Bank and the EU Global Facility on AML/CFT, on the implementation of effective registry systems.

As previous Executive Director and Registrar of Companies at the Jersey Financial Services Commission (1999 – 2024), Julian led the design and full-scale digitisation of one of the world’s most advanced company registries. He was directly responsible for building Jersey’s central register of beneficial ownership, ensuring alignment with FATF Recommendations 24 and 25 through hands-on policy, legislative, and technical development.

Julian brings recent practical experience from supporting registry and transparency reforms in countries across Europe, Africa, Asia and Australasia. He is a Chartered Director, a Fellow of both the CISI and ACCA, and has received multiple international awards for innovation in registry design and implementation.

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Find out how we can help your organisation or jurisdiction navigate complex AML/CFT challenges and build robust, effective defences against financial crime.

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