- Private sector institutions, from banks and casinos to fintech and professional firms, are increasingly impacted by the evolving FATF Standards and national AML/CFT regulations. As jurisdictions strengthen their legal frameworks and enforcement, expectations have risen for the private sector’s risk understanding and compliance practices.
- Recent evaluations show that weaknesses in preventive measures and private-sector implementation of FATF Standards continue to impede overall effectiveness. The private sector is facing heightened obligations and heightened scrutiny.
- New FATF requirements for sectors like VASPs and stricter supervision of designated non-financial businesses and professions (DNFBPs) mean that the private sector must proactively adapt or face potential regulatory or criminal penalties. Supervisors worldwide are focusing on previously under-regulated “gatekeeper” professions (including lawyers, accountants, and trust and company service providers), and on emerging risks such as virtual assets.
- In many jurisdictions, companies can face criminal or administrative liability for offences such as ML, TF and corruption. This makes strong internal oversight and effective governance by owners and senior management critical. A robust, well-implemented compliance programme with clear internal controls not only reduces the risk of breaches but, in some jurisdictions, can even serve as a defence, demonstrating that the company took genuine steps to prevent wrongdoing.
About this service
- Advising institutions on how current and upcoming FATF requirements will apply within their jurisdiction(s), including multi-jurisdiction operations, and helping clients map out compliance strategies.
- Developing tailored ML/TF risk assessments for banks, DNFBPs, VASPs and other obliged entities, to identify vulnerabilities and prioritise mitigation measures in line with a risk-based approach.
- Assisting clients with the design of AML/CFT/CPF compliance and remediation programmes, from customer due diligence and transaction monitoring to governance, training, and audit mechanisms designed to meet international best practice and protect against corporate liability.
- Guiding clients on the interplay between AML/CFT standards and other regulatory regimes (e.g. tax transparency, anti-corruption, data protection), ensuring a holistic approach to compliance and risk management.
Prevention
The global average effectiveness of preventive measures and suspicious transaction reporting in 2024 (down from 24% in 2021) – Basel AML Index.
Number of DNFBPs
The maximum expected increase in the number of DNFBPs registering as reporting entities in Australia in 2025/2026.
ML/TF risk level
The Basel AML Index ML/TF risk level in 2023 (1 to 10 scale), reflecting corruption, transparency issues, and weak private-sector controls.
Our Experts in Action
Meet the team leading this service
Kamal Abou El Nasr
Associate Expert
Risk, Supervision and Financial Intelligence
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.
Ian Matthews
Associate Expert
Risk, Supervision, Beneficial Ownership
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.
Julian Lamb
Associate Expert
Registries, Beneficial Ownership and Risk
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.
Connect with Monere Global today
Find out how we can help your organisation or jurisdiction navigate complex AML/CFT challenges and build robust, effective defences against financial crime.