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hermes-brain/ideas/compliance/fatf.org
2026-05-23 06:35:21 +00:00

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:PROPERTIES:
:ID: auto-fatf
:CREATED: [2026-05-23 Sat]
:END:
#+title: risk-weight mapping correctness. A $100K/yr Basel gate package for a G-SIB
#+filetags: :passepartout:compliance:framework:fatf:
risk-weight mapping correctness. A $100K/yr Basel gate package for a G-SIB
is a trivial expense relative to the capital requirement penalty of getting the
mapping wrong.
** FATF (Financial Action Task Force) — AML/CFT Standards
International standard-setter for anti-money laundering and counter-terrorism
financing. 40 Recommendations covering: risk assessment, customer due diligence
(CDD), beneficial ownership transparency, suspicious transaction reporting,
targeted financial sanctions, proliferation financing. National implementation
varies by jurisdiction.
Who must comply: Financial institutions, DNFBPs (designated non-financial
businesses and professions), virtual asset service providers (VASPs). In
practice: every bank, money service business, crypto exchange, and high-value
dealer globally.
Penalties: National enforcement varies. Systemic failures lead to FATF grey-list
(monitoring) or black-list (counter-measures). Grey-listing increases transaction
costs — Iran and North Korea are black-listed.
Why it matters: FATF's CDD requirements are the most widespread and
rule-complex compliance obligation globally. The gate stack can encode
tiered CDD rules, prove that every customer onboarding followed the correct
verification path, and produce an auditable trail for every suspicion