The importance of an efficient AML/CFT (Risk) Model

Since January 2020 EBA is the sole AML/CFT guardian

EU legislators and regulators are storming ahead with the fight against ML and TF via several actions on EU level. EBA now acts as the end-to-end AML/CFT guardian and enhances the Risk Factor Guidelines. Most national legislations make EU guidelines legally binding like BaFin via Guidelines and Q&As issued by the ESA or FMA via Circular FMA 3/2019. Hence implementation becomes a must have. We expect the Guidelines to become effective in January 2021.

What are the Risk Factor Guidelines about?

The Guidelines define how financial institutions have to identify and assess their ML and TF risks at a client individual and business-wide level. Assessment results determine the risk mitigating measures obliged parties have to implement.
Exhibit 1

How will you handle these revised Guidelines?

Implement in time and thoroughly. Avoid findings during audits as well as sanctions from supervisory authorities. Missing implementation of the Guidelines will very likely result in an incomplete ML/TF risk assessment. Data centricity is key to success for efficient processes and optimised Compliance Costs. Hence, leverage digitalisation and new data techniques.
Exhibit 2

Our solution 

BDO and Projective have formed a partnership to provide you with a best of breed solution. Together we cover the Guidelines implementation end-to-end from a single source to add real value to your business. We have designed dedicated modules supporting regulatory, economic and implementation level. 
Start now and read our brochure to get more insights on our solution.

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Solution Modules

  • Business-wide ML/TF
    risk assessment
  • Client individual risk
  • Risk Sensitive due diligence measures

More modules are available


  • A timely and adequate transpose of the revised Risk Factor Guidelines
  • An implemented efficient and effective AML/CFT risk model
  • Increased customer satisfaction and operational efficiency
  • Reduced compliance costs
  • Improved data centricity in the AML/CFT discipline