R1. Where countries identify higher risks, they should ensure that their AML/CFT regime adequately addresses such risks. Where countries identify lower risks, theyshould allow and encouragesimplified measures as appropriate. Where countries identify distinct risks that adversely impact financial inclusion, they should allow and encourage the application of alternative measures to facilitate financial inclusion while adequately addressing the identified ML/FT risks.
INR.1. The general principle of an RBA is that, where there are higher risks, countries should require financial institutions and DNFBPs to take enhanced measures to manage and mitigate those risks; and that, correspondingly, where the risks are lower, countries should allow and encourage financial institutions and DNFBPs to take simplified measures. Countries should identify areas of lower risk, for example, through their national or sub-national risk assessments, to support financial institutions and DNFBPs to apply measures proportionate to those risks. Countries should provide guidance or information to financial institutions and DNFBPs on the possible approaches for the implementation of simplified measures where the risks are lower, or for the implementation of alternative measures where the risks are distinct and traditional approaches may be exclusionary.
Note that “alternative measures”, in practice, may often include measures of simplified due diligence at some point in the customer lifecycle (e.g., tailoring the identification standards based on the specific scenario).
2.关于用“countries should allow and encourage simplified measures”代替“countries may decide to allow simplified measures”（标黄部分为Wolfsberg建议修改部分）
Combined with the proposed textual additions cited above, the Group agrees with the FATF’s proposal but recommends the addition of a passage to recognise “alternative measures”. Without an explicit requirement that national authorities create an enabling environment for implementation of simplified measures, the FATF’s push for the practical application of an RBA will not be successful.
However, and in line with our previous proposals, to promote the facilitation of financial inclusion within the context of the RBA, “alternative measures” must be supported as well.
Providing the conditions for financial inclusion requires attentive FIs willing to apply alternative measures to due diligence where traditional approaches have proven to be exclusionary, supported by competent authorities who recognise that national level strategies aimed at decreasing ML/FT risk may on a local level represent an increased risk to an FI. Forcing an FI to apply measures (i.e., simplified measures) that do not address the underlying risk to the FI is not the solution; rather, competent authorities must embrace alternative approaches and collaborate with FIs to demonstrate that shared commitment, including in their supervision of FIs. This is as relevant for retail, mass market relationships as it is for correspondent relationships that facilitate country access to the international financial system.
Accordingly, we recommend the following additional changes to paragraph 13:
They should be required to monitor the implementation of those policies, controls and procedures,and apply standard, enhanced or simplified measures in line with the risks. They should also be permitted to apply alternative measures to address more effectively identified risks when appropriate, particularly when traditional approaches can be exclusionary.
3.关于附录措施。（标黄部分为Wolfsberg建议修改部分）
Annex 2: List of SDD and Alternative Measures
The Group recommends further examples of possible measures be included in paragraph 21. The chapeau text also has edits to conform with the above changes to the text in the Recommendation and Interpretive Note.
21. Where the risks of money laundering or terrorist financing are lower, financial institutions should be allowed and encouraged could be allowed to implement conduct simplified CDD measures, which should take into account the nature of the lower risk. The simplified measures should be proportionate to commensurate with the lower risk factors (e.g. the simplified measures could relate only to customer acceptance measures, aspects of ongoing monitoring, or both). Where the risks may not be lower but are distinct, and the application of traditional CDD measures may represent a barrier to financial inclusion, financial institutions should be allowed and encouraged to implement alternative CDD measures that facilitate inclusion while adequately addressing the risk.
Examples of possible simplified measures include but are not limited to:
•Verifying the identity of the customer and the beneficial owner after the establishment of the business relationship (e.g. if account transactions rise above a defined monetary threshold).
•Reducing the frequency of customer identification updates.
•Reducing the degree of on-going monitoring and scrutinising transactions, based on a reasonable monetary threshold.
•Not collecting specific information or carrying out specific measures to understand the purpose and intended nature of the business relationship, but inferring the purpose and nature from the type of transactions or business relationship established.
Examples of possible alternative measures include but are not limited to:
•Providing limited purpose account types with simplified identification requirements, balanced by ongoing controls (e.g., application/device tracking, usage terms and conditions such as monthly deposit or transactions limits, prohibitions on transfers to certain geographies/jurisdictions, etc).
•Tailoring the monitoring of a customer relationship, for example a correspondent relationship, to recognise that even if the correspondent is located in a high-risk country, not all payments to/from that country are necessarily high risk (e.g., propriety payments, payments related to the provision of humanitarian services, payments to/from established sources, etc.).
