FATF-Style Regional Bodies and How to Read a Mutual Evaluation Report

When people talk about a country's anti-money laundering (AML) standing, they usually mean the result of a mutual evaluation: a peer review of how well that country's laws and practice meet the global standard. Those reviews are run either by the Financial Action Task Force (FATF) itself or by one of its regional partners, the FATF-style regional bodies (FSRBs). This guide explains who they are, how a mutual evaluation report is organised, and how to read one without being misled by a single headline score. It is based on the websites of the Caribbean Financial Action Task Force (CFATF), the Asia/Pacific Group on Money Laundering (APG) and the FATF, and on an APG follow-up report. FATF's own report pages were not accessible to us, so we do not describe their layout.

The nine FATF-style regional bodies

The CFATF's description of the FATF Global Network lists nine FSRBs. The network as a whole is described as covering over 200 jurisdictions. The nine bodies are:

• Asia/Pacific Group on Money Laundering (APG);
• Caribbean Financial Action Task Force (CFATF);
• Eurasian Group (EAG);
• Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG);
• Action Group against Money Laundering in Central Africa (GABAC);
• Financial Action Task Force of Latin America (GAFILAT);
• Inter-Governmental Action Group against Money Laundering in West Africa (GIABA);
• Middle East and North Africa Financial Action Task Force (MENAFATF);
• Committee of Experts on the Evaluation of Anti-Money Laundering Measures (MONEYVAL).

According to the same source, the FSRBs conduct mutual evaluations, assessing how well their members' AML, counter-terrorist financing and counter-proliferation financing frameworks comply with international requirements and work in practice. Some bodies also have a history with the FATF itself. The FATF's page on the Eurasian Group says it was founded in Moscow in October 2004 and became an associate member of the FATF in June 2010. We did not find membership counts for each body in the sources we read, so we do not give them.

What a mutual evaluation tests

The APG describes a mutual evaluation as a peer-review process with two parts:

• Technical compliance: a desk-based review of laws, regulations and institutional frameworks against the 40 FATF Recommendations.
• Effectiveness: an assessment of how well the jurisdiction implements the 11 Immediate Outcomes in the FATF Methodology.

Expert assessors drawn from members and observers prepare the report, which analyses the system, assesses effectiveness and sets out recommendations. The APG says all of its reports go through a global quality and consistency review so they line up with assessments across the wider FATF and FSRB network, and that members belonging to both the FATF and the APG are assessed under FATF's procedures, with the APG adopting their reports.

How the scores are expressed

An APG follow-up report on Vietnam, published in 2023, sets out the scales in a footnote:

• technical compliance is rated for each Recommendation as compliant (C), largely compliant (LC), partially compliant (PC) or non-compliant (NC);
• effectiveness is rated for each of the 11 Immediate Outcomes as Low, Moderate, Substantial or High.

Two different scales, in other words, and one does not translate into the other. A country can have a strong legal framework on paper and still score poorly on effectiveness if the law is not applied.

Follow-up after the report

After a report is adopted, the jurisdiction enters follow-up. The Vietnam report says there are three follow-up categories: regular, enhanced and enhanced (expedited), and that technical compliance re-ratings are given where sufficient progress has been demonstrated. In that report, Vietnam was re-rated on one Recommendation, Recommendation 13, the report found insufficient progress to re-rate the other Recommendations it asked about, and Vietnam was placed on enhanced (expedited) follow-up. It also says the follow-up analysis does not look at progress on effectiveness. The practical lesson is that the original report is a snapshot, and later follow-up reports can change individual technical ratings.

The APG also says its Global 5th Round began in 2024, that APG-only evaluations start in 2026, and that follow-up for APG-only members under the 5th Round begins in 2030. Check which round a report belongs to before you compare two countries.

How to read a report: our suggestions

These are our suggestions, not FATF guidance.

1. Note the date and the body. A report adopted in 2016 and one adopted in 2023 may sit in different rounds, and some countries have since been re-rated.
2. Look for the follow-up reports. They show which technical ratings have moved.
3. Compare the two scales separately. Count how many Recommendations are partially compliant or non-compliant and how many Immediate Outcomes are Low or Moderate.
4. Read the sections on your profession. Look for what the report says about accountants, company service providers and beneficial ownership.
5. Keep it separate from grey listing. A mutual evaluation is not the same process as the FATF's lists of jurisdictions under increased monitoring. Our guide to the FATF recommendations, grey list and black list covers the lists.

Why this matters for accountants

National AML rules are written to meet the international standard that these evaluations test. Our guides to South Africa and Nigeria show how that looks in two countries. For a firm with clients or offices abroad, reading the latest report for each country is a quick way to see where regulators are likely to focus. For the underlying client checks, see our guide to customer due diligence in accountancy practices.

What we could not confirm

• The layout of FATF's own report pages and the Methodology document, which were not accessible to us.
• How many jurisdictions each FSRB has.
• The detailed rules for moving between regular and enhanced follow-up, which the follow-up report refers to another document for.

Frequently asked questions

How many FATF-style regional bodies are there?

Nine, according to the CFATF's description of the FATF Global Network.

What do the effectiveness ratings mean?

They rate each of the 11 Immediate Outcomes as Low, Moderate, Substantial or High, according to the APG follow-up report we read.

Does a poor rating mean a country is grey listed?

Not by itself. Grey listing is a separate FATF process.

This guide is general information, not legal advice.