Implementation Issues

Certain key determinates affect the pace of implementation of AML/CFT standards. Gaining, maintaining and sustaining political will among APG members is the primary determining factor, which is linked to the  levels of AML/CFT awareness, understanding and trust. Implementation can be negatively affected in a ‘non supporting’ environment – an APG member may resist external pressure because it is perceived to be contrary to prevailing political and economic objectives.

The nature of the economy and level of development is another determinant. This affects core frameworks, institutional capacity and reliance on external assistance, which may in turn influence policy priorities and resource allocation.

Closely related is overall governance and institutional development including the nature, capacity and pace of legislative processes, and associated institutional capability and capacity. This affects implementation, even if political will is present.

Lastly, corruption – political and institutional - may affect a jurisdiction's willingness to conduct and accept risk and other assessments. It can impede effective implementation and undermines trust in AML/CTF systems and institutions.