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IMPROVING COMPLIANCE WITH INTERNATIONAL AML/CFT STANDARDS: REPORT ON THE STRATEGIC REVIEW OF THE FIRST ROUND OF MUTUAL EVALUATIONS OF GIABA MEMBER STATES (2007-2012)
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As a Financial Action Task Force Style Regional Body (FSRB), the Inter-Governmental Action Group against Money Laundering in West Africa (GIABA) is mandated to undertake mutual evaluation (ME) of its member States. The ME exercise commenced in 2007 with the evaluation of Sierra Leone, and was completed in 2012, with the evaluation of Sao Tome and Principe, which became a full member of GIABA in 2012. In total, sixteen (16) member States, namely, - Benin, Burkina Faso, Cape Verde, Cote d'Ivoire, Gambia, Ghana, Guinea, Guinea Bissau, Liberia, Mali, Niger, Nigeria, Sao Tome and Principe, Senegal, Sierra Leone and Togo, were evaluated. Sao Tome and Principe has not been included in this review for two strategic reasons. Firstly, the country became a member of GIABA at the time when the first round of MEs was about to be concluded. This means that there was limited engagement with the country throughout the first round of the evaluation. Secondly, because the country is not a member of ECOWAS, it has not benefitted from the technical assistance given to ECOWAS members States. The data for the ME, therefore, may be skewed and incomparable with those of ECOWAS member States.
The evaluations were aimed at determining the level of compliance of the member States with the FATF Recommendations, based on a set of objectives and guiding principles as laid out in the 2004 FATF Methodology for Assessing Compliance, the FATF Handbook for Countries and Assessors and the GIABA Mutual Evaluation Process and Procedures (P&P).
Following the conclusion of the first round of MEs of GIABA member States, and in order to improve on subsequent evaluation outcomes, GIABA conducted a strategic review of the first round of the evaluations. The objectives of the review were to: i) review and analyze the framework for the evaluation in relation to the peculiarities of GIABA member States; ii) review and analyze the process and procedures adopted during the evaluation and determine the challenges encountered; iii) assess the outcome of the MEs and determine the consistency of the outcome; and iv) provide key observations, conclusions and recommendations drawing from the analyses and assessment of i-iii above in order to learn lessons that will help to improve the second round of MEs.
January 2014