A. Background
i) FATF and APG
The FATF (The Financial Action Task Force), an international inter-governmental body, is responsible to set international standards that aim to prevent money laundering and terrorist & proliferation financing. The G-7 Summit formed the FATF in 1989. The FATF has developed the worldwide accepted AML/CFT (Anti-Money Laundering/Combating the Financing of Terrorism) standards, generally known as FATF Recommendations. Implementation of FATF Recommendations help authorized agencies to follow and go after the money of criminals. Its main aim is to ensure global coordination to prevent organised crime, corruption, illegal drugs, human trafficking, other crimes and terrorism as well as to stop funding for weapons of mass destruction.
To
achieve the expected outcomes from implementation of FATF Recommendations, the
FATF also relies on a strong global network of FATF-Style Regional
Bodies (FSRBs), in addition to its own 39 members. These FSRBs are
also the associate members of FATF. The nine FSRBs have very crucial role in
promoting the effective implementation of the FATF Recommendations by their regional
membership and in providing expertise and input in FATF policy-making. Through
the international network of FSRBs and FATF memberships, over 200 states
worldwide have vowed to abide by the FATF Recommendations. Nepal is member of
one of the FSRB, named Asia/Pacific Group on Money Laundering (APG). In June
2002, Nepal joined the APG as a member.
ii) FATF Recommendations and FATF Methodology
40
Recommendations, including interpretative notes, 2012 (Last updated on
March 2022), FATF Methodology for assessing compliance, 2013 (Last
updated on October 2021) and various best practice guidelines are referred
as core FATF standards.
The
FATF Recommendations set out a comprehensive and consistent framework of
measures which countries should implement in order to combat money laundering
(ML) and terrorist financing (TF), as well as the financing of proliferation of
weapons of mass destruction (PF). The FATF Recommendations are considered as
AML/CFT related international standard, which countries should implement
through their own measures adapted as per their context, circumstances and
risks. FATF 40 Recommendations with their broader categories are as below: -
Table 1: FATF 40
Recommendations
|
A – AML/CFT POLICIES AND COORDINATION |
|
Recommendation 1: Assessing risks and applying a risk-based approach * |
|
Recommendation 2: National cooperation and coordination |
|
B – MONEY LAUNDERING AND CONFISCATION |
|
Recommendation 3: Money laundering offence |
|
Recommendation 4: Confiscation and provisional measures |
|
C – TERRORIST FINANCING AND FINANCING OF PROLIFERATION |
|
Recommendation 5: Terrorist financing offence |
|
Recommendation 6: Targeted financial sanctions related to terrorism and terrorist financing |
|
Recommendation 7: Targeted financial sanctions related to proliferation |
|
Recommendation 8: Non-profit organisations |
|
D – PREVENTIVE MEASURES |
|
Recommendation 9: Financial institution secrecy laws |
|
Recommendation 10: Customer due diligence |
|
Recommendation 11: Record-keeping |
|
Recommendation 12: Politically exposed persons |
|
Recommendation 13: Correspondent banking |
|
Recommendation 14: Money or value transfer services |
|
Recommendation 15: New technologies |
|
Recommendation 16: Wire transfers |
|
Recommendation 17: Reliance on third parties |
|
Recommendation 18: Internal controls and foreign branches and subsidiaries |
|
Recommendation 19: Higher-risk countries |
|
Recommendation 20: Reporting of suspicious transactions |
|
Recommendation 21: Tipping-off and confidentiality |
|
Recommendation 22: DNFBPs: customer due diligence |
|
Recommendation 23: DNFBPs: Other measures |
|
E – TRANSPARENCY AND BENEFICIAL OWNERSHIP OF LEGAL PERSONS AND ARRANGEMENTS |
|
Recommendation 24: Transparency and beneficial ownership of legal persons |
|
Recommendation 25: Transparency and beneficial ownership of legal arrangements |
|
F – POWERS AND RESPONSIBILITIES OF COMPETENT AUTHORITIES AND OTHER INSTITUTIONAL MEASURES |
|
Recommendation 26: Regulation and supervision of financial institutions |
|
Recommendation 27: Powers of supervisors |
|
Recommendation 28: Regulation and supervision of DNFBPs |
|
Recommendation 29: Financial intelligence units |
|
Recommendation 30: Responsibilities of law enforcement and investigative authorities |
|
Recommendation 31: Powers of law enforcement and investigative authorities |
|
Recommendation 32: Cash couriers |
|
Recommendation 33: Statistics |
|
Recommendation 34: Guidance and feedback |
|
Recommendation 35: Sanctions |
|
G – INTERNATIONAL COOPERATION |
|
Recommendation 36: International instruments |
|
Recommendation 37: Mutual legal assistance |
|
Recommendation 38: Mutual legal assistance: freezing and confiscation |
|
Recommendation 39: Extradition |
|
Recommendation 40: Other forms of international cooperation |
FATF Methodology provides the
basic structure, procedures and framework to undertake assessments of technical
compliance with the revised FATF Recommendations and to review the level of
effectiveness of a country’s Anti-Money Laundering / Countering the Financing
of Terrorism (AML/CFT) system.
iii) Mutual Evaluation
Mutual
Evaluation is a structured process to evaluate a status and progress of a
nation for strengthening measures to combat money laundering, the financing of
terrorism and the financing of proliferation of weapons of mass destruction. Mutual evaluation
is basically a process of peer reviews, where members from different nations evaluate
another country on the basis of international standards of AML/CFT. A mutual
evaluation report offers a thorough description and analysis of a nation's
system for preventing criminal misuse of the financial system, as well as
specific recommendations for how to make the system even stronger.
Figure 1: Mutual Evaluation Process
(Source: APG)
Mutual
Evaluations have two basic components, effectiveness and technical
compliance.
- The main component of a mutual evaluation is
effectiveness. To evaluate overall effectiveness of the system is the focus of
the on-site visit during Mutual Evaluation. The assessment team will need proof
that the assessed country's policies are effective and yield the desired
outcomes during the visit. What is expected from a country differs, as per the
ML/TF/PF (Money Laundering/Terrorist financing/Proliferation financing) and
other risks it is exposed to. The FATF has created elaborative assessment
technique to ensure fair and consistent evaluations.
Table 2: The
Framework for Assessing Effectiveness
iv) Relationship between Recommendations and Immediate
Outcomes
Technical
compliance evaluations primarily concentrate on the existence and provisions of
the legal framework, institutions, and system to strengthen the AML/CFT regime
of the country in accordance with FATF recommendations. The assessment of
compliance's effectiveness focuses on how practically effective the framework,
institutions, and overall system are at carrying out AML/CFT-related activities
and actions. As a result, recommendations and immediate outcomes have a direct
relationship that can be summed up as follows:
Table
3: Relationship between Recommendations and Immediate Outcomes
v) Previous
Mutual Evaluations
of Nepal
In 2005,
the first ME for Nepal was carried out using the then-current FATF 40+9
Recommendations. Out of 49 recommendations, Nepal received the following
ratings: Non-Compliant (NC) on 34, Partially Compliant (PC) on 8, Largely
Compliant (LC) on 4, and Non-Applicable (NA) on 3 recommendations. Nepal was NC
or PC on 15 of the 16 core/key recommendations and LC on one of them out of the
total of 16. Since Nepal did not have an Assets (Money) Laundering Prevention
Act at the time the first mutual evaluation was conducted, money laundering was
not a crime. After that, in 2008, the Act was enacted.
In
2010, Nepal had a second evaluation based on the FATF's previous 40+9
requirements. When the report was finally adopted in July 2011, Nepal received
ratings of NC or PC on 43 recommendations, LC on 3, compliant on 1 and NA on 2.
Nepal was NC or PC on 15 of the 16 core/key recommendations and LC on one of
them out of the total of 16. Nepal's post-evaluation development, however, was
so significant that it technically (legally and institutionally) led to LC in
10 Core/Key recommendations. Nepal was helped by these accomplishments to exit from
the APG Expedited/Enhanced as well as from regular monitoring in 2014.
The following were the main conclusions of the ME Report of Nepal, 2011:
• Serious vulnerabilities caused by the porous border between India and Nepal.
• The predicate offenses' scope is insufficient to meet FATF standards, and TF is not criminalized.• The FIU needs operational autonomy within NRB.
• The ML offence has serious flaws, and there is no TF offence
• Limitation in the scope of reporting Suspicious Transaction/Activity Reports and Threshold Transaction Reports (STR/SAR/TTR), etc.
• There are gaps in the coverage of institutions including postal savings banks, commodities brokers, lawyers, accountants, person acting as real estate agents and precious metal/gem dealers, etc., and requirements are not enforced.
• Customer identification and verification are weaknesses in Nepal's preventive efforts.
• Absence of adequate legislative frameworks for extradition and mutual legal assistance (MLA).
B. Ongoing APG Third Round ME process of Nepal
The
third-round ME of Nepal was initially slated for 2021–2022, however due to the
Covid–19 outbreak, it has been moved to 2022–2023. The FATF's Revised 2012
standards and 2013 Methodology are being used for Nepal's Third Round Mutual
Evaluation, which is being conducted in accordance with FATF's Universal
Procedures. It is the assessed jurisdiction's responsibility to provide substantiate
evidence of technical compliance and effectiveness. The burden of proof rests
on the assessed jurisdiction. A prerequisite is thorough knowledge of our
system, case studies, statistics, and proof of compliance and effectiveness to
back our claims. Together with government agencies, the private sector,
non-profit organizations (NPOs), and other stakeholders, APG professionals
(legal, supervisory, FIU, and law enforcement assessors) examine Nepal's
AML/CFT system and its effectiveness.
With
the active involvement of regulators, intelligence agencies, investigation
agencies, prosecuting and adjudicating agencies, oversight and policy agencies,
the private sector, civil society, high level committees, and with the support
of the APG secretariat, Nepal has started preparing for the Mutual Evaluation
2022–2023.
i) How Third Round ME is different?
The
third-round mutual evaluation of Nepal is based on a new Methodology that was revised
in 2013. In contrast to the previous ME of Nepal in 2010, which was mostly
based on technical (legal and institutional) factors, the effectiveness for
visible implementation and outcomes will also be evaluated in the third-round
evaluation in addition to technical outputs and laws. Overall ratings will be
as below for each Recommendations and IOs: -
Table 4: Rating Scales for Technical Compliance and
Effectiveness Assessment
|
COMPLIANCE/ACHIEVEMENT
RATINGS |
||
|
Technical-40 Recommendations |
|
Effectiveness –11 Immediate Outcomes (IOs) |
|
Compliant (C) |
High level of effectiveness |
|
|
Largely Compliant (LC) |
Substantial level of effectiveness |
|
|
Partially Compliant (PC) |
Moderate level of effectiveness |
|
|
Non‐Compliant (NC) |
Low level of effectiveness |
|
|
Not Applicable (NA) |
– |
|
ii) Completed actions and
activities
As of November 30,
2022, the following APG Third Round ME of Nepal actions/activities have been
finished:
- ME has been discussed by all significant AML-CFT committees, including the National Coordination Committee (NCC), National Review Council, Regulators Coordination Committee, Investigation Coordination Committee, Counter Terrorism Mechanism, Mutual Evaluation Committee, and Technical Group for ME Support.
- Technical Compliance Response from Nepal: Nepal's response to 40 recommendations and follow-up questions in the technical compliance criteria
- Effectiveness Compliance Response from Nepal: Nepal's response to 11 Immediate Outcomes and Follow-Up Questions
- Nepal's response to the Assessment Team's additional questions on technical compliance and effectiveness.
- Work is being done on the onsite visit preparation.
- Participation of 57 agencies (ministries, departments, law enforcement agencies (LEAs), regulators, and committees), with more than 100 in-person meetings, workshops, and exchanges;
- More than 30 programs (both physical and virtual) for ME preparation
- Three virtual interaction programs with coordination with APG Secretariat
- Regular meeting of Mutual Evaluation Committee (MEC) of Nepal
- Pre-onsite visit on TC (Technical Compliance) was conducted on 12-14 October, 2022.
iii) Remaining actions and activities
To
finish the ME process, the following actions/activities will be completed:
- • Onsite visit for EC (Effectiveness Compliance) (Scheduled for December 5-16, 2022)
- • First draft of ME Report
- • Face-to-face meeting in Nepal
- • Global distribution of Final draft report
- • Comments and review
- • Pre-plenary meeting
- • Report adoption at APG Annual Meeting in Canada (July, 2023)
- • Determination of monitoring modality based on results
- • Report publication (September, 2023)
C. Nepal’s current AML/CFT status
Overall
rating of Technical compliance (TC) and Effectiveness compliance (EC) will be
majorly based on following dimensions which will be the major concern during
the ME process by assessors. General picture of Nepal in each of the following
dimensions is portrayed below based on findings of the National Risk Assessment
Report, 2020 and in other relevant documents:
i.
ML/TF Risks and Context
Money laundering and financing in
terrorism is criminalised under section 3 and 4 of the Asset (Money) Laundering
Prevention Act (ALPA), 2008. It also includes a list approach to define
predicate offences and following offences are classified as predicate offence:
- •
Participation in an organized criminal
group and racketeering,
- •
Disruptive (terrorist) act and terrorism,
- •
Trafficking in person and migrant
smuggling,
- •
Any kinds of sexual exploitation including
sexual exploitation of children,
- •
Illicit trafficking of narcotic drugs and
psychotropic substances,
- •
Illicit transportation of arms and
ammunition,
- •
Illicit transportation of stolen and other
goods,
- •
Corruption and bribery,
- •
Fraud,
- •
Forgery,
- •
Counterfeiting of coin and currency,
- •
Counterfeiting of goods and plagiarism or
piracy of products,
- •
Environmental related,
- •
Murder, grievous bodily injury,
- •
Kidnapping, illegal restraint or
hostage-taking,
- •
Theft or rubbery,
- •
Smuggling (including custom, VAT and tax)
related,
- •
Tax (including direct and indirect)
related,
- •
Extortion,
- •
Piracy,
- •
Insider Dealing and Market Manipulation in
securities and commodities related,
- •
Ancient monument conservation related,
- •
Forest, National Park and wild animals
related crime,
- •
Money, banking, finance, foreign exchange,
negotiable instruments, insurance, cooperatives related,
- •
Black marketing, consumer protection,
competition, supply related,
- •
Election related,
- •
Communication, broadcasting, advertising
related,
- •
Transportation, education, health,
medicine, foreign employment related,
- •
Firm, partnership, company, association
related,
- •
Real estate and property related,
- •
Lottery, gambling, donation related,
- •
Citizenship, immigration and passport.
- •
Offence of terrorist financing or
association with terrorist organization.
Each
nation must conduct a National Risk Assessment (NRA) in accordance with the
most recent FATF recommendations in order to identify threats and
vulnerabilities in its AML/CFT system. This information will be used to design
a policy framework and its implementation strategy, including the allocation of
resources. In 2016 and 2020, Nepal performed National Risk Assessments. The
following summarizes the key findings of the National Risk Assessment Report,
2020:
- •
The assessment of national vulnerabilities
across sectors revealed flaws in the monitoring of REs, the robust continuation
of recent tax reform attempts, and the tightening of domestic and international
trade imbalances, including the remittance and hundi difficulties.
- •
The Report has identified following
threats:
o
Major threats: Corruption
(bribery), tax (revenue) evasion, financial crimes such as banking offence and
hundi.
o
Threats of concerns: Drug
trafficking, organized crime, extortion, arms-related offence, domestic
terrorism, fraud, counterfeiting of currency, environment related crime,
robbery (theft), smuggling (including black marketing) and forgery.
o
Low threats: counterfeiting
and piracy of products, kidnapping, illegal restraint and hostage taking,
international terrorism, trafficking in stolen goods and insider trading.
ii.
National AML/CFT Policies and
Coordination
•
The National Coordination Committee has
been established to coordinate the high-level institutions and authorities
related to AML/CFT and provide advice to the Government of Nepal in this
regard.
•
Across the public and private sectors,
there is still a lack of proper common understanding of AML/CFT risks.
iii.
Legal System and Operational Issues
• The legislative, regulatory, and
enforcement mechanisms relating to the AML/CFT system have improved
significantly. Some of the notable examples include the creation of important
institutions like the DMLI and FIU, the formulation and enactment of numerous
laws, delegated legislations, and regulatory manuals, and the identification of
11 agencies as regulators.
• The current AML/CFT legal, policy, and
institutional frameworks include fairly extensive provisions that are in line
with the standards and best practices of the FATF, such as CDD, monitoring,
reporting, record keeping, regulation, supervision, and the prohibition of
fictitious and anonymous accounts and transactions with shell banking. They
also include monitoring PEPs, wire transfers, and non-face-to-face
technology-based financial activities.
•
The regulation of casinos, real estate,
and the gathering of data on beneficial ownership have limits.
•
The DMLI and other LEAs have functional
overlap.
iv.
Terrorist Financing and Financing
of Proliferation
There
are a few designated predicate offences/conducts that are yet to be
criminalized including categorical criminalization of TF and PF.
v.
Preventive Measures
• Financial Institutions (FIs) are
submitting adequate amounts of STR/SAR/TTR reports, however only a small number
of Designated Non-Financial Businesses and Professions (DNFBPs) are reporting.
•
It is challenging to navigate risks and
adopt appropriate measures and inherited in new, uncharted industries like
cryptocurrency, other virtual assets, and related new technology.
vi.
Supervision
Key
relevant points regarding supervision and vulnerabilities of different sectors
in the ‘National Risk Assessment Report, 2020’ are as below: -
•
The overall banking sector vulnerability
to ML is rated as medium-high whereas; the quality of the general AML control
is medium. Large business-related credit products are found to be highly
vulnerable products with medium- high rating, current deposit product is rated
as medium-high and natural persons saving accounts are rated medium.
• The overall cooperative sector's
vulnerability to ML is rated as medium-high due to the implementation issues of
the existing AML/CFT laws.
•
The overall securities and insurance
sector’s vulnerability to ML is rated as medium.
•
Though money changers and remittance
companies are licensed and regulated, informal remittance or value transfer
services or hundi dealers pose serious challenges and is assessed as an
area of high concern.
• Among DNFBPs, 'casinos' and 'dealers in
precious metals and stones' operate with minimum business regulation and are
often unaware of their AML/CFT obligations, thus their vulnerability has been
assessed medium-high. The real estate sector is most vulnerable to ML and rated
high due to lack of business laws regulating them for licensed business.
Independent legal, notary and accounting professionals are assessed as medium
level vulnerability.
• Lack of laws requiring the AML/CFT
measures and national statistics related to the Non-Profit making Organizations
(NPOs) are the main problems, so, the vulnerability of this sector is assessed
as medium.
vii.
Legal Persons and Arrangements
Assessors'
top worry is the status of transparency in relation to legal entities and
agreements. Concern over the identification of Beneficiary Owners (BOs) is a
global issue, and Nepal also faces certain difficulties in this area.
viii.
International Cooperation
Nepal
is an active participant of global community; on realization of common agenda,
including AML/CFT. It is evident from its membership to the UN, SAARC, APG,
Egmont Group of FIUs, BIMSTEC, ARIN-AP etc. Ratification of major international
conventions; enactments of instrumental statutes; implementation of National
AML/CFT Strategy; and establishment and designation of major institutional
infrastructures in a short period of time are the basic foundation for
functional operation of the AML/CFT regime.
D. Challenges for Nepal and possible consequences of low
compliance ratings in ME
A
country being classified as high risk does not necessarily imply that it is
totally cut off from the rest of the world. However, other nations are hesitant
to conduct business under the same terms and conditions with riskier nations.
As a result, the cost of doing business internationally may increase
significantly. High-risk nations may also confront social and political
difficulties in addition to financial difficulties.
Following are some
of Nepal's main challenges in the ongoing APG Third-round ME (2022-23): -
•
Need for revisions to inadequate
legislative or statutory provisions
•
Poor compliance with implementation of institutional
commitments, rules, and laws
•
Weak action in high-risk areas
• Lack of capacity building and motivation
of human resources working in the area of collection, analysis, dissemination,
and investigation of financial crimes
• Risk of Nepal being placed under Enhanced
follow-up or the FATF's International Co-operation Review Group (ICRG)
Monitoring
A
jurisdiction with a low ME compliance rating will either appear on the list of "High-Risk
Jurisdictions subject to a Call for Action" (often known to as the "black
list") or the list of "Jurisdictions under Increased
Monitoring" (commonly referred to as the "grey list").
According to FATF, as of November 30, 2022, the Democratic People's Republic of
Korea (DPRK), Iran, and Myanmar are on such "black list," while 23
other nations are on the "grey list." Directly or indirectly, any
nation with low compliance after the ME Report may experience one or more of
the negative consequences in different dimensions as below: -
i.
Consequences to Economy
• Most likely lead to a decline in local
investment, exports, inward foreign direct investment and flow of remittance.
• For high import-based countries, like
Nepal, high inflation due to high cost imposed by other countries as a result
of being high-risk country.
•
Possible occurrence of Capital flight.
•
Direct and indirect negative consequences in the GDP size and
economic growth. For example: In a paper titled “Bearing the Cost of Global
Politics – the Impact of FATF Grey-Listing on Pakistan’s Economy,”
Dr. Naafey Sardar estimated that Pakistan lost $38 billion in GDP and $3.6
billion in foreign direct investment from 2008 to 2019.
•
Unwanted Expansion of Informal Sector
which may jeopardize and limit the areas and influence of Fiscal and Monetary
Policy.
ii.
Consequences to Banking Sector
• International and corresponding Banking
may get blocked, delayed or pass-through cumbersome process of covenants which
may add to cost of international trade and Informal systems like Hundi,
Hawala.
•
Banking Sector may face undue consequences
in conducting International Banking Transactions.
•
Along with decreasing foreign capital inflows, the listing is
likely to negatively impact bank access for people. According to a review done by FATF, banks become more risk averse
and narrow access to banking services in response to receiving grey list
status.
iii.
Consequences to Government
•
Pressure to Government to act against high-risk
areas and intervene in some areas of market.
•
Pressure from opposition parties and
pressure groups.
•
Internal issues may emerge such as civil
unrest and destabilize the economy.
iv.
Consequences to General Public
• Public may face difficulties in
cross-border transactions due to high cost imposed by foreign-countries.
•
Difficulty for easy access to financial
services.
•
Negative pattern in inflow of Remittance
income to nation as well as public.
•
Assets of citizens and Government abroad
may be considered Risky.
v.
Consequences to Business and Tourism Sector
•
Low level of capital inflows and
difficulties for cross-border transactions.
•
Decrease in tourism revenues.
•
Challenges for import based industries for
LC, TT based transactions.
vi.
Consequences to Financial Aid / Grants
•
International formal assistance or aid is
decreased after declared as high-risk nation.
•
Informal aids via INGOs and other similar
way is also decreased.
vii.
Consequences to Image of Nation
• Reputation and Image of Country's
financial sector will be at stake and hence Overall image of country is
considered weak.
•
Nation’s governance and legal,
institutional and AML/CFT regime is considered weak,
Despite these drawbacks,
the grey/black list acts as a potent motivator for nations to stop money
laundering and financing terrorists. The FATF/FSRB collaborate closely with
nations on the grey/black list to create action plans that address the
structural issues.
E. Way Forward
“The time for action is now. It’s never too late to do
something.” - Antoine de Saint-Exupery
Each nation may fall short of international standards
in the area of AML/CFT in various aspects. We also need to make some
improvements, as previously noted in ME Reports, National Risk Assessment
Reports, and other publications of a similar nature. The following steps must
be taken to strengthen Nepal's overall AML/CFT regime: -
•
Prompt steps to amend rules and
regulations in accordance with global AML/CFT standards
•
Adequate execution of standards, rules,
regulations, and institutional requirements
•
Successful intervention in high-risk areas
• Developing the skills and energizing the
workforce involved in the identification, analysis, dissemination, and
investigation of financial crimes.
All of our efforts and priorities should be directed
toward the ongoing APG Third-Round ME (2022-23) in the short-run. To finish
this process successfully, all concerned government agencies and private
sectors must actively participate and perform their respective tasks. We are
hoping that this ME will provide positive results and keep us off the
non-compliance list.
Our legal framework and implementation procedure
should be restructured and improved in the long-run in accordance with
international standards. The nation should prioritize combating ML/TF/PF.
Economic growth is simply one indicator of a country's strengths and
reputation; another is its AML/CFT regime, which is successful and upholds its
integrity in preventing systemic financial misuse.
References
• APG (2019), Anti-money laundering and
counter-terrorist financing measures - Pakistan, Third Round Mutual
Evaluation Report, APG, Sydney
http://www.apgml.org/includes/handlers/get-document.ashx?d=389ff465-24a1-41cf-9ab9-27edc2e4c836
•
APG (2011), Anti-money laundering and
combating the financing of terrorism - Nepal, Second Round Mutual
Evaluation Report, APG, Sydney
•
APG (2021), APG Third Round Mutual
Evaluation Procedures, APG, Sydney
•
APG website- http://www.apgml.org/
•
FATF (2012-2022), International Standards on Combating
Money Laundering and the Financing of Terrorism & Proliferation, The
FATF Recommendations, FATF, Paris, France,
https://www.fatf-gafi.org/publications/fatfrecommendations/documents/fatf-recommendations.html
•
FATF (2013-2021), Methodology for
Assessing Compliance with the FATF Recommendations and the Effectiveness of
AML/CFT Systems, updated October 2021, FATF, Paris, France,
http://www.fatf-gafi.org/publications/mutualevaluations/documents/fatf-methodology.html
•
FATF website- https://www.fatf-gafi.org/
•
FIU-Nepal (2022), Annual Report,
2021/22, FIU-Nepal, Kathmandu, Nepal
•
FIU-Nepal (2022), Newsletter, 2022,
FIU-Nepal, Kathmandu, Nepal
https://www.nrb.org.np/contents/uploads/2022/10/FIU-Nepal-Newsletter-2022.pdf
•
FIU-Nepal (2021), Newsletter, 2021,
FIU-Nepal, Kathmandu, Nepal
https://www.nrb.org.np/contents/uploads/2021/10/FIU-Newsletter_OCT_2021.pdf
• Government of Nepal (2020), National Risk
Assessment Report on Money Laundering and Terrorist Financing, 2020, (Sanitized
version), FIU-Nepal website:
https://www.nrb.org.np/contents/uploads/2021/07/NRA_REPORT_2020_Summarized.pdf
•
NRB website- https://www.nrb.org.np/
• Sardar, Naafey, “Bearing the cost of
Global Politics: The impact of FATF Grey-Listing on Pakistan’s Economy”, Tabadlab
Working Paper 07
(नेपाल राष्ट्र बैंक, गभर्नरको कार्यालयद्धारा प्रकाशित 'मिर्मिरे', आर्थिक अंक, २०७९ बाट साभार)
