Page 33 - Annual Report 2024 EN
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Risk Assessment Visits 2024 Highlights Aggergate RAVs
During 2024, the AML/CFT supervisory team issued The first Q27 Annual AML/CFT returns were received
9 feedback letters and 5 Risk Mitigation Plans during 2024. This return replaced the previous Banking & Investment management AML/ CFT
(RMP) to firms to remediate deficiencies identified Q25 and Q26 AML/CFT returns. The revised Q27 Total RAVs Insurance & advisory
Combined Standalone
during any RAVs, including 30 RMP items, of which streamlined reporting requirements and eliminated
12 have been closed, as set out in Table 2. duplication. While the quality of reporting has
32 7 6 1 18
improved, revised guidance was issued to firms
to further enhance the quality of reporting.
Table 2: RMPs and Feedback letters issued
The AML/CFT team implemented a revised AML/
Financial
CFT heatmap and dashboard that leverages data Thematic Reviews
Institutions DNFBPs
and statistics from the Q27 AML/CFT annual
RMP issued 3 2 return to further assist in assessing the AML/CFT During 2024, the QFCRA commenced a thematic review project to assess the compliance risks
risk ratings of firms for supervisory purposes. associated with firms meeting their compliance obligations with the United Nations Security
RMP items issued 15 15 Council (UNSC) and National Counter Terrorism Committee (NCTC) domestic sanctions, as well
Based on an assessment of the AML/CFT Independent
as other international sanctions relevant to their operations. The outcome of the project identified
Review Reports (IRRs) submitted by firms, a revised
RMP Items closed 6 6 that firms had a sufficient understanding of their sanctions risk and obligations. Notwithstanding
guidance was published to further support firms and
this assessment, guidance was issued to firms to further enhance their sanction programmes.
independent reviewers in preparing and undertaking
Feedback letters issued 4 5
their reviews for future reporting obligations.
Additionally, a Suspicious Transaction Report (STR) thematic review project was undertaken to
Action items 30 32 assess whether firms had adequate transaction monitoring systems and STR mechanisms in
AML/CFT Supervision worked closely with the Financial
place to meet reporting obligations. The outcome of the review is currently being concluded.
Analysis and Innovation (FAI) team to develop and
Clean reports 3 1
refine an artificial intelligence (AI) tool to review and
analyse AML/CFT policies and procedures received
from firms. This tool identifies gaps and potential
enhancements to policies, procedures, systems, and
controls. It will assist in efficiently conducting reviews
Sectoral Risk Assessment
to ensure firms meet their AML/CFT responsibilities.
AML/CFT Supervision is committed to conducting a
revised Sectoral Risk Assessment (SRA) in alignment
with the updated National Risk Assessment (NRA)
from NAMLC, which is currently being revised.
In the interim, the QFCRA has proceeded with drafting
and updating the SRA framework, analysing quantitative
data from the Q27 AML/CFT annual returns, and
propose issuing a revised QFC SRA during 2025.
