## G20 Methodology for Remittance Corridor Risk Assessment

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**Canonical URL:** [G20 Methodology for Remittance Corridor Risk Assessment](https://www.imf.org/-/media/files/research/imf-and-g20/2021/g20-methodology-for-remittance-corridor-risk-assessment.pdf)

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### Objective and rationale of a Remittance Corridor Risk Assessment (CRA)
- Remittances are described as "the financial lifeblood" for families of migrant workers and many emerging markets and developing economies (EMDEs). (IMF–World Bank Group report framework on remittance corridor risk assessment — BB7 deliverable)
- Remittances may pose money laundering and terrorist financing (ML/TF) risks depending on sender/recipient country context, scale and characteristics of criminal activities, and terrorism in transactions.
- If ML/TF risks are not understood and mitigated effectively, a remittance corridor could be abused by criminals, organized crime groups, terrorists, and terrorist organizations, potentially undermining national security, social order, and economic stability on both sides of the corridor.
- Risk-based AML/CFT measures in line with Financial Action Task Force (FATF) standards enable prioritization of measures and calibration of regulatory frameworks to reduce costs of compliance for lower-risk transactions.
- The G20 Roadmap for Enhancing Cross-Border Payments (endorsed at the October 2020 Finance Ministers and Central Bank Governors meeting) comprises 19 building blocks (BBs); the IMF and the World Bank were assigned to cover BB7 on "safe payment corridors," involving development of a framework for remittance corridors’ risk assessments.
- BB7 phases:
  - Phase 1: develop a framework and methodology for ML/TF risk assessment in remittance corridors and identification of potential "lower risk corridors."
  - Phase 2: pilot testing and refinement of the assessment methodology.
- Terminology:
  - The report uses "safe remittance corridor" (SRC) rather than "safe payment corridor."
  - "International remittances" refers to cross-border person-to-person and non-commercial payments of relatively low value, adopting primarily the Committee on Payments and Market Infrastructures’ (CPMI) definition with the qualifier "non-commercial."
- Key definitional note: "Safe Remittance Corridor" does not imply an absence of ML/TF risks, but rather a lower risk level; qualification should consider proliferation financing or illicit finance, including tax evasion.

### Defining scope of the assessment
- Corridor definition and considerations:
  - A "corridor" is a pair of a remittance origination jurisdiction (sending) and a remittance recipient jurisdiction.
  - A corridor assessment can be carried out jointly or unilaterally by the "sender" or the "receiver" country; in practice, expected that most scenarios will be conducted by a sender country with contributions from the recipient country, as feasible.
  - Assessment may cover a single corridor or multiple corridors where risk factors are similar.
- Factors for selecting corridors for focused CRA:
  - Potential for the corridor to be classified as lower risk (avoid CRA when clear indications of higher ML/TF risks).
  - Importance for immigrant community (number of people supported, amount of support as a share of GDP of the recipient country) and host country (labor market contributions).
  - Vitality of corridor for immigrant community and host country.
  - Importance for recipient country economic development.
  - Challenges in sending or receiving remittances.
  - High remittance costs; indications of de-risking of clients or service providers.
  - Extent of informal money transfer channels; prevalence of cash couriers (declared or undeclared).
  - Feedback/requests from private sector and complaints/requests from migrant communities.
- Uni-directional vs. bi-directional assessment:
  - A CRA can be unidirectional (one direction) or bidirectional (both directions).
  - Unidirectional CRA is useful for corridors dominated by transactions in one direction or where risk profiles vary by direction; most corridors are heavily dominated in one direction.
- Overall corridor assessment vs. sub-categories:
  - Recommended to distinguish risk levels of different sub-categories based on transaction amounts, origin/destination, sender/receiver characteristics, type of RSP and remittance products, delivery channels, or combinations thereof.
  - Even if overall ML/TF risk is medium or high, some sub-categories may be lower risk.

### Domestic and international cooperation
- Domestic cooperation:
  - Domestic contributors can include: the financial intelligence unit; relevant financial sector regulators and supervisors (banks, MTOs, other non-bank financial institutions); financial inclusion unit/team at the central bank; payment systems, national accounts, and other central bank departments; law enforcement, prosecutorial, and intelligence agencies (as necessary); customs and immigration authorities; and the statistics agency.
  - Private sector involvement and NGOs are important for understanding immigrant communities, informal channels, and CDD challenges.
  - Recommended to assign a lead agency, a project leader, and a team for a CRA.
- International cooperation:
  - Ideally corridor countries should carry out CRAs jointly to maximize access to data and bring two perspectives together.
  - Joint assessments facilitate commitment and coordination in addressing recommendations and harmonizing regulations and supervisory approaches.
  - If joint assessment is impossible, the conducting country should coordinate with the other country to obtain inputs and data; bilateral meetings and inviting the counterpart to participate can be effective.

### Data requirements and sources
- Role of quantitative and qualitative data:
  - Both quantitative and qualitative sources are important; a balanced use reduces subjectivity but expert judgments remain necessary.
  - Countries should ensure involvement of qualified experts and quality-control mechanisms.
  - Annex 1 lists illustrative qualitative and quantitative sources; data collection should be focused and efficient, making best use of existing data.
- Use of National ML/TF Risk Assessments (NRAs):
  - NRAs can serve as a foundation for remittance CRAs; FATF Recommendation 1 mandates understanding and assessing ML/TF risks.
  - Since 2014, almost all countries have conducted their first NRAs and many update them every 3 to 5 years.
  - CRA should ideally consider NRAs of both corridor countries; where NRA is not publicized, exchanging relevant information is important.
  - Memoranda of understanding and broader stakeholder involvement can smooth cooperation.
- Assessing country environment and contextual factors:
  - Analyze economic and other links (trade, investment, remittances, predicate crimes) to isolate lower-risk activities.
  - Migration statistics (naturalized citizens, permanent residents, seasonal workers, longer-term visitors, estimates of illegal migrants) help estimate potential remittance flows and approximate an upper bound for corridor value.
  - Include remittance characteristics: volume, value, periodicity, purpose, and currency composition.
  - Consider geographic variability and regional risk differences.

### Assessment of threats: proceeds of crime (POC) and ML threat
- ML threat assessment structure:
  - Start with analysis of POC (funds and assets derived directly and indirectly from domestic or foreign predicate offenses).
  - List various crime types with estimates of their importance in generating proceeds and analyze factors impacting probability that these proceeds would be laundered through the remittance corridor.
  - Main proceed-generating crimes may pose lower ML risk to a specific corridor despite being large sources nationally.
- Layers of threat assessment:
  - Proceeds of crimes → Likelihood of money laundering attempts in the country → Likelihood of money laundering attempts through the remittances in the payment corridor → Likelihood of money laundering attempts in the payment corridor (broader cross-border payments).
- Remittance-specific ML considerations:
  - Low amounts per transaction limit utility for large ML operations; laundering via remittances may require numerous low-amount transactions (smurfing/structuring).
  - Examine past ML cases and typologies to assess existence and extent of smurfing and structuring.
  - Strategic analysis should verify remittance flow patterns against stated rationales: total remittances, seasonality, purposes, frequency across monetary tranches, average amounts, relationship with average income, and macroeconomic/demographic indicators.

### Terrorist Financing (TF) threat
- TF basic scenarios in a payment corridor:
  - Scenario 1: Funds originated in the sender country are sent to the terrorist entities in the recipient country.
  - Scenario 2: Funds originated in a third country are sent to the terrorist entities in the recipient country through the sender country.
  - Scenario 3: Funds originated in the sender country are sent to the terrorist entities in a third country through the recipient country.
- Key determinants:
  - Terrorism context in the recipient country is critical; input from counter-terrorism and intelligence authorities and recipient-country cooperation is key.
  - Existence of terrorist groups/activities does not automatically imply high TF threat; must examine rationale for corridor use.
  - Cultural, demographic, and socioeconomic links (ethnic or ideological proximity) may influence TF risk.
- Quantitative and qualitative information:
  - Use past typologies, detected cases, subject-matter expert observations, interviews with NGOs or immigrant communities, and interactions with recipient-country authorities.
  - Scenario 2 risk increases if the sender country is a global or regional financial hub or a principal gateway to the global financial system for the recipient country.
  - Scenario 3 increases if recipient country is attractive as a transit point for TF or sender country has limited direct access to third-country financial systems.

### Assessing vulnerabilities in the remittance corridor
- Vulnerability definition: properties of AML/CFT regime aspects that can be exploited by ML/TF threats.
- Vulnerability indicators grouped by: geography; financial and non-financial services/products; levels of informality; weaknesses in AML/CFT systems and controls; general levels of corruption; effectiveness of law enforcement and criminal justice; and other jurisdictional characteristics.
- CRA scope and prioritization:
  - Assess only vulnerabilities applicable and sufficiently relevant to remittances corridors.
  - CRA can limit analysis to RSPs and bilateral corridor; some elements (e.g., legal entities) may be out of scope if focus is on payments by natural persons.
  - Consider cross-mitigation: low vulnerability in one corridor country can mitigate counterpart vulnerability.
- Vulnerability elements to include:
  - Products and services attractive for storing/transferring POC (cash accepting/disbursing remittances; debiting/crediting bank accounts; checks; pre-paid products; near cash instruments; ATM networks).
  - Delivery channels: degree of anonymity, share of cash, non-face-to-face transactions, agent networks, electronic money, virtual assets, and new financial technologies.
  - RSP customer base: identify higher-risk customer types (politically exposed persons, trustees, traders in high value goods, real estate agents disguised as individuals); TF-specific higher-risk client types may include certain non-profit organizations.
  - Preventive measures applied by RSPs: quality of originator/beneficiary identification, STRs, record-keeping, thresholds for originator/beneficiary information, reliability of national ID, TF targeted financial sanctions implementation, record-keeping and secrecy issues, adequacy and quality of STRs, agent network controls, detection of structuring schemes.
  - Cross-border cooperation: timeliness of access to information, cooperation between FIUs and supervisors, administrative cooperation, informal sharing of analyses and typologies.
  - Level of corruption: corruption generates proceeds and undermines AML/CFT effectiveness; staff integrity in law enforcement, FIUs, criminal justice, and supervisory agencies matters.
  - Effectiveness of law enforcement, FIU, and criminal justice: measured mainly by performance metrics (investigations, prosecutions, convictions, asset recoveries).
  - Effectiveness of AML/CFT supervision: focus on supervision quality regarding identification, STR reporting, record-keeping, and TF-specific measures where relevant.
  - Deficiencies in legal and regulatory frameworks: identify gaps that materially exacerbate vulnerabilities; compliance with FATF Recommendations 6, 9–11, 14, 15, 16, 20, 26, and 27 is particularly relevant.

### Assessment of consequences (ML and TF) and broader impacts
- Overall risk analysis combines likelihood (threat + vulnerability) and consequences (economic, political, social).
- Consequences include negative economic, political, and social outcomes from ML/TF occurrences, including longer-term and indirect consequences.
- ML consequences:
  - Examine impact on national objectives (reducing predicate crime and terrorism; protecting financial system integrity; meeting international obligations; avoiding misallocation of resources; preventing unfair competition; avoiding destabilizing financial flows).
  - Consequences may be limited for low value and low volume remittances; link amount laundered to ML consequence.
  - Differences by predicate crime: laundering proceeds of drug trafficking may have higher consequence than laundering proceeds of low-scale tax evasion.
- TF consequences:
  - Even low amounts can have significant consequences; focus on intended use, cost/damage, and impact on national objectives.
  - Consider TF stages (raising, pass-through, utilization); consequences vary by stage.
- Consequences of risk-mitigating measures:
  - Applying measures incommensurate with risk (risk-insensitive measures) increases compliance costs, raises barriers to entry for RSPs, reduces competition, and may cause loss of banking access for non-bank RSPs.
  - Inappropriate strict measures can push flows to informal channels (hawala, cash couriers), making detection and asset recovery more difficult.
  - CRA should assess risks of shifts to informal mechanisms and balance mitigation against potential negative consequences.
- Informal remittance channels:
  - CRA should account for existence and relative ML/TF risk of informal channels and structural factors (cash border controls; extent of cash-based economy and informal sector).

### Conclusions and policy implications
- Consolidation of ML/TF risk and assessment steps:
  - Determine overall ML/TF risk by consolidating threats, vulnerabilities, likelihood, and consequences.
  - Steps: understand threat indicators (domestic and foreign), determine overall vulnerabilities, combine threat and vulnerability to deduce likelihood, analyze consequences to determine overall corridor risk.
  - CRA is mainly based on inherent risk assessment, but control factors and monetary thresholds or restrictions may be integral for SRC determination.
- Divergence and granularity:
  - Ex-ante lower-risk perceptions may not be confirmed; for SRC designation both ML and TF risks need to be "lower."
  - Even when overall risk is medium or high, some sub-categories may be lower risk and warrant granular assessment.
- Designation of SRCs and monetary thresholds:
  - CRA conclusions can isolate and designate certain remittance activities as SRCs by identifying key threats and vulnerabilities.
  - SRCs can be achieved by combinations of monetary thresholds and restrictions on riskiest activities that can be practically distinguished and isolated; thresholds may apply to single transactions or annual aggregate values.
- Benefits for private sector and smaller providers:
  - Establishing lower-risk corridors allows prioritization of risk mitigation by RSPs, banks, and correspondent banks.
  - CRA assists RSPs—especially smaller ones lacking capacity—in implementing risk-based approaches and improving STR quality.
  - CRA findings provide TF risk information not always available to private sector and help banks assess relationships with RSPs operating in SRCs.
- Supervisory incorporation and formalization:
  - Supervisors should internalize CRA findings into supervisory strategies and calibrate expectations and oversight of RSPs in SRCs.
  - Some countries may formalize SRCs in regulation or secondary legislation (defining corridor countries, monetary thresholds, eligible products, delivery channels, RSP types, customers, and simplified measures).
- National prioritization and capacity building:
  - CRA enables prioritization of national-level measures to lower ML/TF risks for an SRC; some actions require national-level change while others are agency-specific.
  - For recipient countries reliant on remittances, CRA can provide a roadmap for strengthening AML/CFT regime aspects.
- Simplified CDD, exemptions, and safe harbor:
  - For safe, lower-risk corridors, customer due diligence (CDD) may be simplified: basic identification/verification, STRs, monitoring against targeted financial sanctions lists, and prohibition against structuring.
  - In "proven low-risk scenarios," countries may consider exemptions from certain AML/CFT requirements.
  - Streamlined/centralized processes (e-KYC, transaction databases) can facilitate verification, monitoring of PEPs and UN Security Council TF lists, and reduce remittance costs.
- Examples and liability protections:
  - Some regulators provide relief from liability in low-risk scenarios focused on customer identification/verification and administrative breaches.
  - One country is considering liability protections for RSPs in lower-risk scenarios contingent on full implementation of simplified measures and review of extending protections to banks with RSP clients.
- Consistency and benchmarking:
  - Using a methodology comparable to national or sectoral risk assessments ensures consistent treatment of similar risk levels across sectors and products.
  - Corridor countries can benchmark CRA-identified risk levels against exempted activities or existing simplified due diligence allowances and against other corridors.

*Source: IMF–World Bank Group report framework on remittance corridor risk assessment (BB7 deliverable).*

### 1.1 Objective of a Remittance Corridor Risk Assessment (CRA) .............................................. 8

### 1.1 Objective of a Remittance Corridor Risk Assessment (CRA)

### Context and rationale
- Remittances are described as "the financial lifeblood" for families of migrant workers and many emerging markets and developing economies (EMDEs).  
- Remittances may pose money laundering and terrorist financing (ML/TF) risks depending on: the sender and/or recipient country context, scale and characteristics of criminal activities, and terrorism in transactions.  
- If ML/TF risks are not understood and mitigated effectively, a remittance corridor could be abused by criminals, organized crime groups, terrorists, and terrorist organizations, potentially undermining national security, social order, and economic stability on both sides of the corridor.  
- Risk-based AML/CFT measures in line with Financial Action Task Force (FATF) standards enable prioritization of measures and calibration of regulatory frameworks to reduce costs of compliance for lower-risk transactions.  
- The G20 Roadmap for Enhancing Cross-Border Payments (endorsed at the October 2020 Finance Ministers and Central Bank Governors meeting) comprises 19 building blocks (BBs). The IMF and the World Bank were assigned to cover BB7 on "safe payment corridors," involving development of a framework for remittance corridors’ risk assessments. BB7 is part of focus area B.  
- BB7 has two phases: Phase 1 develops a framework and methodology for ML/TF risk assessment in remittance corridors and identification of potential "lower risk corridors"; Phase 2 expects pilot testing and refinement of the assessment methodology. The report uses the term "safe remittance corridor" (SRC) rather than "safe payment corridor."

### Objective of a CRA (as stated in the report)
- The objective of a CRA in the context of BB7 is assessing and understanding the ML/TF risks of remittances in a corridor, with the aim of simplifying AML/CFT measures in lower risk remittance transactions.  
- If the CRA assesses that the overall ML/TF risk level in the corridor is lower, the corridor can be treated as an SRC and subject to simplified customer due diligence (CDD) measures by regulatory authorities, which can be implemented by the private sector.  
- The process primarily involves assessment and identification of lower risks as the basis for CDD simplifications on a policy and regulatory level, and communicating assessment results to the private sector to assist with their own customer risk assessment.  
- Formal declaration of an SRC by a national or supranational agency is not required; the CRA may also identify lower-risk sub-categories of remittances (e.g., below a certain value, a lower risk product, or a lower risk region) that qualify for CDD simplifications.  
- Factors that may contribute to lower ML and TF risks include: low levels of organized crime and terrorism on both sides of the corridor, low average transaction values, remittances between family members, and a reliable ID infrastructure.  
- The identification of SRCs based on a robust CRA aims to reconcile two policy goals: supporting poverty alleviation and economic growth by safeguarding cost-effective transfers, and minimizing the risk of criminal or terrorist misuse of these mechanisms.  
- Effectiveness of SRC frameworks depends on their ability to inform regulatory and supervisory oversight of global and regional banks and other financial institutions that facilitate remittances.  
- The report proposes a draft framework and methodology for ML/TF risk assessment in remittance corridors with potential to be identified as SRCs and is the deliverable of BB7 Phase 1; the framework can be applied jointly or separately by sender and recipient countries.  
- The term "international remittances" in the report refers to cross-border person-to-person and non-commercial payments of relatively low value, adopting primarily the Committee on Payments and Market Infrastructures’ (CPMI) definition with the qualifier "non-commercial."

### Key definitional note
- The term "Safe Remittance Corridor" does not imply an absence of ML/TF risks in the corridor, but rather a lower risk level.  
- To qualify a payment corridor as safe, it would also be relevant to conclude a lower risk of proliferation financing or illicit finance, including tax evasion.

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### 1.2 Defining the scope of the assessment
- The CRA process should begin with defining the scope of the assessment. The scope should clarify the following elements:

- a) Corridor(s) to be assessed:
  - A "corridor" refers to a pair of a remittance origination jurisdiction (sending) and a remittance recipient jurisdiction.
  - A corridor assessment can be carried out jointly or unilaterally by the "sender" or the "receiver" country; in practice, it can be expected that in most scenarios it will be conducted by a sender country with contributions from the recipient country, as feasible.
  - The assessment may cover a single corridor or multiple corridors where risk factors are similar.
  - A sender or recipient country should consider the following factors when identifying corridors for a focused CRA:
    - Potential for the corridor to be classified as lower risk. It would not be recommended to engage resources in a CRA when there are clear indications of higher ML/TF risks.
    - Importance of the corridor for the immigrant community (e.g., number of people supported, amount of support as a share of GDP of the recipient country) and the host country (e.g., labor market contributions of the immigrant community).
    - How vital is the corridor for the immigrant community (and their dependents) and the host country?
    - How important is the corridor for the economic development of the recipient country?
    - Are there challenges in sending or receiving remittances? If yes, what are the challenges?
    - High remittance costs in the corridor.
    - Indications of de-risking of the clients or the service providers in the corridor.
    - The extent of the informal money transfer channels in the corridor.
    - Prevalence of cash couriers in the corridor (declared or undeclared).
    - Feedback/requests from private sector.
    - Complaints/requests from migrant communities that use the corridor.

- b) Uni-directional or bi-directional assessment:
  - A CRA can be unidirectional (focusing on remittances in one direction) or bidirectional (covering both directions).
  - Unidirectional CRA is particularly useful for corridors dominated by transactions in one direction or where the risk profile varies significantly by direction.
  - In most cases, the assessment can be expected to be unidirectional, as most corridors are heavily dominated by remittances in one direction.

- c) Overall corridor assessment vs. assessment of sub-categories of remittances:
  - The risk assessment may evaluate the overall risk level of a remittance corridor and/or sub-categories of remittances within the corridor.
  - It is recommended that CRAs distinguish risk levels of different sub-categories, which can be based on: transaction amounts, origin and destination, sender and receiver characteristics, type of RSP and remittance products, delivery channels, or combinations thereof.
  - Even if the overall ML/TF risk is medium or high, some sub-categories may be lower risk (e.g., a medium TF risk corridor where likelihood of raising funds for terrorists concentrates in a specific region).

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### 1.3 Domestic and international cooperation
- a) Domestic cooperation:
  - Domestic and international cooperation among stakeholder agencies is particularly relevant for CRA success.
  - Domestic contributors can include:
    - the financial intelligence unit;
    - relevant financial sector regulators and supervisors (of banks, money transfer operators (MTOs), and other non-bank financial institutions);
    - financial inclusion unit or team at the central bank (or another agency);
    - payment systems, national accounts, and other relevant departments of central banks;
    - law enforcement, prosecutorial, and intelligence agencies (as necessary);
    - customs and immigration authorities;
    - the statistics agency.
  - Depending on functions and information collected, some stakeholders should play a key role while others contribute data or viewpoints.
  - Private sector involvement is important; relevant non-governmental organizations (NGOs) can contribute to understanding immigrant communities, informal remittance channels, and CDD challenges (including movement of funds for humanitarian purposes).
  - In countries where centralized remittance data collection is problematic, collaboration with relevant private sector players is essential.
  - It is recommended to assign a lead agency, a project leader, and a team for a CRA.

- b) International cooperation:
  - Ideally, corridor countries should carry out CRAs jointly to maximize access to data and information (including from the NRA) and to bring two perspectives together for a more complete and robust assessment.
  - Joint assessments facilitate commitment and coordination in addressing recommendations, mitigating risks, and introducing harmonized regulations and supervisory approaches as appropriate.
  - If a joint assessment is impossible, the conducting country should coordinate with the other country to keep it informed and obtain inputs and data; bilateral meetings and inviting the counterpart to participate in project activities or the project team can be effective for coordination and information exchange.

*Source: IMF–World Bank Group report framework on remittance corridor risk assessment (BB7 deliverable).*

### 1.4 Data Requirements and Sources

### g20-methodology-for-remittance-corridor-risk-assessment - 1.4 Data Requirements and Sources

### Role of quantitative and qualitative data in remittance CRAs
- The methodology emphasizes that both quantitative and qualitative data sources are important components of remittance CRAs and that a good risk assessment balances their use.
- Adequate and reliable quantitative and qualitative data reduce subjectivity and lead to informed judgements; however, the CRA will retain a subjective element requiring expert analysis, evaluations, and judgements.
- Countries should ensure involvement of qualified experts and have quality-control mechanisms for the assessment.
- Annex 1 contains a list of possible qualitative and quantitative data sources that can support a CRA; the list is illustrative and does not imply all listed data must be collected for any CRA.
- Data collection for a CRA should be focused and efficient, making best use of existing data and considering additional data based on the value they add.

### Use of National ML/TF Risk Assessments (NRAs)
- NRAs can be used as a foundation of remittance CRAs; if a country already has a recent and reliable NRA, its analysis and conclusions can inform the CRA.
- As per FATF Recommendation 1, understanding and assessing ML/TF risks is mandatory and constitutes the backbone of the AML/CFT regime.
- Since 2014, almost all countries have conducted their first NRAs and many update their risk assessments every 3 to 5 years.
- The CRA can rely on corridor countries’ NRAs for analysis of the general ML/TF risk environment, including typologies and trends in generation and laundering of proceeds of crimes (POC), funding of terrorist activities and organizations, and abuse of sectors and products for ML and TF.
- If an NRA is being conducted or about to be conducted, CRA timing may be planned so the NRA outputs can inform corridor risk assessments; conducting both in parallel may generate synergies.
- Ideally, the corridor risk assessment should consider NRAs of both countries in the corridor. Where a corridor country has not publicized its NRA, exchanging and incorporating relevant information is important.
- A memorandum of understanding between the two countries and involvement of a wider group of stakeholders from both countries can contribute to smoother cooperation and coordination in conducting the risk assessment.
- Reference: FATF Guidance on the National Money Laundering and Terrorist Financing Risk Assessment (footnote 5).

### Assessing the environment of the two countries and contextual factors
- Understanding economic and other links between corridor countries (trade, investment, remittances, predicate crimes spanning both countries) provides a useful backdrop to analyze corridor risks and to isolate lower-risk activities.
- The CRA should focus on country ML/TF risk factors relevant to the specific corridor being assessed.
- Migration and related data should be analyzed to estimate potential remittance flows:
  - Statistics on number of naturalized citizens, permanent residents, seasonal workers, longer-term visitors, and estimates of illegal migrants originating from the recipient corridor country can identify sources of remittances and estimate potential maximum value.
  - This potential value can approximate an upper bound for the corridor's value and number of remittances, useful for examining discrepancies between potential and actual flows.
  - Size of migrant community, geographic distribution, and average income can be cross-checked with value, volume, and location of remittances.
  - Information on labor market and guest worker policies can provide additional understanding of remittance sources.
- Characteristics of remittance payments to include in a CRA:
  - volume, value, periodicity, purpose, and currency composition.
  - Currency composition may impact settlement arrangements, CRA stakeholders, and possibly the need to consider actions of supervisors and regulators of other countries.
  - Contextual factors such as migrant community access to banking services affect purpose and characteristics of remittances (example: seasonal employment programs may lead to less frequent but higher value remittances).
- CRAs need to consider risks related to organized crime groups, terrorist organizations, and predicate crimes that span both countries:
  - Existence, nature, and operations of serious and organized crime groups, terrorist organizations, and predicate crimes that span both countries help assess likelihood of corridor abuse.
  - Evidence of cross-border organized crime activity combined with high volumes and average values of remittances may preclude identifying a corridor as lower risk.
- Geographic variability:
  - Some countries have regional ML/TF risk variability; originator or beneficiary regions may pose higher ML/TF risks (examples: illegal mining of precious stones, illegal logging, attractiveness for real estate investment).
  - Identifying higher ML/TF threats at regional level allows CRAs to provide more granular delineations of lower-risk activities.
- Note: References to NRAs apply to sectoral risk assessments (e.g., financial sector) conducted as part of or in addition to NRAs (footnote 6).

### Assessment of threats in the remittance corridor — overview
- The estimated volume of proceeds of crimes (POC) in a country broadly determines overall potential for money laundering.
- ML threat assessment logically starts with analysis of POC; POC include funds and assets derived directly and indirectly from domestic or foreign predicate offenses.
- An ML threat assessment consists of:
  - a list of various types of crimes with an estimate of their importance in generating proceeds in the country; and
  - analysis of factors impacting the probability that proceeds of the main crime types would be laundered through the remittance corridor.
- The methodology notes that main proceed-generating crimes (e.g., corporate tax evasion, corruption) may pose lower ML risk to a specific remittance corridor despite being large sources of POC nationally.
- Layers of threat assessment (as illustrated in Figure 1):
  - Proceeds of crimes (the pool of funds and assets derived from crimes)
  - Likelihood of money laundering attempts in the country
  - Likelihood of money laundering attempts through the remittances in the payment corridor
  - Likelihood of money laundering attempts in the payment corridor*  
    - *“Payment corridor” in the chart refers to the broader group of cross-border payments that include non-remittance transactions.

### Understanding proceeds of crime and ML threat
- CRA should describe nature and scale of predicate crimes and POC where possible; CRAs are not expected to undertake full-fledged POC assessments and can rely on NRAs, credible academic studies, expert perceptions, and competent authority reports.
- Analysis should be broader than confiscation records and capture POC that may not have been confiscated; records and estimates about criminal goods and activities (e.g., smuggled drugs or arms) may help estimate POC.
- CRA can explore attractiveness of corridor countries for foreign POC to analyze risk from layering stage of money laundering.

### Assessing ML threat in the payment corridor and specifically to remittances
- The ML threat in the payment corridor is defined as the probability of money laundering attempts in the payment corridor from the home country to the recipient country.
- Factors increasing that likelihood include demographic, geographic, socioeconomic relationships and attractiveness of the recipient country (e.g., role as a regional/global financial center or links to organized criminal groups).
- Assessment should analyze quantitative information and complement with qualitative information:
  - Quantitative examples: money laundering cases, information exchange requests, suspicious transaction reports that involve the payment corridor; analyze in absolute terms and relative to other corridors.
  - Money laundering typologies can indicate whether institution types, products, and services present in the corridor have been used for ML.
- ML threat to remittances may differ from overall ML threat in a country:
  - Consider remittance-corridor-specific factors influencing probability that POC from various crimes pass through the remittance corridor.
  - Use country context, typologies, serious and organized crime assessments, and demographic data on detected crimes to focus on crime types most relevant to the corridor.
  - Factors shaping ML threats to remittances include nature of underlying crimes (petty vs. organized), use of POC (consumption vs. laundering), and composition of POC (financial vs. physical assets).
- Remittance-specific considerations:
  - Low amounts per transaction limit utility of remittances for large ML operations; laundering via remittances may require numerous low-amount transactions.
  - Examples of micro-scale laundering: smurfing or structuring—may be feasible for organized crime groups depending on identification infrastructure and demographic links.
  - CRA should examine past ML cases and typologies to assess existence and extent of smurfing and structuring in the corridor and linked corridors.
- Strategic analysis is important:
  - Verify whether remittance flow patterns align with stated rationales (seasonality, purposes, senders, receivers).
  - Analyze total remittances in the corridor; seasonal patterns; purposes; frequency of transactions in different monetary tranches; average amounts remitted; relationship with average income; and relationships with macroeconomic and demographic indicators.

*G20/IMF Methodology for Remittance Corridor Risk Assessment (sections 1.4–1.6).*

### 1.7 Terrorist Financing Threat

### 1.7 Terrorist Financing Threat

### Basic TF scenarios in a payment corridor
- Scenario 1: Funds originated in the sender country are sent to the terrorist entities in the recipient country.
- Scenario 2: Funds originated in a third country are sent to the terrorist entities in the recipient country through the sender country.
- Scenario 3: Funds originated in the sender country are sent to the terrorist entities in a third country through the recipient country.

### Key determinants of TF threat
- The terrorism context in the recipient country is one of the most important factors determining TF threats in the payment corridor; presence of consequential terrorist activities and terrorist organizations in the recipient country is critical to assess.
- Input and cooperation from counter-terrorism and intelligence authorities and information exchange with recipient country authorities are key.
- Existence of terrorist groups/activities in the recipient country does not necessarily imply high TF threat in the corridor; the assessment must examine potential and rationale for using the corridor for TF.
- Important assessment questions:
  - Are terrorist activities and organizations in the recipient country mostly funded domestically or internationally?
  - If internationally, why would these terrorist organizations prefer the payment corridor being assessed and how would they use it?
- Cultural, demographic, and socioeconomic factors in sender and recipient countries should be considered, including immigrant communities in the sender country and ethnic or ideological proximity that may link sympathizers to terrorist organizations in the recipient country.

### Use of quantitative and qualitative information
- Principles applied to ML threat assessments also apply to TF threat assessments.
- Understand patterns and behaviors in terrorist financing in both sender and recipient countries through:
  - Past typologies and detected cases.
  - Qualitative information: typologies, subject-matter expert observations, interviews with NGOs or immigrant communities, and interactions/interviews with recipient-country authorities.
- Assess attractiveness of the sender (home) country as a transit point for TF transactions (relevant to Scenario 2):
  - If recipient country with terrorism risks has limited access to the global financial system and the sender country constitutes its main gateway, TF threat to the corridor may increase.
  - Close socio-economic relations and frequent transactions from third countries known or suspected to have sympathizers of terrorist organizations in the corridor (recipient) country are additional factors.
  - Scenario 2 is more likely if the sender country is a global or regional financial hub.
- Scenario 3 considerations:
  - Use of the recipient country as a transit to support terrorist organizations in a third country increases if the sender country (based on ethnic, demographic, ideological factors) has limited direct access to financial systems of the third country or the recipient country is attractive for TF transactions.

### Assessment of vulnerabilities in the remittance corridor
- Vulnerability definition: properties of AML/CFT regime aspects that can be exploited by ML/TF threats to enable ML/TF abuse.
- ML/TF vulnerabilities comprise intrinsic properties of products, services, distribution channels, customer bases, private sector entities, systems, institutions, and jurisdictions (including weaknesses in AML/CFT-relevant measures and controls).
- Vulnerability indicators can be grouped by geography; financial and non-financial services and products; levels of informality in sectors; weaknesses in AML/CFT systems and adequacy of controls; general levels of corruption; effectiveness of law enforcement and criminal justice; and other jurisdictional characteristics facilitating ML/TF.
- CRA scope and prioritization:
  - Only vulnerabilities applicable and sufficiently relevant to remittances corridors should be assessed.
  - CRA can limit analysis to RSPs and the bilateral remittance corridor; some elements (e.g., legal entities) may be out of scope if CRA focuses on payments by natural persons.
  - CRA may focus on specific components (e.g., effectiveness of cooperation between the two corridor countries rather than broader international cooperation).
  - CRA can consider country vulnerabilities not directly related to the corridor but which may affect reputation and country risk assessments of intermediary financial institutions.
- Consider cross-mitigation: low vulnerability in one corridor country can mitigate corresponding vulnerability in the other (e.g., effective preventive measures by RSP originator mitigating counterpart vulnerabilities; effectiveness of criminal justice, supervision, ML/TF detection, control of corruption).

### Vulnerability elements to include in the CRA
- Various products and services offered in the remittance corridor:
  - Focus on aspects attractive to money launderers for storing value or transferring POC.
  - Examples: cash accepting/disbursing remittances; debiting/crediting bank accounts; checks; pre-paid products such as electronic money; near cash instruments (travelers checks, money orders, pre-paid cards); ATM networks.
  - Starting point: analyze overall value and number of remittance transactions across different products/services to understand relative importance and attractiveness.
  - Consider RSP policies limiting value of single or connected cash and non-cash transfers; expert perceptions; FATF and FSRBs’ ML and TF typologies.
- Remittance delivery channels between the two countries:
  - Identify channels with higher perceived risk (e.g., higher degree of anonymity or low traceability).
  - Analyze share of cash in accepting and disbursing remittances.
  - Higher risks: conducting transactions on behalf of another person, non-face-to-face transactions, extensive use of agents for accepting/disbursing remittances.
  - Assess potential ML/TF vulnerabilities of agent networks, number of RSP branches/agents.
  - Consider materiality of electronic money, virtual assets, and new financial technologies; approximate share of higher risk products/services in overall value and number of transactions.
- RSP customer base:
  - Assess risk posed by customer types; distinguish higher risk for ML and TF customers.
  - When detailed customer data is unavailable, rely on expert perceptions or customer surveys to approximate shares.
  - Higher ML risk customer types: politically exposed persons, their family members and associates, trustees and other persons operating on behalf of others, traders in high value goods, and real estate agents (disguised as ordinary individual clients).
  - TF-specific higher-risk client types may include certain non-profit organizations misused for TF; where origin country raises funds for TF, identify likely donor and recipient profiles and approximate materiality.
  - Consider whether proceeds-raising crimes or sales of goods/services to raise TF funds indicate identifiable higher-risk customer types.
- Preventive measures applied by RSPs (sector-level assessment of extent and effectiveness):
  - Focus on quality of implementation of key preventive measures: identification of originator and beneficiary, suspicious transaction reporting (STRs), record-keeping.
  - Consider the extent to which effective implementation by one side mitigates counterpart vulnerability.
  - Specific CRA assessments:
    - Whether required and accurate originator and beneficiary information is always immediately available across RSP types; existence of thresholds below which only names and a transaction number are required; distinguish vulnerabilities of ordering vs beneficiary financial institutions; reliability of national identification documents and ease of transacting with false names or front persons.
    - For corridors with material TF threats, assess quality of implementation of targeted financial sanctions related to prevention and suppression of terrorism and terrorist financing, including whether RSPs can and are freezing, without delay and without prior notice, the funds of designated persons and entities, and effectiveness of national mechanism for timely communication of designations and guidance on obligations.
    - Vulnerability related to record-keeping and secrecy measures that lead to lack of or insufficient records or denial of timely access to records.
    - Adequacy of the number of STRs submitted by RSPs regarding payments in the assessed corridor and incorporation of feedback from relevant authorities (e.g., FIU, law enforcement) on quality/usefulness of these STRs for AML/CFT efforts.
    - If material reliance on agents exists, consider effectiveness of preventive measures in the agent network and whether functions are outsourced.
    - Consider measures RSPs apply to detect structuring schemes (splitting large transactions into small ones) to circumvent thresholds and suspicious activity reporting requirements.
    - If specific ML threats are identified, include analysis of impact of preventive measures for specific customers and activities.
- Cross-border cooperation between corridor countries:
  - Assess whether international cooperation delivers timely access to information and evidence located in the other corridor country and facilitates action against criminals and assets.
  - Cover cooperation between FIUs and supervisors; administrative cooperation; informal sharing of strategic analyses, typologies, trends, and emerging risks.
  - If other countries are relevant (e.g., third-country financial institutions involved in settlement), assess cooperation aspects with those countries (e.g., supervisors).
- Level of corruption in society:
  - Corruption generates proceeds (ML threat) and undermines the effectiveness of AML/CFT regime.
  - Staff integrity and absence of corruption in law enforcement, FIUs, criminal justice, supervisory agencies, and other relevant public agencies reduce probability of attempted ML/TF and compromised enforcement.
  - Consider corruption in the financial sector that can compromise preventive measures.
- Effectiveness of law enforcement, the FIU, and criminal justice system:
  - Consider efforts at crime suppression, detection/investigation of ML/TF, analysis/dissemination of quality financial intelligence, prosecution, and sentencing.
  - Focus on effectiveness related to ML/TF threats in the remittance corridor (e.g., analysis of STRs from RSPs specifically related to assessed corridor).
  - Assess based on powers/resources but mostly on performance metrics: number and complexity of ongoing investigations and cases sent to trial, number of convictions, value of asset recoveries.
- Effectiveness of AML/CFT supervision:
  - Effective supervision promotes stronger compliance by RSPs and prevents criminals from controlling RSPs.
  - CRA should focus on quality of supervision regarding key preventive measures identified by the CRA (identification, STR reporting, record-keeping).
  - For corridors with material TF risks, cover supervision of TF-specific preventive measures (targeted financial sanctions).
  - Engage AML/CFT supervisors for banks when different, as banks’ risk assessments of RSP clients provide valuable information given banks’ critical role.
- Deficiencies in legal and regulatory frameworks:
  - Identify gaps in laws/regulations that materially exacerbate vulnerabilities.
  - Focus on deficiencies related to preventive measures applied by RSPs, powers of relevant agencies, secrecy, and international cooperation.
  - Compliance with relevant elements of the FATF Recommendations 6, 9–11, 14, 15, 16, 20, 26, and 27 appears particularly relevant.
  - Note: FATF and FSRB mutual evaluation and follow-up reports can include valuable information on and reliable assessments of some vulnerability factors.

### Assessment of consequences (ML and TF)
- Overall risk analysis combines likelihood (threat + vulnerability) and consequences (economic, political, social).
- Consequences defined as negative economic, political, and social outcomes from ML/TF occurrences, including longer-term and indirect consequences.
- ML/TF consequences analysis:
  - Examine impact on national objectives (reducing predicate crime and terrorism; protecting integrity/soundness of financial system and public institutions; meeting international obligations and foreign policy goals; avoiding misallocation of resources; preventing unfair competition; avoiding destabilizing financial flows).
  - Use opinions/judgments of officials/experts and data relevant to consequence indicators (e.g., number of economic crime victims, terrorism-related deaths and other terrorism-related damages and costs, estimated value of ML/TF transactions relative to financial sector assets and GDP).
- ML consequences considerations:
  - Consequences can be limited for low value and low volume remittances; link amount laundered to ML consequence.
  - Larger-scale criminal activities requiring laundering of significant amounts may not be possible in some remittance corridors due to low corridor size or RSP operational constraints.
  - Remittance corridors with low average value and volume relative to country economies may have lower ML consequences.
  - Differences by predicate crime: laundering proceeds of drug trafficking may have higher consequence than laundering proceeds of low-scale tax evasion; CRA should consider types of crimes likely to be laundered in the corridor.
  - Consider how services and institutions abused for ML/TF impact ML consequences.
- TF consequences considerations:
  - Potentially even low amounts of successful TF can have significant consequences; intended use of TF funds can be more important than amount.
  - Base TF consequence analysis on cost, damage caused, significance of outcomes, and negative impact on national objectives.
  - Consider nature of possible TF events in the corridor, as different TF events impact national objectives differently.
  - TF consequences vary by TF stage (raising, pass-through, utilization). CRA should consider likelihood of corridor being abused at these stages.
    - Example: if material likelihood is only pass-through to third countries, consequences may be lower compared to raising or utilizing funds in corridor countries.
  - Consider terrorists/organizations using funds, intended purpose, donor profiles, crimes used to raise funds, source and destination countries for pass-through TF.
- Consequences of risk-mitigating measures:
  - Assess potential consequences of applying measures incommensurate with ML/TF risk (i.e., failing to apply a risk-based approach).
  - Risk-based AML/CFT allows efficient use of scarce public/private resources; CRA should assess consequences of not applying risk-based approach and of applying stricter measures than warranted.
  - Stricter measures than warranted increase compliance costs, raise barriers to entry for RSPs, reduce competition, and increase costs—affecting national objectives in social, labor, and foreign policies.
  - Insufficient risk sensitivity can cause non-bank RSPs to lose or struggle to maintain access to banking services.
  - Applying regular/enhanced measures to lower-risk corridors increases costs and unintended AML/CFT-relevant consequences.
- Informal remittance channels and unintended shifts:
  - Inappropriate risk-insensitive measures in formal channels can make informal channels more attractive (e.g., hawala-type networks, cash couriers, barter exchanges).
  - CRA should account for existence and relative ML/TF risk of informal channels.
  - Consider structural factors exacerbating/mitigating informal channel risks (cash border controls; extent of cash-based economy and informal sector).
  - Analyze AML/CFT consequences of shifts to informal mechanisms (difficulties detecting, tracing, confiscating proceeds and TF funds).
  - Balance mitigation of ML/TF risks in lower-risk corridors against potential negative consequences of inappropriate risk-mitigating measures.

*International Monetary Fund — G20 Methodology for Remittance Corridor Risk Assessment, Section 1.7*

### Conclusions

### G20 Methodology for Remittance Corridor Risk Assessment — Conclusions

### Consolidation of ML/TF risk and assessment steps
- Overall ML/TF risk for an assessed remittance corridor is determined by consolidation of ML/TF threats, vulnerabilities, likelihood, and consequences.
- First step: understand ML/TF threat indicators originating from domestic as well as foreign sources (Section 4).
- Second step: determine overall ML/TF vulnerabilities of the remittance corridor as a function of inherent vulnerabilities and factors such as products, channels, customers, and the effectiveness of preventive measures (Section 5).
- Combine threat and vulnerability assessments to deduce the likelihood of a risk event.
- Analyze direct and indirect short- and long-term negative consequences of a risk event to determine overall corridor risk (Section 6).
- CRA is mainly based on assessment of inherent risks, but some control factors and monetary thresholds or restrictions on users may be integral elements for SRC determination.

### Possible divergence between ex-ante perception and CRA findings; granularity
- Ex-ante lower-risk perceptions may not be confirmed by the CRA; assessments may result in medium or higher ML/TF risks.
- For designation as a Safe Remittance Corridor (SRC), both ML and TF risks need to be “lower”; either category assessed as medium or higher may undermine corridor safety.
- Even when overall ML or TF risk is medium or high, some remittance sub-categories can be lower risk; CRA may be expanded to more granular assessments of sub-categories.

### Designation of SRCs, monetary thresholds, and isolating lower-risk activities
- CRA conclusions can be used to insulate and designate certain remittance activities as an SRC.
- CRA provides granular identification of key threats and vulnerabilities driving ML/TF risks in the corridor.
- Authorities can isolate products, delivery channels, types of RSPs, and customers that pose lower risk when the overall corridor does not qualify as lower risk.
- SRC can be achieved by imposing combinations of monetary thresholds and restrictions on the riskiest remittance activities that can be practically distinguished and isolated.
- Monetary thresholds can apply to both single occasional transactions as well as the annual value of transactions.

### Benefits of CRA for RSPs, banks, and smaller providers
- Establishing lower-risk corridors allows prioritization of risk mitigation measures by RSPs, their banks, and correspondent banks.
- CRA assists RSPs to accurately identify and assess ML/TF risks related to their operations, enabling effective implementation of a risk-based approach and improved suspicious transaction reporting.
- CRA conducted by authorities is an important information source for RSPs, especially on TF risks not always available to the private sector.
- CRA is particularly useful to smaller RSPs and those lacking capacity to conduct adequate risk assessments, enriching understanding of ML/TF risks.
- CRA helps banks assess risks of business relationships with RSPs operating in an SRC and with respondent banks facilitating corridor remittance payments.

### Supervisory incorporation and possible formalization
- AML/CFT authorities, particularly supervisors, should internalize CRA findings and incorporate results into supervisory strategy and activities.
- Supervisors must calibrate attention to RSPs’ activities in the SRC commensurate with identified risk and communicate supervisory expectations (e.g., acceptable documents for identification and verification).
- Banking supervisors should take CRA conclusions into account when guiding and assessing banks’ management of ML/TF risks associated with RSP clients.
- Where financial institutions in third countries facilitate remittance payments, CRA results can be usefully communicated to supervisors of those institutions.
- Some countries may formalize the SRC in regulation/secondary legislation defining corridor countries, monetary thresholds, eligible products, delivery channels, types of RSPs, customers, and simplified measures or exceptions based on CRA conclusions.

### National prioritization, capacity building, and recipient-country roadmaps
- CRA enables prioritization of national-level risk mitigation measures to achieve lower ML/TF risks for an SRC.
- Some threats and vulnerabilities require national-level action; others can be addressed by a single agency (e.g., strengthening supervision of RSPs and enhancing preventive measures).
- For recipient countries reliant on remittances, CRA can provide a roadmap of AML/CFT regime aspects that need strengthening to lower ML/TF risks.

### Simplified CDD, exemptions, and safe harbor approaches
- For safe, lower-risk remittance corridors, customer due diligence (CDD) requirements can be simplified in a risk-based manner.
- Simplified due diligence measures for lower-risk remittance transfers can include basic controls such as identification (and verification) of originator and beneficiary, suspicious transaction reporting, monitoring against targeted financial sanctions lists for terrorism and TF, and prohibition against structuring.
- If CRA identifies absolute and proven low ML and TF risks, countries may consider exemptions from certain AML/CFT requirements in “proven low-risk scenarios,” where full AML/CFT measures may not be in line with corridor risk.
- Streamlined and centralized processes (e-KYC and transaction databases) can facilitate faster verification of ID information, development of customer profiles, monitoring of PEPs and UN Security Council TF lists, and unusual/suspicious transactions, potentially reducing remittance costs.

### Examples and liability protections
- A handful of regulators provide relief from liability to financial institutions in low-risk scenarios/transactions; current safe harbor policies have focused on customer identification and verification and administrative breaches.
- One country is considering liability protections for RSPs in lower-risk scenarios provided all simplified measures required in the safe payment corridor are fully implemented, and is reviewing extending such protections to banks with RSP clients, provided banks ensure RSP clients operate strictly in the safe payment corridor and apply required simplified measures.
- Footnote references: FATF Interpretive Note to Recommendation 10 contains information on ML/TF lower-risk situations and examples of simplified CDD measures; additional examples and country practices are noted in existing guidance and policy documents referenced in the CRA.

### Consistency across sectors and benchmarking
- Using a methodology comparable to national or sectoral risk assessments when conducting the CRA helps ensure consistent treatment of similar risk levels across sectors and products.
- Corridor countries can compare CRA-identified risk levels with exempted activities or existing simplified due diligence allowances from national risk assessments.
- Benchmarking the CRA against other corridors or overall cross-border remittance payments provides additional insight into relative ML/TF risk and measure consistency.

### Annex 1 — Possible data and information sources for a Corridor Risk Assessment
- Quantitative sources include: granular international funds transfer data by RSPs in the corridor; STRs and TTRs submitted by RSPs to the FIU; data on ML and TF cases and typologies from law enforcement, Prosecutor’s Office, and FIU databases; statistics on ML- and TF-related international legal assistance requests; enforcement and intelligence data on terrorism threats and financial flows; enforcement data on relevant predicate offenses; national identification infrastructure suitability for ID verification; statistics on fraudulent ID use; information on quality and effectiveness of CDD, transaction monitoring, and AML/CFT systems; data on customers, products, delivery channels, transaction value and volume, and cash usage; governmental criminal intelligence reports; data on effectiveness of supervisors, law enforcement, and the criminal justice system; and data on effectiveness of private-sector AML/CFT controls.
- Qualitative sources include: findings from FATF and FATF-style regional body mutual evaluation reports; national ML/TF risk assessment reports of corridor countries; sectoral and institutional risk assessment reports available to supervisors; reports by international organizations on crime environment and ML/TF trends; interviews and focus groups with AML/CFT authorities, police, law enforcement, and criminal intelligence agencies; consultations with RSPs, industry experts, and industry associations; surveys of AML/CFT authorities, service providers, private sector, NGOs, immigrant communities, and remittance-dependent households; literature on remittance businesses; credible informal sources on ML/TF methods, typologies, and trends; and credible news reports and public information on the assessed remittance corridor.

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_Source: https://www.imf.org/-/media/files/research/imf-and-g20/2021/g20-methodology-for-remittance-corridor-risk-assessment.pdf_