## Anti-Money Laundering/Combating the Financing of Terrorism Thematic Fund (AML/CFT)

## Source details

**Canonical URL:** [Anti-Money Laundering/Combating the Financing of Terrorism Thematic Fund (AML/CFT)](https://www.imf.org/-/media/files/topics/aml-cft/fy25-1174850-aml-cft-factsheet-final.pdf)

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- [Markdown version](/-/media/files/topics/aml-cft/fy25-1174850-aml-cft-factsheet-final.pdf.md)
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### Key facts and scope
- The AML/CFT Thematic Fund was established in 2009 and is in its third Phase of operations.
- Twelve partners financed over US$30 million in comprehensive and targeted AML/CFT capacity development activities.
- Over 40 CD projects have been implemented, reaching 57 countries:
  - 22 single-country projects
  - 2 regional projects covering 7 countries (two Pacific Island countries and five Middle East and North Africa countries)
  - 10 thematic projects benefiting 29 countries
  - 2 analytical and development (A&D) projects
  - CD delivery through 5 regional advisors (RAs)
- The TF recently helped Jordan, Jamaica, and Uganda exit the grey list of the Financial Action Task Force, assisted Haiti in upgrading its Financial Intelligence Unit, and funded two publications on counter terrorism financing and beneficial ownership.

### Approach to capacity development (CD)
- Phase III employs a combination of:
  - Modular medium-term, tailor-made engagements for comprehensive reforms:
    - Tailor-made solution
    - For Medium-term engagements (2–3 years)
    - For recipients with multiple needs
    - Programmatic approach with many outcomes
    - More resource-intensive
  - Thematic short-term targeted engagements based on themes:
    - Engagement in one area only
    - Shorter engagements (6M-1Y)
    - For recipients with specific need
    - Smaller teams and more flexible delivery
    - Less resource-intensive
  - Research and development for medium-term design of CD tools:
    - Highlight AML/CFT challenges and good practices by IMF members
    - Research to further design and finetune the available CD toolkit
- The approach facilitates country projects with clear objectives, outputs, and indicators against which progress can be measured.

### AML/CFT CD products and focus areas
- National Risk Assessment: Help members understand their risks and develop policy priorities
- National Strategy: Develop AML/CFT and financial integrity strategies
- Legal Drafting: Align the AML/CFT legal framework with international standards and good practices
- Risk-based Supervision: Enhanced risk-based supervision of banks, non-banks, financial institutions, and designated non-financial businesses and professions
- Financial Intelligence Units (FIU): Enhance the governance, structure and tools of FIUs
- AML and Corruption: Prioritize the AML framework to tackle proceeds of corruption
- AML and Tax Crimes: Prioritize the AML framework to focus on tax crimes and ensure revenue compliance
- Beneficial Ownership (BO): Ensure national or sectoral BO information is collected, accurate, and easily accessible
- Central Bank Digital Currency (CBDC) and Financial Integrity: Ensure CBDC design includes measures to limit criminal misuse
- Combating the Financing of Terrorism (CFT): Enhance measures to detect and deter terrorism financing with a focus on fragile and conflict states
- Support to AML/CFT Conditionality: Quick TA intervention to help countries meet their AML/CFT conditionality under IMF lending
- Post Mutual Evaluation Engagement: Quick TA engagement to address strategic deficiencies that could prevent an IMF member for FATF listing
- Unusual Financial Flows Analysis: Analysis of cross-border payments to detect ML risks and a diagnostic of AML/CFT measures to address non-resident risks
- Virtual Assets: Ensure proper regulatory framework for virtual asset service providers and appropriate risk-based supervision to prevent misuse of virtual assets for criminal misuse

### Results and concrete outcomes under Phase III
- Passage of a new AML/CFT law in Bosnia and Herzegovina and amendments to AML/CFT laws in Tajikistan.
- Comprehensive National ML/FT risk assessments conducted in Bhutan and Jordan.
- Risk-based approach tools to AML/CFT supervision implemented in Guatemala.
- Enacted Law organizing the Financial Intelligence Unit in Haiti.
- Improvements to AML/CFT frameworks leading to removal from the FATF’s International Cooperation Review Group’s (ICRG) grey list of countries such as Jordan and Uganda.
- Launching thematic projects on emerging issues that benefited a large set of countries.
- Publication of two flagship research books:
  - Countering the Financing of Terrorism: Good Practices to Enhance Effectiveness
  - Unmasking Control: A Guide to Beneficial Ownership Transparency (TBO)
  - Both books highlighted significant deficiencies, led to new CD tools in thematic projects, and benefited the AML/CFT community at large.
- Adoption and implementation of regulations requiring the publication of beneficial ownership information of companies awarded procurement contracts as part of the project on preventing misuse of COVID-19 emergency-related spending and to safeguard against the misuse of IMF emergency financing.

### Analytics, innovation, and program evolution
- The AML/CFT TF Analytics and Development (A&D) component produces AML/CFT publications and tools that shape CD delivery.
- A&D projects inform future CD delivery through CD tool development and benefit from Fund staff AML/CFT expertise.
- Two books on beneficial ownership and counter terrorism financing have been published; upcoming publications on confiscation and asset recovery issues and an e-learning course on risk-based supervision are underway.
- Current efforts aim to fully align the AML/CFT CD program with the Fund’s reviewed CD strategy—towards a more flexible, integrated, and tailored model.
- The 2023 Review of the AML/CFT strategy endorsed by the Board was used to take stock of the CD program and agree on a way forward; stakeholder feedback highlighted program strengths.

### Strategic coordination, regional balance, and demand
- Project teams regularly coordinate with other CD providers to avoid duplication and enhance complementarity.
- Regional advisors engage with FATF-Style Regional Bodies (FSRBs) and play a key role in project development and implementation.
- Frequent coordination with donor partners, other CD providers, and international/regional organizations ensures best use of AML TF III resources and maximizes project effectiveness.
- Demand for AML/CFT CD remains high and is prioritized to achieve regional balance, avoid duplication of efforts, and ensure synergies between IMF CD and the IMF’s Surveillance program.

### Thematic Fund spending by region (percentages)
- Europe: 5%
- IMF Headquarters: 3%
- Africa: 25%
- Asia and Pacific: 25%
- Middle East and Central Asia: 23%
- Western Hemisphere: 19%

### Development partners (listed partners)
- CANADA
- JAPAN
- ITALY
- THE NETHERLANDS
- SWITZERLAND
- UNITED KINGDOM
- QATAR
- SAUDI ARABIA
- KOREA
- LUXEMBOURG
- FRANCE
- GERMANY

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_Source: https://www.imf.org/-/media/files/topics/aml-cft/fy25-1174850-aml-cft-factsheet-final.pdf_