Review of the IMF’s Anti-Money Laundering and Combating the Financing of Terrorism Strategy

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The International Monetary Fund (IMF) conducted a review of its 2018 Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) Strategy (“The AML/CFT Strategy”).
Effective AML/CFT policies and measures are described as key to the integrity and stability of the international financial system and member countries’ economies.
Money laundering (ML), predicate offenses, terrorist financing (TF), and proliferation financing (PF) are characterized as crimes with economic effects that can threaten financial-sector integrity and external stability.

Public consultation for Civil Society Organizations (CSOs): April 11 – May 21, 2023.
Total CSO responses received: 19.
Report submission to the IMF’s Executive Board: staff report presenting findings and recommendations to be submitted in November 2023.
Executive Board conclusion of the Review: November 20th, 2023.
Next review by the Executive Board of the AML/CFT Strategy: expected to take place within five years.
Reference to IMF Executive Board mandate: Press Release published on February 4, 2019.

ML, TF, and PF can:
- Threaten the integrity and stability of a country’s financial sector and external stability more generally.
- Result in destabilizing “hot money” from inflows and outflows.
- Contribute to banking crises.
- Lead to ineffective revenue collection and broader governance weaknesses.
- Create reputational risks for international financial centers and loss of correspondent banking relationships (CBRs).
The harm from these crimes is noted to be global, affecting the integrity and stability of the international financial system.

The 2023 Review covers all elements of the Fund’s financial integrity work.
AML/CFT and broader financial integrity issues are integrated across Fund workstreams, including:
- Surveillance.
- Financial Sector Assessment Program (FSAP).
- Fund-supported programs.
- AML/CFT assessments.
- Capacity development (CD) activities.
AML/CFT and financial integrity issues have been included in a wide range of Fund policies, with examples cited: governance, climate change, Fintech, trade, and CBRs.

Public consultation targeted Civil Society Organizations (CSOs) globally.
After the online consultation (April 11 – May 21, 2023), an in-person and a virtual follow-up meeting with CSOs were planned to:
- Present inputs received.
- Discuss results.
- Seek further insights.
Bilateral meetings available if additional follow-up is needed.
Consultation questions focused on:
- The effectiveness of Fund staff in engaging members on AML/CFT and broader financial integrity issues.
- The Fund’s engagement and cooperation with CSOs and other organizations on AML/CFT and broader financial integrity issues.
Participants were asked to base feedback on the IMF Executive Board mandate as summed up in the Press Release published on February 4, 2019.

The policy includes a comprehensive stocktaking of IMF work in AML/CFT over the prior five years and concrete proposals to strengthen IMF engagement in these areas.
Review documents include an analysis of CSO input provided during the consultation process (Background Paper V).
Press release and main review and background papers summarize the findings of the AML/CFT Strategy review process.