20+ Years of AML-CFT evolution
20+ Years of AML-CFT evolution
27 October, 2025 •Cenfri hosted a two-day seminar, AML | CFT 20: Reflections on 20+ years of AML-CFT implementation, on 22–23 July 2025 at the University of the Western Cape (UWC), Cape Town. The event was convened in collaboration with IFAD, La Trobe University and UWC and brought together regulators, policymakers, academics, financial institutions, remittance providers and civil society to reflect on recent changes to FATF standards and to discuss implications for inclusive financial integrity, financial inclusion and emerging technologies.
Background
The seminar was convened in light of recent updates to the Financial Action Task Force (FATF) standards, particularly Recommendations 1 and 16, which marked the most significant changes in over a decade. As these global standards continue to evolve, there is increasing recognition that they must achieve inclusive integrity outcomes and be implemented in ways that reflect the realities of low-capacity countries and do not unintentionally limit access to finance or hinder legitimate economic activity.
Seminar objectives:
- Reflect on over 20 years of AML/CFT/CPF implementation (with a view to assess the progress, challenges and opportunities), with a focus also on Africa and the Global South;
- Examine implications of recent changes to FATF Recommendations and implications on inclusive integrity (financial integrity that enhances financial inclusion) for financial institutions, remittance service providers, NPOs, and regulatory and supervisory authorities in Africa and the developing world;
- Explore potential action and collaboration opportunities among stakeholders going forward.
The event brought together regulators, policymakers, academics, and civil society from across Africa and beyond to share experiences and discuss the above.
Key discussion points
The discussion was broad-ranging but some of the key discussion points included:
- AML/CFT/CPF implementation is a gradual and iterative process requiring sustained effort over decades. To be truly effective, these efforts require multi-stakeholder collaboration and need to be aligned with broader anti-corruption and justice sector reforms. Increased supervision of Designated Non-Financial Business and Professions (DNFBPs) was highlighted as one key to strengthening inclusive integrity outcomes. Key collaboration strategies in the final session of the conference.
- Debate around the risk-based approach and concerns around the fact that, in most cases, regulatory fines often cite no actual money laundering or terrorist financing risk, creating concern that such penalties address only compliance failures rather than mitigating genuine ML/TF threats. The importance of capacity building for supervisors and financial institutions [on the risk-based approach] was emphasised.
- The perception that FATF’s high-level objectives and communication is sometimes vague and insufficiently actionable. Participants reflected on whether the revised Recommendation 1 provides the clarity and flexibility needed to embed financial inclusion into AML/CFT/CPF practices.
- How the mutual evaluation process can be improved to ensure it moves beyond a tick-box approach, including to potential measure financial inclusion outcomes.
- Key initiatives from FATF including impact assessments, greater engagement of regional bodies, guidance on effective application of standards in low-capacity countries and continued emphasis on derisking and de-banking.
- The danger of perception-driven frameworks, which are linked to disproportionate impact on marginalised groups and non-profit organisations. The Cenfri and IFAD Remittance Innovation Toolkit, which is a practical resource that countries can adapt to implement proportionate, risk-based measures without undermining access for remittance recipients, including those considered vulnerable.
- The readiness of African institutions and regulators to adopt regtech and suptech solutions in a way that avoids creating additional compliance burdens. The need to address algorithmic bias in AI-driven transaction monitoring was also raised.