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The Wolfsberg Group’s Comments on FATF’s Proposal on NPOs

AML Conversations

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Challenges of Implementing AML Compliance Programs for Smaller Operators in Conflict Zones

This chapter discusses the difficulties faced by smaller operators in implementing AML compliance programs in conflict zones, drawing parallels to the obligations for MSBs in the US. It highlights concerns about lack of regulation, limited resources, and the focus on risk, while emphasizing the importance of dialogue and collaboration between supervisors, financial institutions, and NPOs.

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