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Case Studies

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Technical Assistance programs offered by the Financial Integrity Group address a full range of aspects related to a country’s programs for
 Anti-Money Laundering and Combating Financial Terrorism (AML/CFT). The case studies below are based on projects completed in recent years.

Regulatory Reform

Following two years of technical assistance to a country in Africa, the Central Bank of the country adopted new regulations enhancing the AML/CFT regulatory framework for the banking, wire transfer and money changers sectors. The regulations were developed with technical assistance by FPDFI. The regulations extended the AML/CFT effort to sectors not previously covered and enhanced the content of the recordkeeping and customer due diligence measures in all the covered sectors. The regulations also addressed money laundering and terrorism financing risks that were not previously addressed including the risks posed by politically exposed persons, correspondent accounts, and high risk jurisdictions. The adopted regulations address many of the deficiencies identified by a Bank led AML/CFT assessment of the country.


Strengthening Capacity

Following up on a 2005 AML/CFT Financial Sector Assessment Program (FSAP) analysis of a country in Africa, the Group looked into ways to help the country implement the report recommendations and strengthen its AML/CFT legal and operational system. In cooperation with the Africa region national AML/CFT stakeholders, the Group prepared a comprehensive, result-oriented and sequenced technical assistance program. This program was provided by the Group and financed by the Bank’s Institutional Development Fund (IDF). The country has been building stronger AML/CFT regimes, which will incidentally foster good-governance and transparency, reinforce institutional capacities, and advance financial sector reform and the transparency of financial flows.



This Middle East and North Africa country passed the Law to Combat Money Laundering after more than 3 years of a stalemate. This success is the culmination of the Group’s efforts in assisting the authorities, through its Central Bank, to bring the AML/CFT legal and regulatory framework into compliance with international standards. The Bank provided extensive legislative drafting assistance to the country. In delivering this assistance the Bank adopted a multi-agency approach and encouraged the Central Bank to use its leadership to bring together representatives of nine key agencies in a drafting workshop organized by the Bank. It was through this intensive interagency discussion that the buy-in of the relevant agencies was achieved and a more comprehensive draft was developed and placed before Parliament.


Enhanced Cooperation

The Bank provided technical assistance to a country in Africa to enhance domestic and international cooperation in AML/CFT. The program was to bring all stakeholders and share the same understanding of AML/CFT. This was the first event where all relevant stakeholders gathered together to discuss the country’s AML/CFT policy and coordination. During the program, the authorities developed action plans to enhance the domestic and international cooperation and identified strategic priorities to develop its AML/CFT regime.

AML/CFT Framework for the Securities Sector
This project aims to help client countries best tailor their AML/CFT policies in the securities industry, and identify the AML/CFT risks and vulnerabilities it faces. The project is developed in coordination with key players in the securities industry. It will include research work on the identification of best practices, and the preparation of a "flagship" training program customized to the specific needs of supervisors/regulators and private sector representatives. These products will be rolled out in early 2009.

Governance in Financial Intelligence Units
This is a study on the governance structure, management and practice of countries’ Financial Intelligence Units (FIUs), the agency at the heart of any country’s AML/CFT regime. International standards require that FIUs have "sufficient operational independence and autonomy." How this requirement is implemented in practice has so far received little attention.

In order to gain more insight into this question, the World Bank worked with the Egmont Group, a world-wide organization of FIUs, and drafted a questionnaire addressing aspects of governance, such as appointments and terms of directors and staff, reporting and oversight over FIU activities, determination and use of budgets, and the conduct of daily operations.

In 2007, the questionnaire was sent to a sample of 15 FIUs of different types and sizes and located in different regions. Based on 13 responses received an interim report was prepared and adopted by the Egmont Group in October 2007. The WB and the Egmont Group also decided to extend this survey to cover all the Egmont Group members.

In January 2008, an amended questionnaire was sent to all 64 Egmont Group members. The data was analyzed and a new interim report was prepared and presented to the Group in May 2008. A final report shall include some additional responses and shall be presented to the Egmont Group in October 2008.

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