(AML-CFT Decision Article 23)

As part of their obligation to update their ML/FT risk assessments on an ongoing basis, the AML-CFT Decision specifically requires FIs to “identify and assess the risks of money laundering and terrorism financing that may arise when developing new products and new professional practices, including means of providing new services and using new or under-development techniques for both new and existing products.”

FIs must complete the assessment of such risks, and take the appropriate risk management measures, prior to launching new products and services, practices or techniques, or technologies. In general, they should integrate these ML/FT risk assessment and mitigation requirements into their new product, service, channel, or technology development processes.

For the purpose of assessing the ML/FT risks associated with new products, services, practices, techniques, or technologies, FIs may consider utilising the same or similar risk assessment models or methodologies as those utilised for their ML/FT business risk assessments, updated as necessary for the particular circumstances. They should also document the new product, service, practice, technique, or technology risk assessments, in keeping with the nature and size of their businesses (see Section 4.6.1, Documentation, Updating and Analysis).