This classification applies when introducing additional AML/CFT measures could unintentionally increase illicit misuse risks or hinder legitimate transactions beyond the expected benefits. In such scenarios, financial institutions refrain from implementing new controls and instead rely on risk-based approaches to preserve financial inclusion and operational efficiency. By choosing not to introduce further measures, FIs avoid inadvertently pushing illicit activity into unregulated channels or placing undue burdens on low-risk clients. However, they must still ensure existing regulatory obligations are met, regularly assess changing risks, and confirm that the decision not to mitigate aligns with broader compliance and business objectives.
Main/
Do Not Mitigate
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Code
M0010
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Name
Do Not Mitigate
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Version
1.0
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Application Level
Strategic
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Functional Category
Risk Management & Governance
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Client Lifecycle Stages
Onboarding, Ongoing Relationship
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Created
2025-03-14
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Modified
2025-04-02
Client Lifecycle Stages
CL0003
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Onboarding
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An FI might decide no extra measures are needed if standard checks suffice and risk is low.
CL0004
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Ongoing Relationship
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If a risk reevaluation shows further controls might be counterproductive.