Public Sector
End-to-End Guidance on the new FATF Evaluation Cycle
The Fifth Round under the 2022 FATF Methodology has changed evaluation practice. More than ever, effectiveness must be proven through sustained evidence, risk-based choices must be demonstrable in practice, and results must be embedded before the on-site.


Service area 01
Mutual Evaluation Preparation
For jurisdictions preparing for a FATF or FSRB mutual evaluation, Stellini Advisors delivers a structured, multi-year engagement comprising four components. Our flexible approach provides holistic guidance across the whole evaluation cycle. Depending on specific needs, all modules can be delivered as a fully integrated programme or engaged independently.
Being more than an advisory firm, we serve as a strategic counterpart – combining an established international network with the commitment to stand alongside and support our clients throughout the evaluation cycle.
Navigating the Evaluation Cycle through three Modules
Diagnostic Assessment
Objective
Module 1 establishes a clear understanding of the jurisdiction’s AML/CFT/CPF system through an independent, evidence-based diagnostic aligned with the FATF Methodology. It assesses both technical compliance and effectiveness, identifying strengths, weaknesses, risks, and dependencies. This provides the analytical foundation for reform and assessment readiness.
Scope & Approach
The diagnostic takes a system-wide perspective, examining how legal, institutional, supervisory, and operational elements interact and translate risk into measurable outcomes. The work combines desk-based analysis, targeted stakeholder engagement, and a one-week on-site simulation mirroring the depth of a FATF assessment. This process tests institutional coherence, evidence maturity, and the credibility of results.
Outputs & Action Plan
Over a six-month engagement, the process produces a comprehensive diagnostic report highlighting compliance gaps, effectiveness constraints, and coordination challenges. Building on these findings, a prioritised project plan defines sequencing, ownership, and evidence targets. It serves as the operational blueprint for reform implementation.
Capacity Building, Technical Compliance Remediation & Effectiveness Implementation
Objective
Module 2 is the core implementation phase of the engagement. It translates diagnostic findings into concrete reforms, operational improvements, and measurable results across the AML/CFT/CPF system. The aim is to ensure reforms are implemented early and consistently, generating the evidence needed to demonstrate real results well before the onsite evaluation.
Implementation Framework
The module is delivered through a multi-year programme of onsite missions combined with continuous advisory support. Work is organised through four parallel Delivery Tracks addressing the core components of an effective AML/CFT/CPF system. Together, they translate risk understanding into legal, supervisory, operational, and policy reforms while strengthening coordination and institutional capacity across authorities.
Outputs and System Development
Module 2 establishes the operational foundations needed for assessment readiness. Typical outputs include procedures and manuals, supervisory tools and risk models, training programmes and private-sector outreach, cooperation templates, and material supporting statistics and case development. Together, these outputs embed reforms across the
Drafting of Assessment Materials & Mock Evaluation
Objective
Module 3 prepares jurisdictions for the FATF assessment by transforming operational results into coherent technical compliance and effectiveness submissions. Built on the operational evidence generated during the earlier phases, these materials form the narrative and evidentiary basis for the upcoming assessment.
Drafting and Consolidation
The module develops recommendation-level technical compliance materials and immediate outcome narratives. These link legal frameworks, supervisory and operational actions, and measurable results. Drawing on procedures, statistics, supervisory outputs, and case material produced during the capacity-building phase, the drafting process consolidates supporting material, develops illustrative case studies, validates statistics, and ensures consistency of positions across authorities.
Mock Evaluation and Preparation
Through structured mock interviews, onsite missions, and targeted stress-testing of higher-risk immediate outcomes, the module tests the robustness of the drafted materials under FATF-style questioning. This process highlights narrative weaknesses, evidentiary gaps, and inconsistencies between written submissions and oral explanations. It allows targeted refinement before the formal assessment.
An Integrated Delivery Model
The entire project is delivered through four concise Delivery Tracks, each covering a core element of an effective AML/CFT/CFP system. All Delivery Tracks run in parallel, interact continuously and are coordinated through Delivery Track 01.
Delivery Track 01
(Risk Coordination & Technical Framework)
Scope: IO.1 and Technical Compliance across all FATF Recommendations.
This Delivery Track provides the structural and strategic backbone of the project. It ensures the system is legally sound, risk-based, coherently coordinated, and strategically steered.
(01)
Risk Assessment & Prioritisation
Review and validation of NRA methodology and governance
Targeted updates or thematic NRAs
Risk prioritisation matrices translating NRA findings into operational priorities
Agency-specific risk interpretation notes aligned with the NRA
Agency-specific action plans to mitigate risks
(02)
National Coordination & Governance
Review of AML/CFT coordination mechanisms and mandates
Design/refinement of inter-agency coordination frameworks
Drafting/revision of terms of reference and decision-making protocols
Facilitation of coordination committee workshops and strategic retreats
(03)
National Strategy & Action Planning
Drafting/revision of National AML/CFT Strategies
Multi-year Action Plans aligned with FATF IOs
Ownership, timelines, performance indicators
Monitoring and reporting frameworks
(04)
Technical Compliance Framework
Comprehensive TC gap analysis against FATF Recommendations
Legal and regulatory framework reviews
Drafting/redrafting primary and secondary legislation
Consistency checks across law, policy documents, and operational practice
Support to governmental/parliamentary adoption processes
(05)
Monitoring, KPIs & Reporting
AML/CFT performance indicators linked to effectiveness
Internal progress-tracking tools
Support for FATF/FSRB progress reports
Sequencing advice to maximise assessment impact
Delivery Track 02
(Preventive Framework & Supervision)
Scope: IO.3 (FIs), IO.4 (DNFBPs), and IO.2 in the preventive/supervisory context.
(01)
Risk Based Supervision
Redesign of supervisory risk assessment models
Risk-based planning frameworks
Sectoral/entity risk scoring tools
Integration of NRA findings into supervisory prioritisation
(02)
Supervisory Tools & Practices
Enhanced on-site/off-site methodologies
Effectiveness-focused inspection manuals
Supervisory testing tools targeting outcomes
Training of supervisors on effectiveness-oriented supervision
(03)
Preventive Measures & Compliance
Review of FI and DNFBP obligations
Sector-specific guidance and typologies
Support to obliged entities on CDD, monitoring, governance
Review of compliance functions and internal controls
(04)
STR Quality & Feedback Loops
STR quality guidance (relevance, timeliness, narratives)
Joint supervisor–FIU workshops on reporting quality
(05)
Supervisory International Cooperation (IO.2)
Review of supervisory cooperation frameworks
Assessment of incoming/outgoing exchanges
Procedures and templates for cooperation requests
Support on cooperation with foreign supervisors/regulators
Delivery Track 03
(Financial Intelligence, Investigations & Prosecution)
Scope: IO.6, IO.7, IO.8, IO.9 and IO.2 in the operational context.
(01)
Financial Intelligence (IO.6)
STR quality indicators and scoring frameworks
FIU analytical methodology review and enhancement
Prioritisation/filtering/enrichment process improvements
Dissemination thresholds, formats, and timeliness review
(02)
FIU-to-FIU and Policy-Level Cooperation (IO.2)
Review of request/spontaneous exchange practices
Use of foreign intelligence in operational/strategic analysis
Guidance on handling incoming/outgoing foreign intelligence
(03)
Intelligence-to-Investigation Conversion
Mapping end-to-end case lifecycle from STR to prosecution
Bottleneck analysis and drop-off reduction
Referral/tasking/escalation protocols
Joint FIU–LE–prosecutor case workshops
(04)
ML and TF Investigations & Prosecution (IO.7 & IO.9)
Investigative strategies and case selection
Investigation manuals and typology-based guidance
Support on third-party/foreign predicate/complex ML cases
Prosecutorial case management and decision-making review
(05)
Asset Tracing, Freezing & Confiscation (IO.8)
Asset tracing and parallel financial investigation methodologies
Support on freezing, seizure, management, confiscation
Case-based reviews of underperforming confiscation efforts
(06)
Operational International Cooperation (IO.2)
MLA and extradition review and timeliness improvement
Templates/guidance for MLA requests/responses
Joint investigations and foreign asset recovery support
Delivery Track 04
(Transparency, NPOs & Targeted Financial Sanctions)
Scope: IO.5, IO.10, IO.11 and IO.2 related to beneficial ownership exchange.
(01)
Legal Persons and Arrangements (IO.5)
BO legal/institutional framework review
Data accuracy, verification, accessibility assessment
BO register enhancement and access regimes
Sanctions/corrective measures for BO breaches
Testing of BO usability in real cases
(02)
Beneficial Ownership International Cooperation (IO.2)
BO exchange frameworks review
Timeliness/usefulness assessment of BO requests
Procedures/templates for BO information exchange
Capacity building on cross-border BO cooperation
(03)
Non-Profit Organisations (IO.10)
NPO risk assessment review and classification
Proportionate, targeted oversight frameworks
Outreach/awareness/mitigation measures
Sanctions and remedial actions review
(04)
Targeted Financial Sanctions – TF (IO.10)
Legal framework review and “without delay” implementation
Operational freezing procedures
Capacity building for authorities and obliged entities
Simulation exercises and operational drills
(05)
Targeted Financial Sanctions – PF (IO.11)
PF framework review and designation processes
Screening/freezing/reporting guidance
End-to-end PF implementation testing
Service area 02
ICRG / Enhanced Monitoring Support
For jurisdictions subject to, or at risk of, FATF enhanced monitoring (the “grey list”), Stellini Advisors provides intensive, results-driven support designed to achieve compliance with FATF Action Plan items and secure delisting at the earliest opportunity.
Our ICRG support is led by experts who have personally designed, managed, and applied the ICRG methodology from within the FATF Secretariat, and who have guided multiple jurisdictions through the process to successful delisting.
Approach
- Action Plan Implementation Map: Translating each FATF Action Plan item into monthly targets, specific outputs, and evidence requirements
- Monitoring and Evidence Development: Continuous progress tracking, evidence compilation, and gap identification to ensure all deadlines are met
- Progress Report Preparation: Drafting and quality-assuring all required Progress Reports for submission to the FATF
- Strategic Engagement Support: Coaching and preparation for Review Group, ECG, and Plenary discussions, including mock sessions before each FATF Plenary
- Simulation Exercises: Mock Review Group sessions to test the jurisdiction’s delegation on likely lines of questioning and to refine messaging
Key Deliverables
- Detailed Action Plan Implementation Map with monthly milestones
- Drafted Progress Reports aligned with FATF expectations
- Evidence packs for each Action Plan item
- SOPs, procedures, and statistics demonstrating operational progress
- Mock Review Group and Plenary preparation sessions
- Exit readiness package and transition strategy to post-delisting sustainability
Service area 03
National Training & Capability Programmes
Stellini Advisors designs and delivers structured, nationwide training programmes to build a shared operational foundation across all AML/CFT/CPF authorities and regulated sectors. These programmes can be deployed as standalone engagements or integrated into broader evaluation-preparation or ICRG projects.
Format
- Delivered through intensive onsite missions, each comprising multiple thematic workshops
- Each workshop trains 25–30 participants, ensuring interactive, focused engagement
- Train-the-trainer modules ensure national institutions can replicate sessions internally
- Programmes are typically delivered over 12–24 months across 8–10 missions
Indicative Themes
- Financial intelligence and investigations
- Prosecution and the judiciary
- Risk-based supervision and compliance
- Targeted financial sanctions (TF and PF)
- Corporate transparency and beneficial ownership
- Risk assessment processes and policy design
- NPO risk management
- Cross-cutting effectiveness, KPI development, and statistics
Target Audience
- FIU, law enforcement, and prosecution authorities
- Supervisory bodies (central banks, securities regulators, insurance supervisors, DNFBP supervisors)
- Company registries and beneficial ownership units
- Sanctions and TFS authorities
- NPO regulators and key non-profit organisations
- Compliance officers from financial institutions, DNFBPs, and VASPs
Service area 04
Private Sector Outreach & Awareness
Effective AML/CFT systems depend on a well-informed and engaged private sector. Stellini Advisors supports jurisdictions in designing and delivering targeted outreach programmes that strengthen compliance culture, improve the quality of suspicious transaction reporting, and demonstrate supervisory engagement to FATF assessors.
Outreach Activities
- Sector-specific awareness events: Conferences, roundtables, and briefings tailored to financial institutions, DNFBPs (lawyers, accountants, real estate agents, TCSPs), and VASPs
- Thematic webinars and workshops: Focused sessions on key topics such as risk-based compliance, CDD obligations, STR quality, targeted financial sanctions, and beneficial ownership requirements
- Compliance guidance: Development and dissemination of sector-specific guidance notes, typology documents, and risk indicators aligned with national and FATF risk assessments
- STR quality improvement: Joint supervisor–FIU workshops targeting reporting quality, relevance, timeliness, and feedback mechanisms
- Public-private partnership facilitation: Supporting the establishment of structured dialogue mechanisms between authorities and the private sector to exchange intelligence, share typologies, and improve system-wide effectiveness
These activities are designed to produce demonstrable evidence of private sector awareness and engagement – a key factor in FATF effectiveness assessments under Immediate Outcomes 3, 4, and 6.
