President Otamendi, thank you for agreeing to this interview. You have just briefed the United Nations Security Council Counter-Terrorism Committee. Could you give us a short overview of FATF’s work?

FATF is an important institution internationally. We work to counter the financing of terrorism. This is done through peer review and mutual evaluation among all 203 jurisdictions that have committed to the 40 FATF recommendations.

 

It sounds like FATF, similar to the UN Counter-Terrorism Committee, provides assessments of Member States, including recommendations, is that right?

Absolutely. We have our recommendations, countries have their internal laws, and for us it is important that countries do not only have the laws on paper, but also make sure that those laws are implemented in a proper and effective manner. And this is what we measure in our mutual evaluations.

 

Could you say something about the general landscape of how countries are doing in this sense; are they improving, or are things getting worse?

It is a mixed picture. Most of the countries are making efforts to adopt the necessary laws and implement them in a proper way. As we measure effectiveness, we note whether the judiciary not only works preventively, but also acts after a serious incident has happened. To achieve this, we need to have a comprehensive and constructive dialogue between regulators and the judiciary.

This is something we invest a lot of effort in. It is a great challenge to cover the world, but we have already started in our region South America – in Ecuador – and in the next three weeks we will be moving to China, and eventually we shall cover Europe as well. Our goal, our objective, is to establish guidance and try to improve the relationships between prosecutors and judges all around the world.

As I told the Committee only moments ago, terrorists do not respect borders, whereas the judiciary is not as flexible as we need to be. We now have a common view between all these institutions that will allow for an approach to further improve and counter the activities of terrorists that constitute a threat to our societies.

 

You are currently the FATF President (1 July 2017-30 June 2018); what could you tell us about your priorities?

As you know, FATF has 27 years of institutional experience, so I shall follow this institutional track, including in terms of information sharing, on combating money laundering and proliferation, as well as the financing of terrorism; these are our main objectives. Other than that, we always try to further study the latest trends and risks and see how we effectively can mitigate these.

In terms of some of these trends and risks, in your briefing to the Counter-Terrorism Committee you mentioned FinTech (financial technology) and RegTech (regulatory technology). What are some of the challenges that stem from these areas?

FinTech and RegTech are brand new industries that are growing quickly. Financial innovation can be very useful to society, but can also be exploited by terrorists. We have therefore started a constructive dialogue with representatives from the FinTech and RegTech sectors, in order to get a better understanding and see what recommendations we can provide so that they develop new technologies and products that are resilient to money laundering and terrorist financing. These sectors want to be a safe industry; through this dialogue, we can get a better picture of what new technologies are developing. At the same time, we can stress the importance for the industry to commit to our recommendations, and convey to regulators what they need to know.

 

Is it your view that the existing FATF recommendations are enough to cover all risks stemming from the FinTech and RegTech industry?

The FATF recommendations evolve continuously to address new threats to the financial system.  To support the recommendations and interpretive notes, and to clarify their implementation, FATF issues guidance and best practices, for example on the risk-based approach to virtual currencies.  If necessary, FATF could develop additional guidance, or issue new interpretations or recommendations.

Finally, with ISIL (Da’esh) losing territory in Iraq and Syria, does this affect terrorism financing in any way?

Due to loss of territory, ISIL has seen a significant shift in its funding sources, as well as the mechanisms used to retain or move its funds.  FATF continues to monitor developments in the region, and specifically ISIL’s financing and expenditure, and how current developments are affecting the tools used to finance terrorism.  FATF is also closely monitoring the financing strategies of other terrorist organisations, including Boko Haram in West Africa and Al-Shabaab in East Africa.