How do observers contribute to the FATF as part of its Global Network?

Observers to the FATF observers are in a unique position to more meaningfully contribute to countering illicit finance. Effective engagement with observers allows the FATF to increasing the impact of its work by involving a broader range of stakeholders to gain access to relevant expertise and/or resources to:

  • support the Global Network (including FATF-style regional bodies) for effective implementation of the AML/CFT/CPF standards;
  • support regional diversity and amplify regional voices and experiences;
  • support assessment processes, and
  • aid in ensuring policy coherence and understanding of risks at the international level and keep abreast of relevant issues impacting AML/CFT/CPF efforts.

The information below clarifies the FATF’s expectations of observers – both for initial admission and for ongoing observer status and was approved by the FATF Plenary in October 2025, marking the end of the Strategic Review of Observers. The FATF works with observer organisations to identify expected contributions to the FATF’s Strategic Priorities and Work Programme, taking into consideration the mandate and capacity of different observer organisations. Observers are required to report on their contributions to the work of the FATF and the Global Network and their continuing compliance with these criteria.

 

Interpretation of the FATF Policy on Observers’ criteria

This document clarifies the FATF’s expectations of observers – both for initial admission and for ongoing observer status. The FATF works with observer organisations to identify expected contributions to the FATF’s Strategic Priorities and Work Programme, taking into consideration the mandate and capacity of different observer organisations. Observers are required to report on their contributions to the work of the FATF and the Global Network and their continuing compliance with these criteria.

1.      The organisation should be inter-governmental[1] and international/regional in nature, and it should not work according to private sector mechanisms.

This is a threshold criterion to clarify the types of organisations that are eligible to be an observer. They:

  • should be organisations made up of or representing government/public sector officials, or be a body created by governments; and
  • must be international or regional in nature (cannot be serving the interests of one or a few countries only).

2.      The organisation should have a stated role relating to AML/CFT/CPF.

The role should be reflected in statutory documents, but could also be reflected in long-term policy or strategy documents approved by the governing bodies of the organisation. This criterion is about the relevance of the organisation to the FATF and its ability to contribute as an observer.

3.      The organisation should endorse the FATF Standards.

The organisation must endorse the mission and objectives of the FATF and acknowledge that the FATF Standards are the global AML/CFT/CPF standards. They must agree to facilitate the implementation of, and avoid the duplication or contradiction of, the FATF Standards, assessment processes and their results or other FATF and Global Network activities. This can be reflected in the organisation’s mandate, priorities or can be a public commitment to make sure their policies and activities are in line with the FATF Standards.

This criterion is considered to have particular importance in assessing the relevance of an organisation to become, or continue to be, an observer.

4.      Admission of the organisation as an observer should enhance the FATF’s global reach, geographically and/or sectorally.

This criterion can help to increase the diversity of voices at the FATF table and the implementation of the FATF’s work to all relevant stakeholders.

The FATF already has significant geographical reach through the Global Network. Organisations will better meet this criterion if they are representing regions/sectors of strategic importance or that are otherwise under-represented at the FATF or the Global Network. Participation in the work of FATF-Style Regional Bodies (FSRBs) can include activities and areas of specific relevance for the Global Network such as economic development and financial inclusion.

5.      The organisation should be able to contribute to the work of the FATF.

This is one of the most important criteria and addresses the contribution observers should make to the FATF and the Global Network that they could not make if they were not an observer.

In order to contribute to the work of the FATF and the Global Network that includes FSRBs, the organisation should demonstrate that it has:

  • the capacity and resources (or an ongoing/a long-term ability to secure them) to actively participate in the FATF and the Global Network and actively monitor and participate in relevant work streams;
  • an adequate level of experience and expertise to be able to contribute actively in the FATF and the Global Network in the medium and long term.

The organisation should, on an effective and on-going basis, contribute to the FATF work in more than one of the following ways:

  • provide input to the definition of FATF’s strategic priorities and work planning, within its area of expertise and where relevant;
  • enrich FATF risk, policy and assessment work with regional and/or sectoral perspectives (relevant to criterion 4);
  • provide technical expertise and input to the work of the FATF and the Global Network (for example, sharing their experience through written comments on the FATF papers and evaluations, by making constructive interventions in Plenary and WG meetings, or by joining or leading FATF project teams); support greater implementation of the FATF standards regionally or globally through technical assistance (TA), operational expertise, training or other support to the Global Network, in line with the Global Network’s needs;
  • actively disseminate and endorse FATF work and messages within their membership.

Expectations will be set at the beginning of each biennium between the FATF and observers. The FATF’s Internal Governance Principles provide details on the consequences of failing to meet expectations.

6.       If the organisation were to become an observer, reciprocity would exist between it and the FATF, including with respect to attendance at meetings and information sharing on AML/CFT/CPF issues.

The FATF should be able to register for and attend meetings (which are open to other observers) in its own right, should the FATF wish to do so. The observer should notify the FATF of any such engagements with sufficient notice to enable effective participation. The observer should also actively ensure that the FATF has access to documents that are relevant to the FATF’s work, and that the FATF is invited to contribute/has visibility of projects that impact the FATF or pertain to its work.

This can be of particular interest to the FATF in relation to other organisations that have a policy- or decision-making role that has an impact on the implementation of AML/CFT/CPF measures to ensure the FATF’s expertise is taken into account and there is coherence and alignment with FATF Standards, and that they are not contradicted.

Additional consideration

 

7.      Does the organisation participate in the work of the FSRBs?

Supporting the Global Network is critical for effective implementation of the AML/CFT/CPF standards. Participation of the organisation in the work of the FSRBs and its support to the Global Network are therefore important considerations which will be taken into account throughout the assessment of the criteria above and are particularly relevant for criterion 4 and criterion 5.

 

[1] Including international organisations of competent authorities.