SILO Compliance - Anti-Money Laundering (AML) Compliance Software
FATF Fifth Round Mutual Evaluation Review cover

FATF Fifth Round Mutual Evaluation Review

April 2026

The FATF’s Fifth Round of Mutual Evaluations introduces important changes to methodology, effectiveness assessments and grey listing. This session explains what has changed, how the process works and what regulated firms should be doing to prepare.

In this session, Elisabeth Lees of Claritas Legal provided a practical walkthrough of the Mutual Evaluation process and the increased emphasis being placed on effectiveness, risk and context during the Fifth Round.

The discussion looked at what these changes mean in practice for regulated firms, including the importance of understanding national and sectoral risks, demonstrating effective implementation of AML obligations and engaging constructively with regulators throughout the evaluation process.

In this session we covered:

  • How the FATF Mutual Evaluation process works
  • The key changes introduced for the Fifth Round
  • The increased focus on effectiveness, risk and context
  • The 11 Immediate Outcomes used to assess AML/CFT/CPF effectiveness
  • Greater emphasis on beneficial ownership, proliferation financing and asset recovery
  • How grey listing and the FATF increased-monitoring process work-
  • The potential consequences of grey listing for jurisdictions and businesses
  • The role regulated firms play before and during a Mutual Evaluation
  • How firms can prepare for onsite interviews and demonstrate the effectiveness of their -compliance framework

Presenters

Elisabeth Lees

Elisabeth Lees

Founder

Claritas

Kimberly Smith

Kimberly Smith

Founder + CEO

SILO Compliance

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