Dissemination of National Risk Assessment and Strategy for Anti-Money Laundering, Combating
the Financing of Terrorism and Proliferation of Weapons of Mass Destruction

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On 8^th August 2022, Pol. Maj. Gen. Dr. Piyapun Pingmuang, Secretary-General of the Anti-Money Laundering Board, presided over the opening ceremony for “Dissemination of National Risk Assessment and Strategy for Anti-Money Laundering, Combating the Financing of Terrorism and Proliferation of Weapons of Mass Destruction” at the Royal Orchid Sheraton Hotel & Towers Bangkok. Heads and representatives from government agencies, the private sector and civil society, including representatives from foreign embassies and international organizations, over 350 persons attended the event. The event aims to raise awareness on the risk posed by money laundering, terrorism financing and proliferation of weapons of mass destruction financing (ML/TF/PF), It also published a strategy on anti-money laundering, and combating the financing of terrorism (AML/CFT), which recently endorsed by the cabinet on 2^nd August 2022 as a guideline for relevant agencies to effectively enhance Thailand AML/CFT system in line with the international standards. In addition, it demonstrates the power of cooperation and integration in the implementation of risk-based strategic policies and measures on AML/CFT.

Pol. Maj. Gen. Dr. Piyapun stated that the National Risk Assessment on ML/TF/PF is the recommendation under AML/CFT international standards. Each country should regularly review their national risk assessment in order to keep pace with ever-changing circumstances. Previously, Thailand conducted two national risk assessments, in 2012 and 2016. This third edition of 2022 is the first that includes the assessment of proliferation of weapons of mass destruction financing risk, which was introduced in the FATF standards. The assessment is the joint effort of the Anti-Money Laundering Office and Research and Consultancy Institute Thammasat University. Results of the assessment can be divided into 3 risk areas.

1. Money-laundering

            The five highest-risk predicate offenses include: (1) corruption; (2) narcotics; (3) gambling; (4) exploitation of natural resources or environment; and (5) public fraud. These five crimes account for 2% of Thailand's GDP, or around 351,360 million baht. Of the channels that may be used to enable such offenses, the highest risk channels being abused for crime commission remain (1) banks due to their convenience to conduct transactions (2) specialized financial institutions, (3) unregulated digital asset providers, (4) front companies, (5) cross-border cash couriers, and (6) trade-based transactions such as imports and exports.

2. Financing of terrorism

            In 3 stages for terrorism financing, i.e. raising, moving and using of funds, the following high-risk behaviors were identified: (1) funds were raised based-on religious believes, and through profit generating crimes, overseas business activities, as well as non-profit organizations; (2) funds were moved mostly by cash couriers; and (3) funds were used for creating the incidents and management of the organization. Other high-risk channels for terrorism financing include cash smugglers, banks, unregulated digital asset providers, and non-profit organizations.

3. Financing of proliferation of weapons of mass destruction

            Although risk of proliferation of weapons of mass destruction in Thailand is low, the highest risk behaviors identified include evasion of economic sanctions, evasion of financial sanctions targeted at designated persons, and dual-use goods trading.

            In addition, the Secretary-General of the AMLO discussed on the AML/CFT Strategy 2022-2027, which was developed under cooperation among AMLO, Research and Consultancy Institute Thammasat University, and more than 40 relevant agencies. Results from the National Risk Assessment were used to formulate the strategies to ensure that AML/CFT measures keep pace with changing circumstances and challenges, as well as provide guidance for all relevant agencies to mitigate the identified risks and implement measures in accordance with the risk-based approach. The AML/CFT strategy consists of 6 strategic objectives:

Strategy 1: Increase effectiveness of Thailand's AML/CFT proactive measures in line with international standards.

Strategy 2: Integrate AML/CFT operations, domestically and internationally in line with international standards.

Strategy 3: Promote regulatory systems and measures of both government and private agencies responsible for prevention and suppression of money laundering, combating the financing of terrorism and proliferations of weapons of mass destruction, and promote AML/CFT compliance among reporting entities.

Strategy 4: Develop a body of knowledge for innovation, new products and business practices towards digitalized AML/CFT operations.

Strategy 5: Facilitate cooperation and disseminate AML/CFT information to civil society.

Strategy 6: Develop towards Thailand’s high AML/CFT performance organization.

The strategy specially focuses on 3 key areas: (1) proactive implementation of AML/CFT in line with international standards; (2) promotion of regulatory systems and measures of government and private agencies related to AML/CFT; (3) Development of knowledge for innovation, new products and business practices towards digitalized AML/CFT operations.

When looking at the progress of the AML/CFT strategy, from its initial implementation in 2010 to the present, it is evident that AML/CFT measures have been developed systematically and with clear direction. Capacity development and collaboration with relevant sectors is increasingly comprehensive, including law enforcement agencies, security agencies, supervisory agencies, and financial institutions, as well as non-bank businesses and professions, regulators, including non-profit organizations and legal persons, thus reducing the risk of being abused by criminals and terrorist activities. This also results in the strengthening of strategic partnerships with relevant agencies, both domestically and internationally, to develop strategic AML/CFT actions that correspond with greater challenges and risks. Furthermore, through cooperation with relevant sectors, Thailand has improved its compliance with international standards. In 2021, Thailand successfully achieved its technical compliance level as compliance and largely compliance with 31 out of 40 recommendations, while its effectiveness was assessed as substantial in 4 out of 11 immediate outcomes. 

To conclude, the Secretary-General of the AMLO stated that AML/CFT operations cannot be performed by any one agency alone, but requires cooperation and integration between all sectors to maintain effective AML/CFT systems in Thailand, with the common objective “Beyond Standards: Synergy for Stronger AML/CFT”.