Corruption as a Predicate Offence in the FATF Framework: How Corruption Risks Appear in AML/CFT Effectiveness Assessments

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Authors: David Kovatev
Cited by: 0

Abstract

Feel free to connect with me on linkedin: https://www.linkedin.com/in/david-kovatev-1a7b683a9 This article explains how the FATF framework treats corruption not as a separate anti corruption policy area, but as a source of criminal proceeds that can be laundered. It shows why corruption matters for AML and CFT through the logic of predicate offences, and how these risks appear in FATF style mutual evaluations. The focus is on where the operational chain must work in practice, including PEP controls, beneficial ownership transparency, financial intelligence, investigations, and the confiscation of assets of criminals involved in corruption offences. The paper also offers a practical contribution. It introduces the Corruption AML Effectiveness Map, which links common corruption scenarios to relevant FATF standards and Immediate Outcomes. It then proposes the Corruption AML Minimal Outcome Dashboard, or CMOD, a small set of outcome focused indicators and a validation plan that uses publicly available mutual evaluation materials. Together, these tools help translate evaluation narratives into comparable signals and support evidence based judgments about whether an AML system actually deprives corruption offenders of illicit gains.

Fields of Study & Subjects

Crime Illicit Activities and Governance Corruption and Economic Development Taxation and Compliance Studies

Publication details

Journal / source
Zenodo (CERN European Organization for Nuclear Research)
Publication date
14 February 2026
Language
EN
Document type
Preprint