FATF Alignment Statement
Last updated: January 2025
Overview
Capital Path operates in alignment with the Financial Action Task Force (FATF) Recommendations and the associated methodology for assessing technical compliance and effectiveness. This statement describes how our operational framework reflects those standards.
Risk-based approach (FATF Recommendation 1)
Capital Path applies a risk-based approach to case acceptance and investigation prioritisation. Cases are assessed against threat typologies, jurisdictional risk ratings, and asset recoverability indicators. Higher-risk cases receive more intensive investigative resources. This approach mirrors FATF's expectation that countries and entities direct their AML/CFT resources proportionate to identified risks.
Customer due diligence
Where Capital Path engages clients on a fee basis, client identity is verified in accordance with applicable AML requirements in our operating jurisdiction. Beneficial ownership information is collected where relevant. We apply enhanced due diligence to clients from high-risk jurisdictions or where the source of funds raises concern.
Suspicious transaction reporting
Capital Path does not function as a reporting entity in the sense of FATF Recommendation 20 (financial institutions and DNFBPs). However, where our investigations uncover evidence of ongoing financial crime, we provide structured intelligence packages to partner Financial Intelligence Units (FIUs) under the terms of applicable Memoranda of Understanding.
International cooperation (FATF Recommendations 36–40)
Capital Path's jurisdiction network spans 40+ countries. Cross-border intelligence sharing is governed by bilateral MOUs that include data protection obligations, confidentiality requirements, and limitations on onward disclosure. We support mutual legal assistance processes and coordinate with partner FIUs to facilitate asset tracing and freezing requests.
Transparency and accountability
Capital Path publishes case statistics, typology reports, and fraud alerts to contribute to the public understanding of financial crime threats. We do not publish information that could identify victims, compromise active investigations, or assist offenders in evading detection.
Governance
Our FATF alignment is reviewed annually by the Governance Council. Any material change to our operating model or jurisdiction network is assessed for consistency with applicable FATF Recommendations prior to implementation. Queries regarding this statement: compliance@cappath.org.