The Gatekeeper Initiative and the Risk-Based Approach to Client Due Diligence: The Imperative for Voluntary Good Practices Guidance For U.S. Lawyers


Table of Contents

1. FATF and the 40+9 Recommendations ...85

2. Background of Gatekeeper Initiative .... 88

3. Risk-Based Approach and Development of Lawyer Guidance ... 91

4. Risk Categories ... 94

5. Development of Good Practices Guidance ... 96

6. Application of Good Practices Guidance to CDD ... 98

7. Conclusion ... 102

...Appendix 1: Voluntary Good Practices Guidance for Lawyers to Detect and Combat Money Laundering and Terrorist Financing ...103

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