On 1 July the Financial Action Task Force (FATF) announced an internet consultation on their National Risk Assessment Guidance Update (the current version is of 2013) that closed on 22 July. It would suggest that the FATF is not that interested in reactions.

In the consultation questions were asked, like:

• What are the most useful ways that the private sector, civil society and academia can contribute to the NRA?
• What are the most effective ways in which countries can engage the private sector, civil society and academia in the NRA?
• How does the private sector, civil society and academia use NRA outputs? Are there any key performance indicators or other methods to measure the impact of the NRA?
• How can countries design the NRA process and outputs to maximise their utility to the private sector, civil society and academia?
• What is the most appropriate and effective mechanism for the private sector, civil society and academia to provide feedback on the NRA?

National Risk Assessments (NRAs) are becoming increasingly important now that they are considered a form of regulation.
Unfortunately, errors occur in Dutch NRAs and there is no correction mechanism (probably the same in other jurisdictions). This makes it a risky tool.