APG 2024-2025 Annual Report on Regional AML/CFT Efforts

ANNUAL REPORT

ASIA/PACIFIC GROUP ON MONEY LAUNDERING

2024-2025

OFFICIAL OFFICIAL

The Asia/Pacific Group on Money Laundering (APG) is an inter-governmental organisation consisting of 41 active members in the Asia-Pacific region, as well as organisations and observers from within and outside the region. Under the APG Terms of Reference, membership in the APG is open to jurisdictions in the Asia-Pacific region. The APG is a non-political, technical body, whose members are committed to the effective implementation and enforcement of the internationally accepted standards against money laundering, financing of terrorism and proliferation financing set by the Financial Action Task Force. This document, any expression herein, and/or any map included herein, are without prejudice to the status of, or sovereignty over, any territory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. Cover image: 2025 APG Annual Meeting, Tokyo, Japan For more information about the APG, please visit our website. © December 2025, APG No reproduction or translation of this publication may be made without prior written permission. Applications for permission to reproduce all or part of this publication should be made to:

Locked Bag A3000 Sydney South New South Wales 1232 AUSTRALIA Tel: +61 2 5126 9110 Email: mail@apgml.org Web: www.apgml.org

OFFICIAL OFFICIAL

Table of contents

PART ONE: Overview and Summary 3 PART TWO: Effective Governance 9 PART THREE: Performance Highlights 11 PART FOUR: Management and Accountability 22

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APG CO-CHAIRS' FOREWORD

In accordance with Section 5.5 of the APG Terms of Reference 2019, we submit the following report to the membership on the operations of the Asia/Pacific Group on Money Laundering (APG) for the period 1 July 2024 to 30 June 2025. This report highlights the achievements of the APG over the reporting period against the goals and strategies contained in the APG Strategic Plan 2024-2028. The APG continues to go from strength to strength. The outcomes achieved this year position the APG and the Asia/Pacific region to be more effective in tackling the threats posed by criminals and terrorists to subvert the integrity of the international financial system. The successful 2025 APG Annual Meeting was hosted by Japan in Tokyo and included the adoption of the mutual evaluation reports for Finance for International Niue and the Maldives. The 2025 APG Technical Assistance and Affairs Mitsutoshi Kajikawa Training Forum was held in parallel and continued the important technical assistance coordination work undertaken by the Secretariat and Donors and Providers Group. This period marked the first year of Japan's 2024-2026 Co-Chair term. The Co-Chairs' Priorities for 2024-2026 focus on supporting Round of members to prepare for and commence the Global 5 th mutual evaluations, strengthen AML/CFT regimes in the APG region and international cooperation, and monitor and respond to evolutions in finance. The relocation of the APG Secretariat office this year marked a significant milestone in the APG's history. The new premises in Sydney will support even greater flexibility, collaboration and growth, but most importantly, the new office enables the engagement of staff from the region, including an active program of secondments. This is a critical aspect of APG Secretariat reforms as it brings in expertise from across our members, strengthen relationships and build capability for the future. Ian McCartney We would like to extend our thanks to all APG members and observers who made 2024-2025 a successful year for the APG. Deputy Vice Minister of Finance for International Affairs Deputy Commissioner Ian McCartney Mitsutoshi (Toshi) Kajikawa APG Co-Chair APG Co-Chair Australia Japan December 2025 December 2025 Deputy Vice Minister of Deputy Commissioner ANNUAL REPORT 2024-2025 2 OFFICIAL OFFICIAL

PART ONE Overview and Summary

APG Organisational Structure 2024-2025

1. The APG has 41 active member jurisdictions as follows: 1

2. The APG has seven observer jurisdictions and 36 observer organisations (including FATF-style

regional bodies, or 'FSRBs'). APG Observers Jurisdictions Organisations FSRBs

France CFATF ADB/OECD Anti-Corruption Initiative International Institute for Justice and Alliance for Financial Inclusion (AFI) the Rule of Law (IIJ) Germany EAG Asia-Pacific Economic Cooperation Institute for Legal Support and Kazakhstan ESAAMLG (APEC) Secretariat Technical Assistance (ILSTA) Kiribati FATF Asian Development Bank (ADB) International Monetary Fund (IMF) Federated Asset Recovery Interagency Network Interpol GABAC States of - Asia Pacific (ARIN-AP) Islamic Development Bank (IsDB) GAFILAT Micronesia Association of Southeast Asian Oceania Customs Organisation GIABA Nations (ASEAN) Secretariat (OCO) Portugal Bay of Bengal Initiative for Multi- Pacific Financial Technical MENAFATF United Arab Sectoral Technical and Economic Assistance Centre (PFTAC) MONEYVAL Emirates Cooperation (BIMSTEC) Pacific Islands Chiefs of Police 2United Commonwealth Secretariat (PICP) Kingdom Egmont Group of Financial Pacific Islands Forum Secretariat Intelligence Units (PIFS) European Commission (EC) Pacific Islands Legal Officers' Financial Services Volunteer Corps Network (PILON) (FSVC) United Nations (UN) Global Center for Cooperative United Nations Office on Drugs and Security Crime (UNODC) Group of International Finance World Bank Centre Supervisors (GIFCS) World Customs Organisation (WCO) Afghanistan's membership has been on inactive status since 2022 1

Observer status granted in August 2025 2

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Australia Lao PDR Philippines Bangladesh Macao, China Samoa Bhutan Malaysia Singapore Brunei Darussalam Maldives Solomon Islands Cambodia Marshall Islands Sri Lanka Canada Mongolia Chinese Taipei China Myanmar Thailand Hong Kong, China New Zealand Tuvalu India Niue United States Indonesia Pakistan Vanuatu Japan Palau Vietnam Korea Fiji Nepal Tonga Cook Islands Nauru Timor-Leste

APG Co-Chairs

1. The APG has two Co-Chairs: one Co-Chair is a permanent position, and the other rotates amongst

APG members every two years. The Co-Chairs are responsible for chairing the plenary and Governance Committee meeting and providing strategic advice and direction to the membership.

1. Co-Chair, Japan: The rotating Co-Chair position is held by Japan from 2024-2026, represented by
   Mitsutoshi Kajikawa, the Deputy Vice Minister of Finance for International Affairs at Japan's Ministry of Finance. In this role, he oversees critical areas including anti-money laundering, counter-terrorism financing, and counter-proliferation financing, while leading Japan's delegation to the Financial Action Task Force. Deputy Vice Minister Kajikawa brings a wealth of expertise to his role in advancing the APG's mission, backed by an extensive career at the Ministry of Finance, where he has worked in areas such as financial regulation, fiscal analysis, budget management, and government reform. His recent efforts have focused on multilateral financial cooperation, including leading negotiations to strengthen a currency swap arrangement for liquidity support among ASEAN+3 nations.

2. Co-Chair, Australia: The permanent Co-Chair is held by Australia, represented by Deputy
   Commissioner Ian McCartney of the Australian Federal Police. Deputy Commissioner McCartney has significant experience in national and international economic and organised crime investigations. In 2014, Deputy Commissioner McCartney was awarded with the Australian Police Medal in recognition of his distinguished service, particularly in the areas of law enforcement liaison in Asia, and for his role in national investigations. APG Co-Chairs' Priorities 2024 - 2026

3. At the 2024 Annual Meeting the APG membership endorsed the 2024-2026 APG Co-Chairs'

Priorities which cover two years and are set out in the below table.

Round of evaluations international cooperation Priority One - Preparation to ensure APG's successful start to the Global 5th Round of evaluations To ensure that the APG is prepared and sufficiently resourced as the APG commences the Global 5th Round of Mutual Evaluations (MEs), noting that the next round will be more intensive than the current round. Contribute to increasing the number of quality assessors across the APG and support efforts to enhance awareness and understanding of the Global 5th Round ME processes and best practices for preparation and coordination.

1. Preparation to ensure APG's successful start to the Global 5th 2. Strengthening AML/CFT regimes in the APG region and ANNUAL REPORT 2024-2025 4 OFFICIAL OFFICIAL
2. Monitoring and responding to evolutions in Finance APG Co-Chairs Priorities 2024-2026 Implementation Outcomes Assessor Training Workshops: APG significantly increased the pool of trained expert assessors through the delivery of three APG-only and one joint FATF/APG/EAG assessor training workshops during 2024-25. APG workshops were hosted by Japan, Macao, China and Chinese Taipei. India hosted a joint FATF/APG/EAG assessor training workshop in April 2025. All hosts generously provided venues and catering for the events. Both Japan and Chinese Taipei provided additional generous contributions to support travel of presenters and some participants. The New Zealand-funded Pacific AML/CFT Capacity Development (PACD) program sponsored the attendance of a representative from Papua New Guina to attend the assessor training workshop in Japan. Through the four in-person workshops, 134 APG assessors were trained for the Global 5th Round of MEs. APG Secretariat also trained 39 assessors in a virtual assessor refresher training workshop in June 2025. Regional ME Preparation Workshop in Fiji APG gave comprehensive longer-term support to members preparing to undergo a Global 5 th Round ME. In April 2025, the APG delivered a regional ME preparation training workshop in Suva, Fiji attended by representatives from the coordination teams of 10 members (Australia; Bangladesh; Cambodia; Cook Islands; Fiji; Macao, China; Samoa; Solomon Islands; Sri Lanka and Vanuatu). The workshop focused on preparations for the Global 5th Round of MEs. The event was supported by the generous voluntary contribution from Japan which covered the venue and the travel of several presenters and delegates. Priority Two - Strengthening AML/CFT regimes in the APG region and international cooperation To strengthen members' AML/CFT/CPF regimes to better prevent, detect and deter serious financial crimes and enhance the development of financial systems and economies. Providing capacity building to strengthen AML/CFT/CPF regimes in the APG region. Conduct high-level visits to strengthen political will for AML/CFT reform, support capacity development for jurisdictions including Pacific Island countries and those with significant deficiencies and share knowledge and Japan's experiences in AML/CFT. Implementation Outcomes Vietnam - High-Level Implementation Support Visit APG influenced strategic AML/CFT leaders and supported better targeted implementation planning and technical assistance to support Vietnam's efforts to meet its ICRG Action Plan. The APG high-level implementation support visit to Vietnam from 6-8 November 2024 focused on prioritising reforms and operational results to address action items in Vietnam's FATF ICRG action plan. The APG team was led by the APG Co-Chair Kajikawa and included the APG Secretariat, the IMF, World Bank, the UNODC and the Japanese Ministry of Finance.

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The APG briefed the key ministers and heads of agencies including the Deputy Prime Minister and Deputy Minister of Public Security as well as leadership of the State Bank of Vietnam and National Security Council. The APG also held an implementation planning workshop with officials from all key agencies and ministries on prioritised planning to meet the ICRG action plan. The visit also included a briefing to the private sector and the diplomatic corps to reinforce messages of prioritisation and coordination. Sri Lanka High-Level ME Preparation Support Visit APG influenced strategic AML/CFT leaders and supported better targeted implementation planning and technical assistance to support Sri Lanka's efforts to prepare for its upcoming mutual evaluation. The APG high-level ME preparation support visit to Sri Lanka took place from 11-12 March 2025. The visit was coordinated by the Central Bank of Sri Lanka and focused on briefing Sri Lanka's strategic AML/CFT leadership on prioritising reforms and operational results to prepare for Sri Lanka's upcoming ME. The APG team was led by the APG Co-Chair Kajikawa and included representatives from the APG Secretariat and Japan Ministry of Finance. The APG delegation briefed ministers, working level officials, and the private sector to ensure Sri Lanka gets the best possible result in its upcoming APG ME. A briefing to the diplomatic corps on the visit identified the critical areas where Sri Lanka requires support and technical assistance. Ministers, senior officials and the private sector all voiced their strong commitment to prioritise actions for necessary reforms and to implement the revised FATF standards. Areas of focus for the visit included, (i) the legislative reform program to address technical deficiencies identified by the FIU, (ii) the legislative framework on VA/VASPs, and (iii) the strengthening of judicial and law enforcement capacity with regards to ML/TF cases. The visit identified priority implementation strategies, actions and possible areas of technical assistance. Following the visit, the APG Secretariat Technical Assistance and Typologies Directorate worked with Sri Lanka on identifying priority areas for technical assistance, and successfully connected Sri Lanka with appropriate donors and providers, including through two Sri-Lanka focussed coordination calls. Fiji High-Level ME Preparation Support Visit APG influenced strategic AML/CFT leaders and supported better targeted implementation planning and technical assistance to support Fiji's efforts to prepare for its upcoming mutual evaluation. The APG high-level ME preparation support visit to Fiji took place from 9-11 April 2025. The APG team was led by APG Co- Chair Kajikawa and included representatives from the APG Secretariat and Japan Ministry of Finance. The visit was coordinated by Fiji's National AML Council supported an APG high-level visit to Suva, Fiji to brief Fiji's strategic AML/CFT leadership on strategic opportunities to harness the momentum of the upcoming APG ME process to deliver on Fiji's national interests. During the visit the APG team also conducted coordination meetings and briefings to the Pacific Islands Forum Secretariat in Suva to discuss Pacific regional issues relating to priority AML/CFT implementation, including AML/CFT issues relating to correspondent banking. Sharing of knowledge and Japan's experiences relating to AML/CFT/CPF including initiatives to support collaboration among FSRBs. In May 2025, APG Co-Chair Kajikawa attended the MENAFATF Plenary in Jordan providing delegates with an update on APG's recent initiatives and emphasizing the importance of further collaboration between FSRBs, including MENAFATF and the APG Secretariats.

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Priority Three - Monitoring and Responding to Evolutions in Finance To monitor and respond to development in finance. As identified in the FATF's Strategic Priorities 2024-2026, financial markets are continuously evolving. These evolutions can pose new questions about the scope and interpretation of the FATF Standards and require them to be updated to be relevant and applicable to a new environment. The importance of monitoring and responding to development in finance and working with strategic public and private sector partners has rapidly grown to address emerging ML/TF risks. Deliver or support technical seminars, webinars, and outreach activities to enhance understanding of FATF standards on virtual assets and new technologies (e.g. Recommendation 15 and 16), and exchange views with members on emerging regional threats and risks (e.g. vulnerabilities from DeFi, P2P and CBDCs). Implementation Outcomes Deliver or support technical seminars, webinars and/or outreach activities on virtual assets APG brought a wide range of stakeholders together to identify and respond to the financial crime environment in the Asia/Pacific region. APG delivered a workstream of the 2024 APG Annual Typologies Workshop focused on cyber enabled fraud and scams. The work stream included presentations and panel discussions on issues relating to evolving risks and typologies, cryptocurrencies and asset recovery, private sector collaboration and technology driven strategies to prevent fraud. The Typologies Workshop was attended by 152 delegates representing 32 APG members and seven observer organisations and 60 delegates from 41 private sector organisations. Exchange views with members on new threats and risks in the region Reflecting the Co-chairs' priorities and APG business plans, the APG ensured a wide cross-section of APG delegate received detailed information and experience on new and emerging threats and responses in the region. Japan held a technical seminar on virtual assets (VA) and VA service providers (VASPs) as part of the 2025 Annual Meeting which included details of FATF standards, implementation support and jurisdiction experience. Japan's voluntary contribution enabled an APG expert presenter and delegates from Bangladesh, Fiji and Sri Lanka to travel to Busan, Korea for an APG/World Bank Virtual Asset Investigation workshop in October 2024. The workshop developed delegates' capabilities and understanding of the cryptocurrency ecosystem, the FATF standards relating to VAs and VASPs, and effective strategies for investigating ML with a nexus to VAs. In November 2024, the APG Co-Chair Kajikawa provided the opening address at the EAG/APG joint workshop on Innovations in Finance (hybrid) as part of the EAG plenary in India. Supporting the workshop theme of Monitoring and Responding to Emerging Technologies in Finance to Address ML/TF/PF Risks, the APG Secretariat presented to delegates on the Implementation of FATF Recommendation 15 in APG jurisdictions. Mr Takahiro Yamasaki at Japan's Ministry of Finance also delivered a presentation on central bank digital currencies and AML/CFT/CPF.

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In March 2025 at the Global Finance & Technology Network Forum in Japan, APG Co-Chair Kajikawa delivered the opening address on Combating Financial Crime and Financial Inclusion in the Digital Era to policymakers, regulators, fintech innovators, and financial service providers from across the Asia-Pacific. The Forum focused on financial crime, including the emerging risks posed by fintech developments, and the ongoing efforts to align with FATF recommendations and the APG, the Co-Chairs' priorities including response to financial innovations, and the importance of collaboration among diverse stakeholders. On behalf of APG Co-Chair, in May 2025, Mr Yamasaki at Japan's Ministry of Finance attended the FSB's Regional Consultative Group for Asia Meeting hosted by the Central Bank of Sri Lanka. The meeting was attended by representatives from Asian Central Banks and financial supervisors who discussed global and regional financial vulnerabilities; progress on the G20 Roadmap to enhance cross-border payments; and approaches to monitoring potential financial stability risks in non-bank financial intermediation. Mr Yamasaki encouraged participants to further exchange views on payment issues with other agencies, such as AML/CFT authorities in their jurisdictions.

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PART TWO Effective Governance

1. In accordance with the APG Terms of Reference 2019 (amended 2023), the APG membership
   is the ultimate decision-making body of the APG, although the Governance Committee may make decisions on behalf of the membership if delegated to do so. Decisions by the membership are made on a consensus basis. All organs of the APG including the Co-Chairs, Governance Committee and Secretariat are responsible and accountable to the APG membership. 2025 Annual Meeting and Technical Assistance (TA) Forum

2. The 2025 APG Annual Meeting and Technical Assistance (TA) Forum was hosted by Japan in
   Tokyo from 25 to 29 August 2025. The meeting was opened with remarks delivered by Katsunobu Kato, Minister of Finance, Japan. The FATF President, FATF Executive Secretary, EAG Executive Secretary, MENAFATF President and MENAFATF Executive Secretary were also in attendance and shared their leadership and experience with APG delegates.

3. Over 400 delegates attended the 2025 APG Annual Meeting and TA Forum. Several APG

delegates received sponsorship funding to attend the meeting, generously provided by China, Japan, New Zealand, Chinese Taipei and the United Kingdom.

1. The membership decided on several important governance-related matters including:

• agreed to appoint Brunei Darussalam as rotating APG Co-Chair 2026-28
• welcomed the Bay of Bengal Initiative for Multi-Sectoral Technical and Economic

Cooperation (BIMSTEC) as an Observer to the APG

• agreed to the proposals set forth by the findings of the ad hoc group on long-term

resourcing to support the membership to increase resources needed for the APG to conduct the Global 5 Round of Evaluations th

• adopted amended APG Global 5 Round Mutual Evaluation Schedule, Procedures and th

APG Global 4 Round Transitional Follow-Up procedures th

• adopted APG Information and Communication Protocols 2025 to strengthen APG's

credibility to govern how it manages and assesses the use of information and communication to achieve its business objectives

• adopted the APG Diversity and Inclusion Strategy
• adopted the APG Secondment Framework

1. The membership adopted the 2025-26 Business Plan and Budget were adopted at the 2025 APG
   Annual Meeting. Initiatives for the year FY 2025-26 are outlined in Part Five of this report. The core budget for FY 2025-26 was approved as AUD$5,532,807 in income and AUD$6,332,807 in expenses, with a net operating deficit of AUD$800,000, to be drawn from accumulated equity.

2. The membership adopted the APG mutual evaluation (ME) reports of Niue and the Maldives.

This now concludes the APG 3rd Round.

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1. The Operations Committee endorsed the draft 2025 APG Typologies Report for discussion at
   the APG 2025 Typologies Workshop, to be held in Bangkok, Thailand in November 2025. The report will then be adopted by the membership and published in early 2026. The 2025 APG Typologies Report contains a synopsis of the typologies project undertaken in 2024-25 (cyber- enabled scams and human trafficking), recent trends in money laundering and terrorist financing, and several case studies.

2. The 2025 TA Forum was held concurrently with the 2025 APG Annual Meeting. The Forum was
   well-attended, with 24 APG members who are technical assistance recipients, and 15 governments or organisations from the APG Donor and Providers (DAP) Group. There were almost 30 meetings held throughout the TA&T Forum, where active and productive discussions focused on targeted and effective technical assistance for APG members.

3. The DAP Group met to discuss technical assistance coordination and cooperation across the
   region, as well as a strategic discussion of challenges and opportunities for longer-term funding aligned with global and regional priorities and opportunities to deepen collaboration. APG held three sub-regional meetings with the DAP Group and APG members, focused on the identification and discussion of sub-regional AML/CFT issues and needs for the Pacific, South- East Asia and South Asia respectively. In addition to the sub-regional discussions, the TA&T Forum held individual meetings for each of the 24 TA recipient APG members in attendance, providing them with an opportunity to engage with the influential DAP Group one-on-one, to identify key gaps and challenges and seek technical assistance. This event also provided an opportunity for DAPs to sequence the delivery of technical assistance in a prioritised and coordinated manner. Governance Committee

4. The APG Governance Committee (GC) met five times during the year (including in person during

the 2025 APG Annual Meeting). During the year the GC:

• received regular updates on APG's budget preparation, management and financial

reporting

• considered and endorsed amendments to governance-related policies, including the APG

Information and Communications Strategy

• forward planning for selecting APG Co-Chairs and APG plenary meeting hosts
• issues related to members' implementation of FATF standards
• updating the APG ME Schedule
• Secretariat reform and sustainability work
• the progress made by the Ad Hoc Groups and the Diversity and Inclusion Network; and
• observer applications. ANNUAL REPORT 2024-2025 10 OFFICIAL OFFICIAL

Mutual Evaluation Committee

1. The APG ME Committee met once in person and four times via video conference, and was co-

chaired by Macao, China and New Zealand. Key achievements of the MEC over the year included:

• consideration of twenty-three (23) FURs, including four (4) APG FURs with re-ratings, and

five (5) joint FATF/APG FURs, from nine (9) reviewers across the APG membership and the Global Network. The MEC endorsed the FURs and recommended out-of-session adoption by the membership

• consideration of four (4) MERs - Marshall Islands, Nauru, Papua New Guinea and Timor-

Leste. The MEC endorsed the MERs and recommended adoption by the membership

• discussion of amendments to the MEC Terms of Reference
• discussion of amendments to the APG Global 5th Round ME Procedures and the APG

Global 4th Round Transitional Follow-Up Procedures

• discussion of ME guidance resources for the Global 5th Round of MEs
• discussion of good practices to meet aspirational APG assessor contribution goals
• continuing the APG process for identifying horizontal issues and complex quality &

consistency (Q&C) issues in adopted APG assessments and coordinating with FATF and FSRB Secretariats

• analysis of the treatment of specific topics of interest to our membership in MEs and

FURs

• discussion of the pilot regional ME preparation workshop for the Global 5th Round;
• introduction of the APG MEC Co-Chair mentoring program
• updates related to APG's ongoing assessor training program

Operations Committee

1. The APG Operations Committee (OC), co-chaired by India and Samoa, met once via video

conference and once in person at the Annual Meeting in August 2025. The OC:

• supported implementation and typologies work, including oversight of the typologies

project on cyber scam hubs and human trafficking

• contributed to the planning of the APG Typologies Workshop

1. The 2024 Annual Typologies Report was endorsed by the OC out-of-session, and adopted by the

membership in November 2024 at the 2024 Annual Typologies Workshop.

1. At the 2025 APG Annual Meeting the membership agreed to the dissolution of the OC. Going

forward the decision-making authority in relation to typologies, implementation issues and technical assistance projects will rest with the GC.

1. During the year the APG Secretariat pursued a range of significant reforms, including a move in

office premises and making further arrangements to enable seconded officers to work within the Secretariat.

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1. The APG Secretariat undertook a planning retreat in March 2025 to more intensively consider
   improvements and reforms that build capability so the Secretariat can prepare for and deliver the APG Global 5th Round Mutual Evaluations. Outcomes from the retreat supported an internal restructure of the Secretariat and a decision on a statement of APG Secretariat Values.

2. The APG Secretariat welcomed a new Communications Specialist in late May, marking a
   significant step forward in strengthening the organisation's outreach and engagement. This development forms part of broader efforts to modernise the Secretariat's communications framework and support more consistent, timely engagement with members, observers and other stakeholders.

3. Australia assisted the Secretariat by providing two officers to backfill APG Secretariat vacancies

related to the ME program and typologies work.

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PART THREE Performance Highlights

APG Strategic Priorities

1. The Strategic Plan 2024-2028 contains the APG's vision, mission and values. Informed by its
   vision and mission, the Strategic Plan sets out three goals for the APG underpinned by governance to guide its work over four years. These goals are supported by overarching strategies designed to give the goals effect. contains the APG's vision, mission and values. Informed by its vision and mission, the Strategic plan sets out three goals for the APG underpinned by governance to guide its work over four years. These goals are supported by overarching strategies designed to give the goals effect.

2. Below is a summary of APG's performance highlights for the 2024-25 financial year under each
   strategic goal. STRATEGIC GOAL #1 THE APG ENGAGES WITHIN AND THROUGH ITS LARGE AND DIVERSE RANGE OF MEMBERS AND OBSERVERS TO SHAPE AND INFLUENCE AML/CFT/CPF POLICY AND IMPLEMENTATION ENGAGEMENT WITH APG MEMBERS AND OBSERVERS

• The 2024 APG Annual Meeting and TA&T Forum was delivered in September 2024, generously

hosted by the United Arab Emirates. Over 400 delegates attended the Annual Meeting and TA&T Forum.

• The significant redevelopment of the APG website commenced, with support from a voluntary
  contribution by Chinese Taipei. To be built with a more contemporary design and feature set, the new website aims to deliver modern platforms and tools that can enhance engagement with APG members and stakeholders, boost the accessibility and user-friendliness of key information, and can improve how we manage events. Work has progressed to early stages of content transition with the new website expected to be live in the first half of 2025-26.

• APG Co-Chair Kajikawa led three high-level visits, with support from the Secretariat and TA
  providers to Vietnam (November 2025 - ICRG support), Sri Lanka (March 2025 - ME preparation) and Fiji (April 2025 - ME preparation). The visits fostered strategic AML/CFT leadership and engagement and supported coordination and prioritisation of implementation efforts to improve compliance and effectiveness, as well as preparation for mutual evaluations. The Co-Chair's high-level visits focused on members that are among the first to be assessed under the Global 5th Round or members in the FATF ICRG process.

• The high-level visit to Vietnam in November 2024 enhanced support for Vietnam's
  engagement with the FATF ICRG process. The visit focused on enhancing Vietnam's strategic leadership for AML/CFT reforms, improved implementation and provided detailed strategic planning support and technical assistance coordination. The visit

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included the UNODC and World Bank and involved ministerial briefings, joint-agency planning workshops and a briefing to the diplomatic corps in Vietnam to seek further cooperation and technical assistance

• The high-level visit to Sri Lanka in March 2025 engaged with the new AML/CFT leadership
  following the 2024 elections. The Visit sought to enhance mutual evaluation preparations, including priority legislative reform and implementation and technical assistance coordination. Thematic areas of focus included beneficial ownership, AML/CFT supervision and law enforcement efforts in anti-corruption. The visit was supported by the ADB, UNODC and World Bank and involved ministerial briefings, joint- agency planning workshops and a briefing to the diplomatic corps in Sri Lanka to seek further cooperation and technical assistance

• The high-level visit to Fiji in April 2024 enhanced support to Fiji for its mutual evaluation
  preparation. The visit focused on enhancing Fiji's strategic leadership for AML/CFT reforms, improved implementation and providing detailed strategic planning support and technical assistance coordination

• In 2024-25, the APG welcomed two new observer organisations, the International Institute for
  Justice and the Rule of Law (IIJ) and Luxembourg's Institute for Legal Support and Technical Both organisations are actively involved in the delivery of AML/CFT Assistance the (ILSTA). 3 technical assistance in the region and have become active members of the APG DAP Group.

• The APG Secretariat continued liaison with the Federated States of Micronesia and Kiribati to

encourage their possible APG membership.

• At the 2024 APG Annual Meeting members decided to remove one jurisdiction, the Democratic

Peoples' Republic of North Korea, as an APG observer due to a lack of engagement over a six- year period.

• The APG continued regular and deep engagement with a range of observer organisations,
  particularly the FATF and FSRBs, but also a range of regional organisations including the Pacific Islands Forum on the topic of AML/CFT technical assistance coordination and correspondent banking and PILON on AML/CFT law and justice sector issues in the Pacific.

• The APG Diversity & Inclusion Network was Co-Chaired by Nauru and Pakistan, and supported
  by a committee of delegates from Australia, India, Nauru, Pakistan, Thailand and Vanuatu. The Network met on three occasions and the Network Committee met on a further three occasions during the year to share experiences and best practices, and to develop an APG Diversity & Inclusion Strategy. This Strategy sets out the specific goals for the APG to pursue to promote a diverse and inclusive environment for the work of the APG and across the AML/CFT workforce in the Asia/Pacific region.

• The APG established the Ad Hoc Group on Strategic AML/CFT Leadership to develop tools to
  better support APG members to enhance and sustain their own strategic leadership of AML/CFT implementation and reforms to maximise effectiveness and avoid the FATF's ICRG processes. The project is being conducted over two phases. Phase one involved research and gathering information to identify challenges and barriers associated with strategic leadership on AML/CFT; and good practices that have helped to foster and sustain strategic leadership on AML/CFT and implement meaningful change. Phase one has been completed, and the Ad Hoc Group will report

BIMSTEC joined as an Observer in August 2025 3

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to the Plenary on outcomes at the 2025 Annual Meeting. The second phase involves developing tools to support the membership to enhance and sustain strategic leadership on AML/CFT.

• The APG Ad Hoc Group on Long Term Resourcing commenced in December 2024 with twelve
  member delegations taking part: Japan (representing the APG Co-Chair); Australia; Canada; China; India; Indonesia; Macao, China; Nauru; Pakistan; Thailand; the United States; and Vanuatu. The Ad Hoc Group met six times to consider a wide range of issues relating to APG resourcing. The Ad Hoc Group conducted rounds of consultation with members and reported to the 2025 Annual Meeting through the GC with a series of recommendations to address demand for resources and models to meet resource needs including secondments and increased staffing and budget to the Secretariat.

• The APG VA/VASP Network, under the stewardship of Indonesia, relaunched and convened on

one occasion during the year. ENGAGEMENT WITH THE GLOBAL NETWORK

• The APG contributed to FATF processes through written input, virtual and in-person attendance

at meetings and input to project teams. A number of APG-only members and the APG Secretariat attended three FATF plenary meetings (October 2024, February 2025 and June 2025)

• The APG Secretariat:

o attended three ICRG Asia-Pacific Joint Group meetings (see below for further detail) o attended the FATF Technical Assistance Peer Exchange Meeting (Strasbourg, June

2025)

o contributed to FATF project teams (including the FATF Training Project Team; the Complex Proliferation Financing (PF) and Sanctions Evasion Schemes project; Online Child Sexual Exploitation project; the Low-Capacity Countries Project; Comprehensive Update on TF Risks project; and the Financial Exclusion and De-Risking: Potential revisions to R.1 project o provided members' and Secretariat comments on FATF policy papers (contact groups, working groups and the plenary)

• The APG contributed as an observer to the FATF Virtual Asset Contact Group through its two

representatives (Mongolia and Chinese Taipei) and the APG Secretariat, who attended two virtual VACG meetings and provided input into the 2025 Targeted Update.

• APG Co-Chair Kajikawa represented the APG at the EAG plenary in Indore in November 2024. In

parallel to the EAG plenary, the APG delivered a joint workshop with the EAG on Virtual Assets, delivered both in-person and virtually. The Secretariat presented at this workshop virtually.

• APG Co-Chair Kajikawa, Samoa Central Bank Governor Atalina Ainuu-Enari and Deputy Governor

Margaret Chan Cheuk-Tafunai, along with the Secretariat, represented the APG at the FATF's Private Sector Collaborative Forum in Mumbai in March 2025.

• APG Co-Chair Kajikawa attended the MENAFATF plenary in Amman in May 2025 and the APG

Executive Secretary attended the MENAFATF plenary in Riyadh in November 2024.

• The APG Executive Secretary pursued wider and more regular engagement with FATF and FSRB

Secretariats and found opportunities to more directly collaborate across the work of the Global Network. In addition to participating in a panel at the November MENAFATF Plenary, the APG

ANNUAL REPORT 2024-2025 15 OFFICIAL OFFICIAL

Executive Secretary also attended an FSRB forum hosted by MONEYVAL and the German Government in Strasbourg in February 2025 to discuss the upcoming challenges for the Global Network. Expanding upon this initial discussion, all Secretariats from across the Global Network met in the United Arab Emirates for a comprehensive discussion to prepare for the start of the Global 5th round, share solutions, innovations and best practices. STRATEGIC GOAL #2 THE APG USES ITS REGIONAL AND SUBJECT MATTER EXPERTISE TO DELIVER HIGH QUALITY ASSESSMENTS OF THE IMPLEMENTATION OF INTERNATIONAL STANDARDS. MUTUAL EVALUATIONS

• The ME reports of India (joint APG/EAG/FATF), Marshall Islands, Nauru, Papua New Guinea and
  Timor-Leste were completed consistent with the APG ME Procedures and related quality and consistency requirements. Each of these reports was adopted by the APG in September 2024 and published following global quality and consistency reviews. The MEs were adequately staffed with expert assessors and reviewers from APG members and observers, supported by the APG Secretariat.

• The ME reports of the Maldives and Niue continued, with draft ME reports prepared for
  consideration at the 2025 APG Annual Meeting. The adoption of these ME reports will conclude the APG's MEs under the Global 4th Round. One assessor withdrew part-way through the ME process, however the Secretariat was able to obtain a replacement assessor with minimal impact to the ME assessment's progress. The APG Secretariat effectively supported all ME processes.

• The APG Global 5th Round of MEs commenced with joint APG/FATF mutual evaluations of

Malaysia, Singapore and Canada. The Malaysia and Singapore ME reports will be adopted at the 2026 APG Annual Meeting and the Canada ME report will be adopted at the 2027 APG Annual Meeting.

• ME preparation support was provided in-country to Fiji, Solomon Islands, Sri Lanka and Vanuatu,
  whose MEs will commence in late 2025 and early 2026. Voluntary contributions from New Zealand and Japan supported the conduct of visits to these members. DAP Group members also supported the ME preparation visits.

• The APG continued to implement its expanded quality and consistency program for all APG ME

reports.

• APG supported ten members preparing to undergo a mutual evaluation through a regional
  training targeted to those staff co-ordinating ME preparations. The APG delivered the Pilot Regional ME Preparation Workshop focused on supporting ME coordination staff in April 2025 in Nadi, Fiji through a voluntary contribution from Japan. FOLLOW-UP PROCESSES

• All APG follow-up reports were subject to internal quality and consistency review and all follow-

up reports with re-ratings were subject to global quality and consistency review in accordance with the FATF Universal Procedures.

ANNUAL REPORT 2024-2025 16 OFFICIAL OFFICIAL

• From July 2024 to June 2025, the MEC endorsed and members adopted four (4) APG FURs with
  re-ratings (Brunei Darussalam, Myanmar, Nepal, and Samoa) five (5) joint FATF/APG FURs (Australia Japan, Korea, New Zealand and the United States), and 14 APG FURs without re-ratings (Bangladesh, Bhutan, Cambodia, Cook Islands, Lao PDR, Mongolia, Pakistan, Palau, Papua New Guinea, Samoa, Solomon Islands, Thailand, Tonga and Vanuatu).

• Seven (7) FUR teams were formed involving 26 reviewers from 15 members and one observer.

The review teams re-assessed a total of 44 recommendations across these reports.

• The APG continued to implement its quality and consistency program for all FURs. The APG
  Secretariat implemented internal quality and consistency tools and processes to facilitate this. PROVIDE ASSESSMENT EXPERTS, CONDUCT TRAINING AND IMPROVE ASSESSMENT PROCEDURES IN ORDER TO EFFECTIVELY DELIVER THE APG'S ASSESSMENT PROGRAM

• Members and observers provided assessors and reviewers across various stages of five APG

mutual evaluations (two APG-only MEs and three FATF/APG MEs) in 2024-25.

• External review and Global Network quality and consistency (Q&C) processes were applied to all

MERs and FURs adopted during the year.

• The APG delivered three assessor training workshops, in Chinese Taipei in October 2024, Japan
  in December 2024 and Macao, China in May 2025. 103 delegates from 30 APG members and observers were trained to serve as assessors. These workshops were supported by generous voluntary contributions from Japan; Macao, China; New Zealand and Chinese Taipei to fund travel for several participants and experts from across the APG membership. The workshops were supported by experts from Australia; Japan; New Zealand; Sri Lanka; Chinese Taipei; Macao, China; the MEC Co-Chairs; and the APG Secretariat.

• The APG supported a joint FATF/APG/EAG assessor training workshop in India in April 2025.

Eleven delegates from 10 APG members and observers were trained. This workshop was supported by a voluntary contribution from Japan.

• The APG held a virtual update assessor training workshop in June 2025 for 39 delegates who

had previously been trained as assessors in the Global 4th Round. The focus was on updates to the ME procedures, FATF Standards and Methodology in the Global 5th Round of MEs.

• Through the MEC, the APG prepared updated ME Procedures and commenced preparation of
  technical compliance templates and ME guidance for APG members to assist in ME preparation for the Global 5th Round. SUPPORT FATF'S INTERNATIONAL CO-OPERATION REVIEW GROUP (ICRG) PROCESS AND APG MEMBERS IN THE ICRG PROCESS

• The APG actively participated in three Asia/Pacific-Joint Group (AP-JG) JG meetings (September

2024, January 2025 and April 2025)

• The Philippines' ICRG exit on-site visit in January 2025
• Three ICRG meetings (October 2024, February 2025 and June 2025)
• APG provided support to the Co-Chairs for the AP-JG for 2024-25 who were provided from

Macao, China and New Zealand.

ANNUAL REPORT 2024-2025 17 OFFICIAL OFFICIAL

• The APG Secretariat provided comments to the ICRG and advice to the AP-JG Co-Chairs and to
  members under ICRG review including on ICRG process, rules and practice including in relation to the FATF's project concerning unintended consequences under Recommendation 8; o general comments on legislative, regulatory and administrative measures to address ICRG concerns o technical assistance coordination o implementation planning o the impact of ICRG processes on APG membership status

• APG conducted a high-level visit to Vietnam to address strategic AML/CFT leadership challenges

and technical assistance coordination in relation to the ICRG. The visit was supported by the APG Co-chair Kajikawa, the UNODC and the World Bank.

• APG Secretariat conducted ICRG preparation support visits to Papua New Guinea (November

2024 and June 2025), which included implementation planning support, technical coordination and briefings to the private sector

• APG Secretariat virtually joined FATF Secretariat ICRG preparation briefings to Papua New
  Guinea in January 2025. STRATEGIC GOAL #3 THE APG SUPPORTS IMPLEMENTATION WITHIN ITS MEMBERS THROUGH THE DELIVERY OF TYPOLOGIES PRODUCTS AND THE COORDINATION AND DELIVERY OF TECHNICAL ASSISTANCE AND TRAINING CONDUCT AND/OR SUPPORT RESEARCH ON EXISTING AND EMERGING AML/CFT RISKS AND CONTEXTUAL ISSUES

• The 2024 APG Typologies Workshop was hosted by Malaysia from 11-13 November 2024 and
  attended by over 150 delegates from 32 members, seven observer and over 60 private sector participants. The workshop focused on the abuse of legal persons and cyber-enabled fraud and included presentations and panel discussions with operational leaders and civil society, moderated by experts.

• The APG commenced preparations for the 2025 APG Typologies Workshop which will be hosted

by Thailand in collaboration with the UNODC, in November 2025. The Workshop will consist of two streams: 1) cyber scam hubs and human trafficking and 2) online child sexual exploitation.

• APG adopted and published the 2024 APG Typologies Report in November 2024. The report
  included information submitted by 18 APG members, 11 APG observer organisations and four non-observer organisations (research centres) and included 138 case studies. The report also included a focus chapter on threats and trends related to the misuse of legal persons.

• The APG, with support from the UNODC, published a fact sheet on shipping registries and PF
  risks in March 2025. The factsheet included case studies which provide practical examples of PF risks and approaches to assessment that can inform members' understanding and response to PF risks associated with shipping registries.

ANNUAL REPORT 2024-2025 18 OFFICIAL OFFICIAL

• The APG commenced a typologies project on cyber scam hubs and human trafficking in March
  2025 with Indonesia and the UNODC as the co-leads of a project team of 24 members representing 10 members and two observers. The project will result in the publication of a report, following a roundtable discussion at the 2025 APG Annual Meeting and workshop stream at the 2025 APG Typologies Workshop.

• The APG Secretariat contributed to the FATF RTMG project teams for 1) online child sexual
  exploitation (OCSE) - report published March 2025; and 2) complex PF sanctions evasion schemes - report published June 2025. APG Secretariat contributed to the FATF launch event for the OCSE report and an awareness raising webinar for the complex PF sanctions evasion schemes report. PROVIDE GUIDANCE, ADVICE, AND TECHNICAL ASSISTANCE ON IMPLEMENTATION OF THE FATF STANDARDS IN COLLABORATION WITH REGIONAL AND GLOBAL PARTNERS.

• The APG identified regional and domestic implementation issues through the APG's TA
  coordination processes, including through regular communication with TA recipient members and frequent liaison with members of the APG DAP Group. The APG supported and encouraged assistance from TA providers in response to identified needs. APG Secretariat delivered targeted TA coordination and assistance to in line with the identified TA priority needs. This particularly focused on members undergoing ICRG review, and supporting members preparing for the Global 5th Round of MEs as well as thematic areas including virtual assets, beneficial ownership, proliferation financing, asset recovery, etc.

• The APG provided post-ME strategic implementation planning (SIP) support with a particular
  focus on TA coordination. These visits included joint-agency implementation planning workshops and engagement with other stakeholders. All SIP visits this year were funded by the PACD program. SIP visits were conducted with Papua New Guinea (November 2024, with Australia, United States, ADB, UNDP and UNODC), Nauru (January 2025), Marshall Islands (February 2025) and Timor-Leste (June 2025, with Portugal and UNODC).

• The APG piloted the APG Global 5th Round Regional ME Preparation Workshop in Fiji, from 29
  April - 1 May 2025. The workshop was supported by a voluntary contribution from Japan. Twenty-nine delegates from 10 APG members which will be assessed early in the Global 5th Round participated in this workshop.

• APG advocated for and received agreement from FATF for regional delivery by APG or the

IMF/World Bank of FATF Standards Training Courses (STC).

• APG Secretariat coordinated the participation of APG delegates in FATF STC at the FATF Training Institute in Busan, Korea as follows: o four participants at the law enforcement-focused STC from 26-30 August 2024 o 26 participants at the STC from 1-6 December 2024 o three participants at the supervision-focused STC from 10-14 March 2025 o 16 participants at the STC from 12-16 May 2025

ANNUAL REPORT 2024-2025 19 OFFICIAL OFFICIAL

SUPPORT THE COORDINATION OF TECHNICAL ASSISTANCE BETWEEN MEMBERS AND RELEVANT PROVIDERS OF ASSISTANCE.

• The 2024 TA Forum was held in September 2024 in Abu Dhabi. The 22nd TA Forum brought

together 25 APG TA recipient members and 19 members of APG's DAP Group who all actively participated in 29 convened meetings including:

• One DAP Group meeting to discuss the coordination of TA and three sub-regional

meetings for members and the DAP Group: Pacific, South Asia and Southeast Asia o 25 individual team meetings between TA recipient members and the DAP Group

• The APG Secretariat distributed information on members' assistance needs and their ongoing
  TA activities to the DAP Group prior to the 2024 TA Forum. This included information received from members in addition to ME reports, ICRG action plans and follow-up reports. The Secretariat has also done this in preparation for the 2025 TA Forum to be held in August 2025.

• The APG Secretariat shared comprehensive TA needs information and donor activity with the

DAP Group and held eight TA coordination virtual DAP Group meetings throughout the year where information on priorities, changing donor landscape and sequencing issues were discussed.

• The APG identified and enhanced TA coordination with relatively new regional donors (IIJ, ILTSA,

the EU Global Facility) and continued to seek enhanced TA in cases where some members with TA needs lack offers of assistance.

• The APG provided support to members, including Lao PDR, Myanmar, Nepal, Papua New Guinea,
  Philippines and Vietnam in relation to the ICRG process and observation period. This included three specific TA coordination calls with the DAP Group to provide an update on progress against action plans and highlighted key areas for TA.

• The APG Secretariat's PACD program continued to support Pacific members and Timor-Leste

through coordinated delivery of TA, through funding from the New Zealand Ministry of Foreign Affairs and Trade. in particular:

• The APG further enhanced TA coordination and collaboration processes and the intensity
  of coordination calls and information sharing (both member-specific and regional) - this has greatly intensified as the number of donors in the Pacific has increased and the APG has more closely integrated with initiatives on correspondent banking relationships (CBR) and other shared regional priorities;

• Member-specific TA related coordination calls have increased to seek updates from

members on their progress the SIP and to confirm upcoming TA delivery and outstanding needs. Calls were conducted with Tonga, Samoa, Marshall Islands, Tuvalu, Palau, Cook Islands and Nauru.

• Stakeholder engagement (members, regional partner organisations, Donors and

Providers of technical assistance) increased in keeping with the changing regional context. Examples include high level briefings from the APG Co-chair to the Pacific Islands Forum;

ANNUAL REPORT 2024-2025 20 OFFICIAL OFFICIAL

• Member-level strategic implementation planning support (before and after an ME) -post-

ME strategic implementation planning support was provided to the Marshall Islands, Nauru, PNG and Timor-Leste. Strategic ME preparation support was provided to Fiji, Sri Lanka and Vanuatu.

• APG provided support to strategic AML/CFT leadership in the Pacific, including through

engagement through Pacific Banking Forum, committees of the PIFS, the World Bank/PIFS CBR project, the PILON, the ARIN-AP, etc;

• APG provided support to Pacific members in relation to AML/CFT supervision, including
  enhanced regional cooperation on AML/CFT supervision through the Pacific Supervisors Forum and closer collaboration with the Pacific Financial Intelligence Community (PFIC); support to DNFBP and money transfer supervision.

• APG delivered technical assistance in cases where there are no other providers able to

assist or there is a pressing strategic opportunity - asset confiscation support to Tonga; and NPO risk-based regulation to Fiji;

• APG contributed global and regional processes supporting the Pacific, for example

various FATF projects (financial inclusion, PF, low-capacity countries), World Bank/PIFS CBR project, etc.

• APG supported assistance for the development and use of legislative packages suitable

for Pacific members, including TFS legislative support (Palau) and a pilot model legal framework project for non-conviction-based forfeiture (initially with the Cook Islands);

ANNUAL REPORT 2024-2025 21 OFFICIAL OFFICIAL

PART FOUR Management and Accountability

Summary of financial performance for 2024-25 4

1. The overall financial results for the period 1 July 2024 to 30 June 2025 are as follows:

2024-25 FY ($AUD) Actual Budget Variance

1. The APG membership agreed to a budgeted deficit of AUD$440,485. Due to temporary staff

vacancies and efficiencies found in travel, the APG ended the 2024-25 FY with a surplus of AUD$258,161. The surplus will be retained in APG equity. Core Funding 2024-25

1. Membership contributions form the core budget to undertake core APG business. The financial

results from the core budget are as follows: 2024-25 FY ($AUD) Actual Budget Variance Net Operating Position 164,790 -440,485 605,275 Voluntary financial support 2024-2025

1. The Co-Chairs and the Secretariat on behalf of all APG members thanked Australia, China,
   Japan, New Zealand, Chinese Taipei and the United Kingdom for their significant and ongoing financial support of APG activities in 2024-2025 through voluntary contributions. These have contributed to ensuring that the APG remains a high-performing FSRB.

2. The overall financial results for voluntary financial support are as follows:

2024-25 FY ($AUD) Revenue Expense Variance 5 6,916 6,916 0

1,226,192 1,181,806 44,386 80,747 78,969 1,778

All figures in Australian Dollars (AUD) 4 The APG accounting policy is to recognise revenue when the expense has occurred. There are slight variances due to timing issues at 5 the end of this FY and previous FYs.

ANNUAL REPORT 2024-2025 22 Project Contribution (PACD)- New Zealand OFFICIAL OFFICIAL

In Kind Support - Australia Voluntary Contribution - Australia Project Contribution - China Project Contribution - New Zealand MOJ Project Contribution - Chinese Taipei 45,957 874,739 341,034 -9,380 102,483 4,401 60,367 874,739 331,654 148,440 64,768 Net Operating Position -440,485 182,324 258,161 Income Expenses IncomeExpenses 7,560,425 7,172,288 7,302,264 7,612,773 4,805,900 4,707,379 4,641,110 5,147,864 388,137 310,509 506,754 98,521 Ministry of Foreign Affairs & Trade

In-kind support

1. Australia provided on-going in-kind enabling services (accommodation, ICT services, finance,

human resources, security, legal etc.) free of charge to the APG. The value of this in-kind support was estimated at AUD$874,739. Untied Funding

1. Australia paid a voluntary contribution of AUD$6,916 that was not tied to a particular project.

Project Contributions

1. China provided a voluntary contribution which supported a Pacific assessor on a Mutual

Evaluation and the attendance of Pacific delegates at the 2024 APG Annual Meeting and 2024 APG Typologies workshop.

1. Japan provided a voluntary contribution which supported the implementation of the Co-Chairs' priorities. In 2024-25, this included: o high-level visits to Sri Lanka, Vietnam and Fiji o hosting of assessor training in Japan and expert presenters, delegates to attend assessor training in Japan and Macao, China o delegates and experts to attend the APG/World Bank Virtual Assets workshop o hosting, expert presenters and priority delegates to attend the Regional Pre-ME Preparation workshop in Fiji

• FSRB collaboration with EAG and MENAFATF

1. New Zealand Ministry of Justice provided a voluntary contribution which supported experts

travelling from New Zealand to APG events to benefit members.

1. Chinese Taipei provided a voluntary contribution which supported:

• attendance of Pacific delegates at the 2024 APG Annual Meeting and the 2024 APG

Typologies workshop;

• APG members in the ICRG process; and
• APG website redevelopment.

PACD program funding

1. Funding from the New Zealand Ministry of Foreign Affairs and Trade supported the activities of the PACD Program. Since June 2023 the Ministry of Foreign Affairs and Trade has supported Phase II of the PACD program. Total value of the programme is NZD6,000,000 over five years (2023-2028). In 2023-2024, a total of AUD$652,815 was spent on: (i) dedicated staff positions, (ii) delivery of technical assistance and training projects to APG Pacific Members, and (iii) administrative costs. Additional detail is outlined in the PACD Program 2024-2025 Annual Report (Annex B).

ANNUAL REPORT 2024-2025 23 OFFICIAL OFFICIAL

Project Contribution - United Kingdom Total 21,313 21,069 2,667,627 86,898 2,754,525

Budget for 2025-2026

1. The APG's 2025-2026 budget and business plan was adopted at the 2024 Annual Meeting. The

agreed budget was an 18% increase from 2024-25. 2025-26 FY ($AUD) Core Non-Core Total Net Operating Position -800,000 0 -800,000

1. The Special Purpose financial statements for the year ended 30 June 2025, including the

independent auditor's review report can be found at Annex A.

ANNUAL REPORT 2024-2025 24 OFFICIAL OFFICIAL

7,495,299 8,285,299 IncomeExpenses5,532,807 1,962,492 6,322,807 1,962,492

Special Purpose Financial Statements

Annex A - Special Purpose Financial Statements

Table of contents

Statement by the Executive Secretary 3 Financial Statements Statement of comprehensive income 4 Statement of financial position 5 Cash flow statement 6 Notes to the Financial Statements Overview 7 Events after the reporting period 8 Note 1: Income 9 Note 2: Expenses 10 Note 3: Trade and other receivables 12 Note 4: Unearned income 12

Page 2 of 12

Statement by the Executive Secretary

Statement by the Executive Secretary

In my opinion:

1. The Asia/Pacific Group on Money Laundering (APG) is not a reporting entity and these special purpose financial statements
   and notes: · are based on properly maintained financial records and prepared in accordance with the accounting policies outlined i n the ov erview to the financial statements which are appropriate to meet the needs of users; · pr esent fairly the APG's financial position as at 30 June 2025 and its performance for the year ended on that date; and

2. At the date of this statement, there are reasonable grounds to believe that APG will be able to pay its debts as and when they
   become due and payable.

Chris Black Executive Secretary, APG Secretariat 15 September 2025

Page 3 of 12

Total revenue* 6,685,686 5,209,095 Gains

EXPENSES

*The increased activity reflected in revenue and expenses compared to the prior year relates to project activity funded by Japan and New Zealand MFAT.

Statement of comprehensive income Employee benefits Depreciation and amortisation 2.1 3,544,694 INCOME 4,280,504 5,552,213 485,019 Supplier expenses Notes 2.2 1,051,060 828,137 $ Contributions from members Other contributions 1.1 1.2 4,253,619 955,476 Total gains Total income Travel expenses Total expenses* Surplus 7,560,425 7,302,264 874,739 258,161 2.3 6,037,232 955,887 $ 1,819,666 4,805,900 1,879,786 Resources received free of charge from the AFP 1,201,522 828,137 874,739 Page 4 of 12

Non-financial assets

LIABILITIES

All supplier payables are expected to be settled within 7 days (2024: 7 days). All other payables are expected to be settled within 1 12 months. Employee provisions which are expected to be settled beyond 12 months (commonly long service leave), are discounted to present 2 value using market yields on the 10-year government bond rate.

Statement of financial position

Supplier payables Unearned income Salaries and wages Superannuation 2,235,865 125,289 76,648 12,377 ASSETS Financial assets 1,470,795 338,381 125,364 20,305 Intangibles FBT 6,170,291 6,171,387 2,452,516 1,096 1,096 2,337 - as at 30 June 2025 Cash and cash equivalents Property, plant and equipment 6,091,597 3,388,635 936,119 $ Notes Leave provisionsRetained surplus 2,782,752 2,782,752 2,782,752 936,119 Trade and other receivables Total financial assets Prepayments Total non-financial assets Total assets Total payables 78,694 6,253,476 6,431,650 1,957,854 137,581 178,174 3,009 - $ PayablesEQUITY 5,415,546 1,432,883 Total liabilities Total equity 3,390,737 3,040,913 3,040,913 Provisions Total provisions Net assets 1,432,883 3,040,913 837,930 40,070 Page 5 of 12

Surplus for the period 258,161 485,019

Cash flow statement

Cash used:

Statement of changes in equity Comprehensive income Employees 3,659,844 $ Operating activities 3,727,096 $ Total comprehensive income Contributions and other receipts 5,925,102 5,937,421 4,690,438 1,246,983 6,091,597 Suppliers and other payments 1,030,594 2,782,752 3,040,913 Total cash received Total cash used Net cash (used in) / generated from operating activities Cash and cash equivalents at the end of the reporting period 5,161,379 5,211,371 5,749,842 5,415,546 (538,471) 258,161 485,019 Net GST received from ATO Purchase of intangibles Net (decrease) / increase in cash held 1,246,983 12,319 $ - - - Cash and cash equivalents at the beginning of the reporting period 4,844,614 2,022,746 Retained surplus (676,051) $ Opening balance 2,297,733 2,782,752 6,091,597 49,992 Total cash used Net cash used by investing activities (137,580) 137,580 137,580 Closing balance Cash received: Page 6 of 12

Overview

Objectives of Asia/Pacific Group on Money Laundering

The purpose of the Asia/Pacific Group on Money Laundering (APG) is to facilitate the adoption, implementation and enforcement of internationally accepted standards against money laundering, terrorist financing and financing of the proliferation of weapons of mass destruction, in particular the Forty Recommendations of the Financial Action Task Force (FATF). The APG allows for regional factors to be taken into account in the implementation of anti-money laundering, anti-terrorist financing and anti-proliferation financing measures and provides for peer review by means of a mutual evaluation process.

Basis of preparation of the financial statements

The APG's accounts form part of the Australian Federal Police (AFP) special account, Services and Other Entities Trust Moneys Account. The AFP continued to host the APG for the year ended 30 June 2025 and has prepared this special purpose financial report for the members of the APG. This special purpose financial report has been prepared for distribution to the members to fulfil the Executive Secretary's financial reporting requirements under the APG Terms of Reference. The financial statements have been prepared on an accrual basis and in accordance with the historical cost convention. The financial statements are presented in Australian dollars and values are rounded to the nearest dollar unless otherwise specified. Unless alternative treatment is specifically required by an accounting standard, assets and liabilities are recognised in the statement of financial position when it is probable that future economic benefits will flow to the entity or future sacrifice of economic benefits will be required and the amounts of the assets or liabilities can be reliably measured. However, assets and liabilities arising under executor contracts are not recognised unless required by an Accounting Standard. Assets and liabilities that are unrecognised are reported as commitments. There is a capital commitment as at 30 June 2025 of $50,446 (2024: nil). Contingent liabilities and assets are not recognised in the statement of financial position but are reported in the notes. They may arise from uncertainty as to the existence of a liability or asset or represent an asset or liability in respect of which the amount cannot be reliably measured. Contingent assets are disclosed when settlement is probable but not virtually certain and contingent liabilities are disclosed when settlement is greater than remote. The APG does not have any contingencies as at 30 June 2025 (30 June 2024: nil). Unless alternative treatment is specifically required by an accounting standard, income and expenses are recognised in the statement of comprehensive income when and only when the flow, consumption or loss of economic benefit has occurred and can be reliably measured.

Significant accounting judgements and estimates

In the process of applying the accounting policies listed in this note, the APG has made the following judgement that has the most significant impact on the amounts recorded in the financial statements: · The liability for long service leave has been estimated using present value techniques. This takes into account expected salary growth through promotion, inflation, attrition and future discount rates. No accounting assumptions or estimates have been identified that have a significant risk of causing a material adjustment to carrying amounts of assets and liabilities within the next accounting period.

Page 7 of 12

New Australian Accounting Standards

Adoption of New Australian Accounting Standard Requirements No new or revised standards and interpretations that were issued prior to the sign-off date and are applicable to the current reporting period had a material effect on the APG's financial statements. Future Australian Accounting Standard Requirements No accounting standard has been adopted earlier than the application date stated in the standard. Gains Resources received free of charge Resources received free of charge are recognised as gains when and only when a fair value can be reliably determined and the services would have been purchased if they had not been donated. Use of those resources is recognised as an expense. Financial instruments The APG's financial instruments are measured at fair value. Interest-earning financial assets and liabilities are measured using the effective interest rate method. The carrying amount of all financial instruments in the Statement of financial position approximates fair value. Financial instruments held by the APG carry minimal credit, liquidity and market risk. Taxation The APG is exempt from all forms of taxation except Fringe Benefits Tax (FBT) and the Goods and Services Tax (GST).

Events after the reporting period

No significant events have occurred since the reporting date requiring disclosure in the financial statements.

Page 8 of 12

Bangladesh 39,492 43,779

Note 1: Income Note 1.1: Contributions from members Australia 248,967 263,084 Vanuatu 16,185 17,981 Vietnam 37,535 United States 717,049 Bhutan Marshall Islands Mongolia New Zealand Philipines Solomon Islands Sri Lanka Thailand 16,185 16,185 16,185 76,440 29,977 52,122 16,185 16,185 77,544 794,559 Canada Chinese Taipei Cook Islands Fiji Indonesia Japan Korea Macau, China Malaysia Maldives Nepal Pakistan Palau Samoa Singapore Timor-Leste Tonga Tuvalu 280,269 114,354 148,456 610,134 260,835 121,402 16,185 16,185 16,185 60,036 16,185 16,185 16,185 42,214 16,185 16,185 16,185 16,185 16,185 40,539 China Hong Kong, China India Lao PDR Myanmar Nauru 499,971 102,597 376,359 16,185 16,185 17,981 Brunei Darussalam Cambodia Total contributions from members 4,253,619 16,185 16,185 4,805,900 183,768 17,981 17,981 17,981 58,220 17,981 17,984 82,340 4,190 307,650 128,819 166,911 677,863 279,974 122,947 17,971 17,981 17,981 62,995 17,981 24,852 17,981 17,981 46,229 17,591 17,981 17,981 17,981 17,981 555,471 113,763 470,737 17,981 17,981 17,987 17,981 Page 9 of 12 Niue Member contributions

1,226,192 547,537 Project Contribution - NZ Ministry of Foreign Affairs and Trade1

Accounting Policy Contributions Increase in Japan VC revenue($300k) and increase in MFAT Pacific funding ($700k) 1 Contributions from members are annual contributions from APG members to fund the ongoing activities of the APG. They are recognised as income on receipt. This treatment of income is consistent with AASB 1058 Income of Not-for-Profit Entities . Voluntary contributions are received from members in accordance with funding agreements which establish the purpose of the activities, proposed budgets, monitoring and evaluation plans. Revenue from voluntary contributions are recognised as revenue over time when performance obligations are met. This treatment of revenue is consistent with AASB 15 Revenue from Contracts with Customers . Project contributions are additional allocations attributed to particular projects or activity as specified by the donor. Project contributions are recognised over time when performance obligations are met. This treatment of revenue is consistent with AASB 15 Revenue from Contracts with Customers.

2024 $ $

Accounting Policy

Liabilities for services rendered by employees are recognised at the reporting date to the extent they have not been settled. Liabilities for 'short-term employee benefits' (as defined in AASB 119) and termination benefits due within twelve months of the end of the reporting period are measured at their nominal amounts. The nominal amount is calculated with regard to the rates expected to be paid on settlement of the liability. All other employee benefit liabilities are measured as the present value of the estimated future cash outflows to be made in respect of services provided by employees up to the reporting date.

Superannuation: Note 2: Expenses Note 1: Income (cont.) Note 2.1: Employee benefits Note 1.2: Other contributions 64,288 331,654 Project Contribution - Chinese Taipei 81,950 Project Contribution - NZ MOJ Specific Travel 112,009 Voluntary Contribution - Australia Project Contribution - China Wages and salaries Leave and other entitlements 2,615,319 128,659 450,657 21,033 - Project Contribution - UK Other employee expenses Defined contribution plans Defined benefit plans 336,907 136,157 5,654 148,440 955,476 1,879,786 80,747 Total other contributions 3,544,694 3,081,347 393,215 187,594 605,642 64,768 6,916 21,069 12,706 Total employee benefits 4,280,504 Page 10 of 12

Note 2: Expenses (cont.)

Leave The liability for employee benefits includes provision for annual leave and long service leave. No provision has been made for sick leave as all sick leave is non-vesting as the average sick leave taken in future years by employees of the APG is estimated to be less than the annual entitlement for sick leave. The leave liabilities are calculated on the basis of employees' remuneration at the estimated salary rates at the time the leave is taken, including the APG's employer superannuation contribution rates to the extent the leave is likely to be taken during service rather than paid out on termination. The liability for long service leave has been determined by reference to the work of an actuary as at 30 June 2025. Attrition rates and pay increases through promotion and inflation are taken into account in the estimate of the present value of the liability. A full review by an actuary is conducted every 3 years. Superannuation Staff of APG are members of the Commonwealth Superannuation Scheme (CSS), the Public Sector Superannuation Scheme (PSS) or the PSS accumulation plan (PSSap). The CSS and PSS are defined benefit schemes for the Commonwealth of Australia. The PSSap is an accumulation fund. The liability for defined benefits is recognised in the financial statements of the Australian Government and is settled by the Australian Government in due course. This liability is reported in the Department of Finance's administered schedules and notes. APG make employer contributions to their employee's superannuation scheme at rates determined by an actuary to be sufficient to meet the cost to the Government of the superannuation entitlements of the APG's employees. APG accounts for the contributions as if they were contributions to defined contribution plans.

20242025

Other supplier expenses

Supplier expenses include $874,739 (2024:$828,137) of resources received free of charge from the AFP comprising 1 consultants and contractors $286,491 (2024: $254,481), building and accommodation $35,724 (2024: $43,723) and office space $552,524 (2024: $529,933).

Note 2.3: Travel expenses

Note 2.2: Supplier expenses 529,933 552,524 295,529 43,809 779,730 35,724 Audit fees General and office Office spaceOther expenses 11,500 10,386 30,405 Consultants and contractorsLegal fees Staff and recruitment Conference costs Communications and IT Building and accommodationAirfares Accommodation 550,198 311,810 997,106 36,387 28,331 9,917 Goods and services Other travel expenses 955,887 93,879 $ Workers compensation expenses Total other supplier expenses 1,819,666 704,351 1,051,060 12,000 16,007 36,896 50,676 53,954 53,954 105,287 219,963 327,093 10,859 $ - Total goods and services 1,768,990 170,078 50,676 Total supplier expensesTotal travel expenses 1,201,522 Page 11 of 12

Note 2: Expenses (cont.) Note 2.4: New Zealand Ministry of Foreign Affairs and Trade (MFAT) expenses*

Travel 220,291 981,231 1,201,522 Total 1,181,806 6,119,886 7,301,692

• Note 2.4 does not include the depreciation expense. In 2017, the New Zealand government provided voluntary funding over five years to support a programme of technical assistance and training in the Pacific. This includes the establishment of three additional staff (referred to as the "Pacific Cell") in the APG secretariat. A second phase of this funding was agreed to in 2023 for an additional five-year period covering 2023 to 2028 This funding forms part of the APG's accounts and is reflected in these financial statements. However, for accountability reasons, and to ensure that this funding does not affect other APG resourcing from member contributions, day to day management of this funding is kept separate from other APG funds. It is reported on separately here for transparency. 2024 2025

Less impairment loss allowance:

Includes five membership contributions which are expected to be received, but not received in full as at 30 June 2025. 1

Accounting Policy

Credit terms for goods and services are 30 days (2024: 30 days). Receivables are held for the purpose of collecting contractual cash flows and measured at amortised cost using the effective interest method adjusted for any loss allowance. Financial assets are assessed for impairment at the end of each reporting period based on Expected Credit Losses, using the general approach which measures the loss allowance based on an amount equal to lifetime expected credit losses. Note 4: Unearned income

All Other APG Total MFAT Note 3: Trade and other receivables 24,851 Not overdue Total unearned income 2,235,865 Member and project contributions paid in advance $ Breakdown of expenses Employee Project contribution - China Project contribution - NZ Ministry of Foreign Affairs and Trade Project contribution - US State Department 653,235 540,292 1,470,795 80,034 1,618 Supplier Project contribution - US State Department Project contribution - Chinese Taipei Project contribution - New Zealand Project contribution - Australian Department of Foreign Affairs and Trade Project contribution - UK 207,080 182,703 526,000 30,238 14,665 $ $ $ 4,280,504 1,819,666 3,545,105 1,593,550 272,778 241,314 526,000 208,638 15,265 58,641 - - $ 735,399 226,116 More than 90 days 59,280 59,140 148,159 796,277 $ Member contributions and other receivablesGST receivable from the Australian Taxation Office 2,399 821,128 Receivable from AFP 17,015 78,694 78,694 2,517 - - $ Total trade and other receivables Total impairment loss allowance Total trade and other receivables (net) 856,500 837,930 (18,570) (18,570) 32,855 Page 12 of 12 Less: expected credit loss allowance

September 2025 Pacific AML/CFT

Capacity Development (PACD) Program

Phase II Annual Report 2024 - 2025

Annex B - PACD Annual Report

Policy Statement

The Asia/Pacific Group on Money Laundering (APG) aims to promote the effective implementation of international Financial Action Task Force (FATF) standards for anti-money laundering / counter terrorism financing / counter proliferation of weapons of mass destruction (AML/CFT/CPF) across the Asia/Pacific region. These standards target the criminal activities that undermine the legitimacy of financial systems and threaten the sound governance of economies, private sector investment and, operation of correspondent banking channels and ultimately, sustainable economic growth. Criminal activities, including corruption, drug-trafficking and environmental crimes, are not merely threats to good governance; they also draw illicit funds out of jurisdictions and public resources. This strains already scarce resources and thereby impacts the prosperity and stability of economies. By working to enhance the capabilities of institutions to detect, investigate, prosecute and repatriate illicit funds, this manipulation of public funds and capital flight can be minimised. A robust economy with an effective AML/CFT framework promotes inclusion in the broader international financial system and fosters private sector investment in trade, tourism and fisheries. Increased participation in the global economy encourages productivity, opportunities for trade and profitability leading to economic growth and development. Conversely, we have seen the severe repercussions on developing economies if they are excluded from global financial flows as a consequence of perceived risks of money laundering, terrorist financing or proliferation financing (ML/TF/PF). Locked Bag A3000 Sydney South New South Wales 1232 AUSTRALIA Tel: +61 2 5126 9110

ASIA/PACIFIC GROUP ON MONEY LAUNDERING / PACD PROGRAM 1 E mail: mail@apgml.org

Web: www.apgml.org

Contents

Contents 2 Abbreviations & Acronyms 3 Pacific AML/CFT Capacity Development (PACD) Program 5

Goal 5 Objectives 5 Stakeholders 5 Pacific AML/CFT Operating environment 6 Program Overview 6 APG Secretariat Update 7 Program Design and MERL Framework 7

2024-2025 Report Against PACD Program Business Plan 10

Contributing Objective 1: Increased awareness of, and demand for, support available from APG/PACD, including implementation planning, TA coordination, and other APG services, contributing to the Overarching Objective 10 Contributing Objective 2: Increased regional coordination to enhance risk-based AML/CFT systems by Pacific Jurisdictions and Donors and Providers 14 Contributing Objective 3: Increased capacity that enhances risk-based AML/CFT systems of selected stakeholders 19 Cross-cutting Contributing Objective: Enhanced benefits and roles for women in relation to AML/CFT activities in the Pacific 27

Detailed Expenditure 2024-2025 29 PACD Program Design Risks and Assumptions 31 Annex A - PACD Program Design (Full) 32 Annex B - PACD Program MERL Framework 37

ASIA/PACIFIC GROUP ON MONEY LAUNDERING / PACD PROGRAM 2

Abbreviations & Acronyms

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AFP Australian Federal Police APEC Asia-Pacific Economic Cooperation ASEAN Association of Southeast Asian Nations CFT Countering Financing of Terrorism DAP DNFBPs Designated Non-Financial Businesses and Professions FATF Financial Action Task Force FSVC Financial Services Volunteer Corps ICAC [PNG] Independent Commission Against Corruption IIJ International Institute for Justice and the Rule of Law ME Mutual Evaluation MFAT [New Zealand] Ministry of Foreign Affairs and Trade ADB Asian Development Bank AFI Alliance for Financial Inclusion AGD [Australian] Attorney-General's Department AML Anti-Money Laundering APG ARIN-AP Asset Recovery Interagency Network - Asia Pacific AUSTRAC Australian Transaction Reports and Analysis Centre CBR Correspondent Banking Relationship CPF Countering Proliferation Financing D&I Diversity and Inclusion DIA [New Zealand] Department of Internal Affairs DJAG [PNG] Department of Justice and Attorney General EMG Executive Management Group FASU [Papua New Guinea] Financial Analysis & Supervision Unit FIU Financial Intelligence Unit FSRB FATF-Style Regional Body GIFCS Group of International Finance Centre Supervisors GIZ Germany's Global Program Combating Illicit Financial Flows ICRG International Co-operation Review Group IDB Inter-American Development Bank ILSTA Luxembourg's Institute for Legal Support and Technical Assistance IMF International Monetary Fund MER Mutual Evaluation Report MERL Framework Monitoring, Evaluation, Research and Learning Framework ML Money Laundering MTOs Money Transfer Operators

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NCBF Non-Conviction Based Asset Forfeiture NGO Non-Governmental Organisation NPOs Non-Profit Organisations OECD Organisation for Economic Co-operation and Development OPP [PNG] Office of Public Prosecutor PDG [Pacific Islands Forum] Pacific De-Risking Group PF Proliferation Financing PFTAC Pacific Financial Technical Assistance Centre PICP Pacific Islands Chiefs of Police PILON Pacific Island Law Officer's Network PNG RPNGC Royal Papua New Guinea Constabulary SIP Workshop Strategic Implementation Planning Workshop STC [FATF] Standards Training Course SWOT Analysis Strengths, Weaknesses, Opportunities and Threats Analysis TA&T Forum Technical Assistance and Training Forum TF Terrorism Financing TWG [PNG] Technical Working Group UN CTED United Nations Counter-Terrorism Committee Executive Directorate UNODC United Nations Office on Drugs and Crime VASPs Virtual Asset Service Providers WCO World Customs Organisation VFIU Vanuatu Financial Intelligence Unit NCC [PNG] National Coordination Committee OCO Oceania Customs Organisation PACD Pacific AML/CFT Capacity Development PFIC Pacific Financial Intelligence Community PIFS Pacific Island Forum Secretariat PSCF Private Sector Consultative Forum SOP Standard Operating Procedure TA Technical Assistance TFS Targeted Financial Sanctions UNDP United Nations Development Programme

Pacific AML/CFT Capacity Development (PACD) Program Goal

To support economic stability, safety and security of Pacific Islands communities by strengthened and targeted efforts against financial crime

Objectives

Stakeholders

APG Members and Observers Included in the PACD Program

APG Donors and Providers (DAP) Group

• Asian Development Bank (ADB)/ Organisation for Economic Co-operation and Development

(OECD) Anti-Corruption Initiative for Asia-Pacific

• Alliance for Financial Inclusion (AFI)
• Asia-Pacific Economic Cooperation (APEC) secretariat
• Asset Recovery Interagency Network - Asia Pacific (ARIN-AP)
• Association of Southeast Asian Nations (ASEAN) secretariat
• Asian Development Bank (ADB)
• Australia
• Canada
• Cook Islands • Solomon Islands • China
• Fiji • Timor-Leste • Chinese Taipei
• Republic of Marshall Islands • Tonga

• Nauru • Tuvalu Substantive actions to enhance risk-based AML/CFT systems by
  leadership and technical personnel of: • Niue • Vanuatu Contributing Objective 2 Increased regional coordination to enhance risk-based AML/CFT systems by: • Pacific governments and private sectors • Palau • Federated States of Micronesia (APG Contributing Objective 1 Increased awareness of, and demand for, support available from ASIA/PACIFIC GROUP ON MONEY LAUNDERING / PACD PROGRAM 5 observer) • Pacific jurisdictions • Regional multilaterals • Papua New Guinea Contributing Objective 3 Cross-cutting APG/PACD, including implementation planning, TA coordination, and Increased capacity that enhances risk-based AML/CFT systems of Enhanced benefits and roles for women in relation to AML/CFT

• Kiribati (APG observer) Contributing Objective other APG services, contributing to the Overarching Objective selected stakeholders activities in the Pacific • Donors and providers • Donors and providers • Samoa

• Commonwealth secretariat

• Egmont Group of Financial Intelligence Units (FIUs)

• Financial Services Volunteer Corps (FSVC)

• France

• Germany

• Group of International Finance Centre Supervisors (GIFCS)

• International Monetary Fund (IMF)

• INTERPOL

• Inter-American Development Bank (IDB)

• Japan

• Korea

• Malaysia

• New Zealand

• Oceania Customs Organisation (OCO)

• Pacific Islands Chiefs of Police (PICP)

• Pacific Island Forum Secretariat (PIFS)

• Pacific Island Law Officer's Network (PILON)

• Pacific Financial Technical Assistance Centre (PFTAC)

• United Kingdom

• United Nations

• United Nations Counter-Terrorism Committee Executive Directorate (UN CTED)

• United Nations Office on Drugs and Crime (UNODC)

• United States

• World Bank

• World Customs Organisation (WCO)

Pacific AML/CFT Operating environment

Over the year there have been several important changes in the regional operating environment for anti-money laundering / countering financing of terrorism / countering proliferation financing (AML/CFT/CPF) technical assistance (TA). These include:

• The region has seen increasing numbers of TA providers (even more so than when the PACD

program began).

• The APG Global 5th Round of Mutual Evaluations (MEs) has begun and all members from the

Pacific are scheduled to be assessed by 2033.

• Papua New Guinea will enter the Financial Action Task Force (FATF) International Co-

operation Review Group (ICRG) process in early 2026 - the first time a Pacific member has been in ICRG since 2018.

• The reduction or loss of critical correspondent banking relationships (CBRs) is worsening -

CBR pressure is partly due to poor AML/CFT progress.

• More Pacific members are under pressure due to unmitigated money laundering (ML) risks

from offshore centres and from new revenue schemes, e.g. citizenship by investment schemes.

Program Overview

The PACD Program's fundamental focus is on activities that help Pacific members to address the most pressing challenges to AML/CFT/CPF, and to make efficient progress with the effective operation of each member's risk-based AML/CFT/CPF systems. This is done through:

• Deepened TA coordination and collaboration (both member-specific and regional)
  ASIA/PACIFIC GROUP ON MONEY LAUNDERING / PACD PROGRAM 6

• Improved stakeholder engagement (members, regional partner organisations, TA donors and

providers)

• Member-level strategic implementation planning support (before and after an ME and in

cased of ICRG listing)

• Support to strengthen strategic AML/CFT/CPF leadership
• Delivery of TA in situations where there are no other TA providers able to assist or there is a

pressing strategic opportunity

• Contributing to global and regional processes supporting the Pacific, including projects
  related to financial inclusion, proliferation financing, support for low-capacity countries, and bank de-risking The PACD Program has identified several areas for priority assistance in the design and delivery of activities in the previous financial year, which respond to the evolving regional operating environment. Priorities particularly relate to:

• Members with upcoming FATF ICRG grey listing (Papua New Guinea)

• Members with an upcoming ME (Fiji, Vanuatu, Samoa, Palau)

• Members under serious CBR pressure (Marshall Islands, Samoa, Tonga, Tuvalu, Vanuatu -

Solomon Islands)

• Newer APG members or those who have received relatively little attention so far (Tuvalu)
• Members who recently completed an ME (Marshall Islands, PNG, Nauru, Timor Leste, Niue)

APG Secretariat Update

The Pacific directorate has been fully staffed during the reporting period with a Director, a Deputy Director, and two Policy Officers. In October 2024 there was a change in Director with David Shannon taking over from Suzie White. Caitlin Ryan, Susan Maggiore and Bailey Reinke remained in the directorate. In May 2025 the APG Secretariat completed a restructure and the organisation is now comprised of the following directorates:

• Pacific
• Training and Capability
• Mutual Evaluation Coordination
• Follow Up Processes
• Technical Assistance and Typologies
• Engagement and Secretariat Services
• Corporate and Enabling Services The APG Secretariat also created an Executive Management Group (EMG). The EMG is the peak forum for internal decision making on issues affecting the APG Secretariat (including for the Pacific directorate). While the EMG does not change the ability of leadership in the APG Secretariat to make decisions as appropriate, it ensures that decision making on cross-cutting points is consultative, consistent and transparent. Membership includes the APG Secretariat Executive Secretary, the Deputy Executive Secretary, and all Directors (including the Pacific Director).

Program Design and MERL Framework

In keeping with the requirements of the New Zealand Ministry of Foreign Affairs and Trade (MFAT) as the donor of the PACD program, the Pacific directorate has developed a monitoring, evaluation, research, and learning (MERL) framework. This is a tool to gather evidence needed to help manage, learn and make decisions about PACD program activities. The MERL framework also helps to navigate PACD program activities through risks, issues and uncertainties.

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To develop the MERL framework, the Pacific directorate held a workshop in December 2024, facilitated by an expert in design, monitoring, and evaluation from the Australian Federal Police (AFP). The workshop identified that a new program design was needed to explicitly outline the unique services that the PACD program is able to deliver, which differ from other TA providers in the region. The new program design reflects the program's engagement with political and government leaders responsible for AML/CFT, and an ongoing priority focus for the program will be on activities which enhance political support for improvements to Pacific jurisdiction's AML/CFT systems, so that other TA providers can then provide their capacity-building activities. The development of the new program design enabled the establishment of a logical MERL framework which will be used to demonstrate the successes of the program. The program design and MERL framework are aligned with the PACD program phase II grant funding agreement and were approved by MFAT in January 2025. The 2024-2025 annual report is structured against the new program design objectives, but as the MERL framework was approved halfway through the 2024-2025 Business Plan, the Pacific directorate is continuing to develop the baseline data systems and will make its first report against the full set of MERL framework indicators in the 2025-2026 progress report. All future annual reports and business plans will be aligned with the new program design and report against the MERL framework, which have replaced the previous PACD Program Phase II Strategic Plan. The program design logic is below, and the full program design is in annex A and the MERL framework is in annex B.

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2024-2025 Report Against PACD Program Business Plan Contributing Objective 1: Increased awareness of, and demand for, support available from APG/PACD, including implementation planning, TA coordination, and other APG services, contributing to the

Activity 1: Increased Direct Engagement

Task 1.1: Specific APG-delivered events Sub-task 1.1.1: Use Annual Meeting / TA&T Forum to enhance engagement with key stakeholders The 2024 APG Annual Meeting and Technical Assistance and Training (TA&T) Forum was attended by over 400 delegates from across the Asia/Pacific during the week of 23 September in Abu Dhabi, United Arab Emirates. The 2024 TA&T Forum was the major TA coordination event of the APG year and involved coordination meetings of the APG DAP Group, Pacific regional TA coordination meetings with all Pacific members and the DAP Group, and individual TA coordination meetings with each Pacific member and the DAP Group. During the meeting delegates discussed important issues and took critical decisions to strengthen collaboration, cooperation and overall effectiveness in combating serious financial crime. The APG also welcomed the Deputy Vice Minister of Finance for International Affairs at Japan's Ministry of Finance, Mitsutoshi Kajikawa of Japan, as the new APG Co-Chair for 2024-2026. Four APG mutual evaluation reports (MERs) were adopted, all of which are PACD program-eligible members: The Marshall Islands, Nauru, Papua New Guinea, and Timor-Leste. Since the adoption of these MERs the PACD program has delivered Strategic Implementation Planning (SIP) workshops in PNG, Nauru, the Marshall Islands, and Timor Leste. See Activity 10 for more details on these SIP workshops. The Pacific directorate undertook comprehensive planning and preparation, including information collection, donor coordination and extensive pre-briefings for the 2025 Annual Meeting and TA&T Forum which will be held in August 2025 in Tokyo, Japan. See activity 8 for more details on the TA&T Forum. Sub-task 1.1.2: Support Pacific members to attend and contribute to the annual APG Typologies Workshop The APG delivered the 25th Annual Typologies Workshop in Kuala Lumpur, Malaysia in November

1. The Typologies Workshop brought together leading experts from the public sector, private industry and civil society to share knowledge and expertise on ML/TF/PF trends and AML/CFT/CPF implementation. The 2024 workshop included two streams: abuse of legal persons, and cyber enabled fraud/scams. The plenary sessions included presentations on case studies from APG members, the typologies work of APG observers, and the FATF Global Network. Sub-task 1.1.3: Provide sponsorship for Pacific members to attend the APG Annual Meeting The PACD program funded one member from the Vanuatu Financial Intelligence Unit (VFIU), one from the National Reserve Bank of Tonga, and one from the Nauru FIU, to attend the Annual Meeting. Sub-task 1.1.4: Provide sponsorship for Pacific members to attend the Typologies Workshop The PACD program funded one member from the PNG Financial Analysis & Supervision Unit (FASU), one member from Samoa's FIU, and one member from Nauru's FIU to attend and contribute to the

ASIA/PACIFIC GROUP ON MONEY LAUNDERING / PACD PROGRAM 10

2024 Typologies Workshop. These attendees presented to the event with expertise on trends and context in the Pacific. Task 1.2: Other forums and workshop In November 2024 the Pacific Director attended the 3rd Annual Pacific Financial Intelligence Community (PFIC) Plenary Meeting in Brisbane. The meeting included discussion on the consideration of the PFIC 2024 work program and potential future activities, as well as how members can work together to strengthen the Pacific's resilience to emerging financial crime threats. The Pacific Director delivered presentations on FATF requirements related to virtual assets and virtual asset service providers, and an update on the ME process and the technical assistance available to Pacific jurisdictions. The Pacific directorate attended the 43rd Annual Meeting of the Pacific Islands Law Officers' Network (PILON) in Fiji in October 2024. PILON is dedicated to promoting a safe and secure Pacific by addressing key law and justice issues through a network of senior law officers from 19 Pacific Island nations, including Australia and New Zealand. At the meeting, members discussed various topics including corruption and the rapidly evolving linkages between corruption and transnational organised crime and its impacts on the Pacific region. The Pacific Director gave an overview of the APG and the ME process, timing of assessments in the Pacific and the TA available to Pacific jurisdictions. The PACD program funded an APG Secretariat member to attend a PILON Corruption Working Group Workshop in Nadi, Fiji in February. The workshop, focused on asset seizure and confiscation, was organised by PILON in collaboration with Fiji, Australia, and other partners. Recognising that asset confiscation is essential to an effective anti-money laundering and counter-terrorism regime, the workshop brought together prosecutors and law enforcement officers from each PILON member to strengthen each jurisdiction's asset confiscation capability by facilitating knowledge sharing and regional collaboration. The workshop focussed on building participants' knowledge and skills in the investigation and litigation of asset confiscation matters, including through practical exercises and group discussions. As a result of the APG Secretariat's participation in the workshop, awareness of new requirements related to asset recovery in the next round of MEs of Pacific jurisdictions increased, as well as opportunities for technical assistance more broadly from the PACD program. Following active networking with Pacific participants during the workshop, PNG requested further support from the PACD program to assist in the implementation of an agency-specific action plan for the Royal Papua New Guinea Constabulary (RPNGC) regarding action items in their ICRG observation period. The Pacific Director attended the Asset Recovery Interagency Network - Asia Pacific (ARIN-AP) annual general meeting in Sydney in November. ARIN-AP is an informal network of law enforcement and central authority contacts established to exchange information on individuals, companies and assets at the international level, with the intention of facilitating the pursuit and recovery of proceeds of crime. Investigators can use ARIN-AP enquiries to assist their investigations in the Asia Pacific Region. Current member countries include the Cook Islands, Timor-Leste, Tonga, and Vanuatu. The APG Secretariat has continued to engage with the Pacific Islands Forum Secretariat (PIFS) via the World Bank's CBR project (see Task 5.6). Sub-task 1.2.1: Support Pacific members to attend and contribute to non-APG forums and workshops In April, the PACD program funded the Governor of the Reserve Bank of Samoa and one APG Secretariat staff member to attend the 2025 Private Sector Consultative Forum (PSCF) in India. See Task 5.4 for more details. Sub-task 1.2.2: Provide sponsorship for Pacific members to attend non-APG forums and workshops In April, the PACD program funded the Governor of the Reserve Bank of Samoa and one APG Secretariat staff member to attend the 2025 PSCF in India. See Task 5.4 for more details.

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Task 1.3: Meetings Sub-Task 1.3.1: Diplomatic engagement in relevant jurisdictions The Pacific directorate engaged with diplomatic corps members during visits to APG members, and through virtual briefings. Briefings were delivered at SIP workshop and ME preparation visits to Fiji, the Marshall Islands, PNG, Timor Leste and Vanuatu. The briefings included bilateral and multilateral missions and focused on issues of priority assistance, support for international cooperation and messaging on the importance of strategic AML/CFT leadership. During the visit to Fiji, the Pacific directorate provided briefings to the PIFS and to the Ambassador of the European Union to the Pacific to address Pacific-wide AML/CFT issues. As part of intensive support to PNG as it prepares for ICRG grey listing, the Pacific directorate has also engaged extensively with diplomatic corps representatives in PNG. Sub-Task 1.3.2: Meetings with private sector in relevant jurisdictions The Pacific Director met with members of the private sector during visits to Vanuatu, PNG, Nauru and the Marshall Islands. Briefings with the private sector focused on issues of capacity building, joint development of guidance, collaboration on the risk-based approach and the key role of the private sector in messaging to lawmakers and leaders on the importance of strategic AML/CFT leadership. In April, the PACD program supported an APG Secretariat staff member to attend the 2025 PSCF in India. See Task 5.4 for more details. Task 1.4: Strategic Implementation Planning workshops, Mutual Evaluation workshops, High-Level Visits Sub-task 1.4.1: Provide sponsorship for Pacific members to attend Mutual Evaluation-related Workshops (shared task with 10.3.6 below) The APG Secretariat delivered a pilot Regional ME Preparation Workshop focused on supporting ME coordination staff, which was sponsored by Japan and held in Nadi, Fiji in April 2025. The Pacific directorate administered the Japanese funding to ensure delivery of this regionally significant event that involved several Pacific members. The PACD program is likely to support this event in the next reporting period.

Activity 2. Increased Media Presence

Task 2.1: Develop press releases and engage with relevant journalists The APG Secretariat appointed a communications specialist to support its communications to members, who is also providing support to the Pacific directorate. This enhanced communications work will involve the development of an APG Secretariat communications strategy, which will include a PACD program communications strategy during the next reporting period. During the November 2024 SIP workshop in PNG, the Pacific Director joined a media conference held by the PNG Government to deliver messages regarding the importance of the PNG Government working together to address the recommendations in their MER, to avoid ICRG listing. See Activity 13 for more details. During the Marshall Islands SIP workshop in February, the Pacific Director met with representatives from a non-governmental organisation (NGO) working with jurisdictions in the Pacific on media strategies and training. The PACD program intends to engage with this NGO more closely in the next reporting period.

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Task 2.2: Social media engagement APG Secretariat has continued to increase the coverage of PACD program events and activities on the APG website and via social media posts. The APG Secretariat communications specialist has worked with the PACD directorate to develop posts for the new APG Secretariat LinkedIn page, which was launched in late June. Task 2.3: PACD Program Newsletter The PACD program has continued to produce quarterly program updates via a newsletter to ensure Pacific members, DAP Group members and other stakeholders are up to date with PACD program activities, AML/CFT news and other TA&T opportunities. The APG Secretariat has also updated its membership-wide newsletter which includes updates on the PACD program, so they reach a wider audience.

Activity 3. Expanded Supporting Materials

Task 3.1: Prepare layered supporting materials for all above The Pacific directorate intends to develop supporting materials for government agencies in Pacific jurisdictions to engage with local media to communicate with their communities the importance of AML/CFT work, how it is relevant to their citizens, and the success stories on AML/CFT. This work will be conducted in the next financial year.

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Contributing Objective 2: Increased regional coordination to enhance risk-based AML/CFT systems by Pacific Jurisdictions and Donors and Providers

Pacific Jurisdictions Activity 4. Identify or create full range of coordination forums/working groups required

Task 4.1: Develop and maintain a database and calendar of AML/CFT forums and working groups See Activity 8 for details.

Activity 5. Directly support regional discussion/actions

Task 5.1: Regional PF risk assessment Sub-task 5.1.1: Sponsorship to PF Risk Assessment Workshop The PACD program funded seven members (four men and three women) from seven jurisdictions (Solomon Islands, Tuvalu, PNG, New Zealand, Cook Islands, Vanuatu, and Nauru) to attend the two day UNODC Regional Counter Proliferation Financing Workshop for Pacific Island Countries in Fiji in November 2024. The PACD program also funded an APG Secretariat Deputy Director to attend to speak about national risk assessments on proliferation financing. The APG Secretariat co-hosted the event under the PACD program, and key stakeholders in attendance included UNODC, Kings College London, Australian Transaction Reports and Analysis Centre (AUSTRAC), and the New Zealand Police FIU. The workshop focussed on international best-practice in counter proliferation financing frameworks, improving regulatory oversight, enhancing intelligence-sharing mechanisms, and boosting the ability of Pacific nations to detect and counter proliferation financing. The workshop also involved Pacific jurisdictions conducting a strengths, weaknesses, opportunities and threats (SWOT) analysis, and completing a scenario-based exercise. For the PACD program, the workshop identified the additional technical assistance needs of five participating members. Task 5.2: Joint Supervision support Sub-task 5.2.1: Sponsorship of Pacific jurisdictions to conduct join supervision activities together See task 9.4.1 and task 9.4.2 for details. Task 5.3: Support emerging regional discussions / actions as they emerge The PACD program supported discussion of emerging regional issues on financial crime risk management throughout the year. Citizenship by investment scheme risk management: Discussions were held during the 2024 TA&T Forum, bilaterally with various TA providers and with Vanuatu, Nauru and the Solomon Islands regarding risks and risk management associated with citizenship by investment schemes. Open shipping registries and proliferation financing risk management: With inputs from the Pacific directorate the APG Secretariat, with support from the UNODC, prepared and issued a shipping registries and PF risk factsheet in March 2025. The factsheet and highlighted case studies provided practical examples of proliferation financing risks and approaches to assessments that can inform members' understanding and response to proliferation financing risks

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Coordinating review of emerging financial crime risks - a pilot approach: During the SIP workshop visit to the Marshall Islands in February 2025 the Pacific directorate initiated a model outline for a piloting interagency review process to identify financial crime risks associated with 'get revenue quick' schemes that may be proposed to Pacific governments. This reflects Pacific members' experience of increasing numbers of approaches to lawmakers for potentially very risky schemes, including special economic zones, crypto asset schemes, golden passports, etc. Task 5.4: Private Sector Consultative Forum (PSCF) sponsorship In April, the PACD program funded attendance by Pacific AML/CFT leaders at the 2025 PSCF in India. The annual PSCF is attended by representatives from the financial sector, non-financial businesses and professions, civil society, academia, FATF members and other stakeholders. PSCF provides an opportunity for FATF and its members to directly interact with the private sector and civil society to strengthen partnerships in AML/CFT. India hosted the 2025 event which included more than 200 participants from around the world. The APG was represented by the Central Bank of Samoa Governor Atalina Ainuu-Enari and Deputy Governor Margaret Chan Cheuk-Tafunai, as well as Suzie White from the APG Secretariat. APG Co-Chair, Mitsutoshi Kajikawa, also attended and presented on complex proliferation financing schemes. Governor Atalina was a panellist during a key session focused on financial inclusion, de-risking and CBR challenges faced by Samoa and the Pacific more broadly. Discussions at the Forum focused on payment transparency issues, the evolving AML/CFT landscape, financial inclusion, supervision and the risk-based approach, beneficial ownership, digitalisation, information sharing and data privacy, terrorist financing and proliferation financing. A panel session on women in AML built on the FATF's initiative to advance diversity and inclusion efforts in the FATF and wider global network through the inclusion of the private sector and civil society into this important conversation. While not a panellist, Governor Atalina was asked by the FATF President to intervene and share her experience as a female leader. Governor Atalina spoke about Samoan culture and women's strong empowerment in Samoa. The event had low FATF-Style Regional Body (FSRB) attendance and Samoa was the only APG non-FATF member at the event. Task 5.5: Contribute to Pacific Banking Forum events and programs The PACD program supported the July 2024 Pacific Banking Forum, organised by Australia and United States and held in Brisbane, Australia in July 2024. The APG was represented by the Australian APG Co-Chair, the incoming APG Co-Chair from Japan and the APG Secretariat. The focus of the Forum was on the decline of correspondent banking relationships in the region, and steps forward to address this issue. The Pacific Director was included on an expert panel in relation to opportunities to enhance targeted AML/CFT measures to ensure that financial crime risk management does not add to de-risking pressures. The outcomes statement of the Forum provides further details. Following the Forum, the APG has committed to enhance the coordination of technical assistance in the Pacific, and initiate a forum between Pacific regulators and supervisors, and US correspondent banks, to provide an avenue for Pacific authorities to provide updates to those banks on risk, context and implementation of the FATF standards. The Pacific Director also contributed to the October 2024 Pacific Banking Forum Roundtable, which was a follow-on event to the Forum. The Roundtable included discussions on the World Bank's CBR project, feedback from development partners in the region, and discussions on private sector solutions to this issue. The PACD program has continued to contribute to virtual meetings of the Pacific Islands Forum Pacific De-Risking Group (PDG) in December 2024 and May 2025. The meetings covered the Pacific Strengthening CBR Project, discussion on strengthening payment systems and AML/CFT compliance, outlining the Pacific CBR Roadmap, and updates from partners of the project, including from the Pacific Director. The APG Secretariat has continued to liaise closely with the co-chair of the PDG.

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Task 5.6: World Bank CBR project [Pacific Strengthening Correspondent Banking Relationships project] The PACD program is continuing to prioritise regional and member-specific responses to AML/CFT concerns that may contribute to the loss of CBRs. The APG Secretariat has been very closely involved with the World Bank and the PIFS through the design and initiation of their Pacific Strengthening Correspondent Banking Relationships Project. The Pacific directorate has held regular consultation calls with the World Bank and has briefed various other stakeholders on the project, and held a half day briefing and coordination meeting with the PIFS in January 2025, which included discussion of the CBR project. In June the Pacific directorate also provided input on the Project's remedial plans for PNG, Kiribati, Tonga, Samoa, Solomon Islands, and Tuvalu. The Pacific directorate virtually attended and provided input to the World Bank's virtual second meeting of the Pacific De-Risking Group in November. This meeting included a review of the draft Terms of Reference for the two PDG working groups, discussion on the progress of the Pacific CBR Roadmap, and updates on the regional work being completed to improve AML/CFT compliance with international standards, which was delivered by the Pacific Director. Task 5.7: Supervisors Forum The second in-person meeting of the Pacific AML/CFT Supervisors' Forum was held in July 2024 in Brisbane, Australia. The Forum was organised by the Pacific directorate and delegates were sponsored through PACD program funding. The Forum was co-hosted by the APG Secretariat, the New Zealand Department of Internal Affairs (DIA) and the PIFS. The Forum brought together 62 AML/CFT supervisors and practitioners from each of the APG's 12 Pacific members, as well as delegates from Australia, New Zealand, United States, PIFS and World Bank. Participants shared key updates and discussed AML/CFT supervisory trends and developments in the Pacific region, with a variety of in-depth sessions and presentations delivered over the two days, including:

• Risk assessments and employing a risk-based approach to AML/CFT supervision
• Correspondent banking relationships and de-risking in the Pacific
• Best practices and lessons learnt in the supervision of financial institutions and designated

non-financial businesses and professions (DNFBPs) and virtual asset service providers (VASPs)

• AML/CFT engagement strategies
• Recent remedial and enforcement actions
• Preparations for the APG Global 5th Round of mutual evaluations
• Technical assistance and training needs and activities Key outcomes from the Supervisors Forum include a proposal for the future of the Pacific AML/CFT Supervisors' Forum, identification of supervisory-related technical assistance needs, and the development of proposals for joint supervision across jurisdictions. The PACD program funded 8 women and 10 men to attend, one each from the Cook Islands, Fiji, Nauru, Niue, Pacific Islands Forum Secretariat (PIFS) PNG, the Marshall Islands, Samoa, Solomon Islands, Tonga, Tuvalu, and Vanuatu, two from Palau, and four from New Zealand. Pacific delegates resolved for the Pacific Supervisor's Forum to more closely align with the PFIC in future years, with the PACD program continuing to provide support.

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Activity 6. Integrate regional issues/views into Contributing Objectives 1 & 3

Task 6.1: Develop and update briefing notes on each Pacific Jurisdiction's AML/CFT political priorities, as agreed to with the jurisdiction The PACD program has developed briefing notes on each Pacific Jurisdiction's AML/CFT priorities, which are updated as needed in consultation with the jurisdiction. These materials will be used so the PACD program and wider APG Secretariat maintain an up-to-date record of details about each jurisdiction and may also be used (with permission) when engaging with the private sector, development partners, and TA providers. It is also hoped that they can be used to communicate clearly with correspondent banks to outline the positive steps each jurisdiction is taking to avoid de- banking.

Activity 7. DAP Meeting Input

Task 7.1: Convene Pacific-focussed DAP meetings a minimum of four times per year The Pacific directorate has continued to engage with individual TA donors and providers (on an as- needed basis) and Pacific regional organisations to discuss coordination, delivery, and progress of TA activities to Pacific members. For this reporting period, the Pacific directorate has been in contact with several TA donors and providers including, but not limited to, the ADB, Australian Attorney- General's Department (AGD), AUSTRAC, IMF, New Zealand DIA, PIFS, UNODC and the World Bank. The following DAP Group meetings were held in the reporting period:

• July 2024 - ICRG-focussed including PNG
• August 2024 - Pacific-focussed
• November 2024 - Pacific and ICRG-focussed meetings
• March 2025 - Pacific and ICRG-focussed meetings

In addition to these formal DAP meetings, there have been multi-donor meetings about PNG and its upcoming grey listing.

Joint Activity 8. Technical Assistance Forum Input

Task 8.1: Maintain up to date records of TA needs of Pacific jurisdictions Sub-task 8.1.1: Pacific TA Overviews The Pacific directorate continues to maintain up-to-date overviews for each Pacific member. Overviews include APG Pacific members' recent TA activities, active TA projects, and future TA needs. Overviews are developed in consultation with APG members and DAP Group members and were updated following the TA Forum and on an ad-hoc basis as required (for example after the pre-ME visit to Vanuatu and the SIP workshop in PNG). Overviews inform the prioritisation of the Pacific directorate's TA activities and are available to all DAPs as a resource to support their TA to APG Pacific members. Work is currently underway to maintain a dashboard of TA needs and programs for each Pacific jurisdiction, which would be updated monthly and are able to be accessed by DAPs as

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needed. The APG Secretariat is developing a new website which will be launched before December 2025 and will enable the Pacific directorate to do this more efficiently and effectively. Sub-Task 8.1.2: Pacific TA Calendar Several Pacific jurisdictions have requested that the Pacific directorate also establish and maintain a calendar of AML/CFT forums, working groups, training, and other relevant information and so the directorate has maintained a TA&T calendar on the APG website since February 2025, which includes details on upcoming trainings, events, and other relevant details for DAPs and Pacific jurisdictions. The Pacific directorate has encouraged DAPs to add their programs to this calendar. Task 8.2: Deliver Annual TA&T Forum The Pacific directorate was critically involved in the preparation and delivery of the 2024 TA&T Forum. In parallel to the 2024 Annual Meeting, the APG convened its 22nd TA&T Forum which provided a collaborative platform to ensure AML/CFT technical assistance in the Asia Pacific region is coordinated, sequenced and synchronised. Participants included 25 TA recipient members and 19 DAPs. The high number of participants reflects the increased volume of AML/CFT TA activities occurring across the region. The Forum involved 29 meetings, including a closed five-hour session for DAPs to discuss the coordination of TA, three sub-regional meetings for members and DAPs (Pacific, South Asia and Southeast Asia), and 25 individual meetings between TA recipient members and DAPs. The 2025 TA&T Forum welcomed three new DAPs including the European Union AML/CFT Global Facility, Germany's Global Program Combating Illicit Financial Flows (GIZ) and Luxembourg's Institute for Legal Support and Technical Assistance (ILSTA). The APG also welcomed one new observer organisation, the International Institute for Justice and the Rule of Law (IIJ). The IIJ recently launched a significant program of TA in the Asia Pacific region. Comprehensive preparations occurred during the report period for the 2025 TA&T Forum to be held in August 2025, including compiling TA needs information from Pacific jurisdictions, TA information from DAPs, and input from members on the agenda for the Pacific Sub-Regional Meeting. Task 8.3: Support or develop additional technical assistance activities as they emerge Nil further activities to report in this financial year.

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Contributing Objective 3: Increased capacity that enhances risk-based AML/CFT systems of selected stakeholders

Activity 9. Provider of last resort (short notice/ad-hoc) capacity development

Task 9.1: Legislative drafting Sub-Task 9.1.1: NCBF legislation for Cook Islands The PACD program has continued to fund a legislative drafting project with the Cook Islands focusing on non-conviction-based asset forfeiture (NCBF), which is aligned with the new requirements on NCBF under FATF Recommendation 4. The project is being delivered by Lexbridge Lawyers and will involve a program in the Cook Islands to meet with key stakeholders in person to further the project ahead of its planned completion in December 2025. Sub-Task 9.1.2: NCBF model legal framework The PACD program has engaged Lexbridge Lawyers to prepare model legal provisions and policy guides for NCBF. This work is a follow on from the Cook Islands legislation in Sub-Task 9.1.1, and has included consultation with Pacific delegations. The model legal provisions and policy guides projected will be progressed in the next financial year.

The PACD program, through Lexbridge Lawyers, finalised a legislative drafting project to enhance Palau's targeted financial sanctions (TFS) framework for terrorism and proliferation financing (FATF Recommendations 6 and 7). This project had been on hold due to low capacity in Palau, but was reinvigorated in the reporting period. The project built on the existing TFS model provisions and focused on expanding the framework to cover proliferation financing. The project included elaboration of a legislative drafting plan, and support for preparation of the following draft legislation:

• Amendments of Chapter 33 of Title 17 of Penal Code
• Weapons Proliferation Sanctions Bill
• Weapons Proliferation and Terrorism Financing Bill
• Transmittal letter - Palau sanctions bills

This project is now substantially complete. Task 9.2: Reviews of Non-Profit Organisation Sector

The Pacific directorate, through an engaged non-profit organisations (NPO) expert, finalised a project to support enhancements to Fiji's risk-based approach to NPOs and compliance with FATF Recommendation 8. This project delivered the following:

• An updated review of the NPO sector in Fiji, covering all elements of FATF criterion 8.1

including: o identification of current higher-risk NPOs o establishment of criteria for identification of future higher-risk NPOs o recommendations for competent authorities

• A review of Fiji's NPO legislation, including a gap analysis against the requirements of Rec 8.

• A visit with relevant stakeholders on the NPO sector review
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• Development of an AML/CFT monitoring strategy, work program and manual for Fiji's at-risk
  NPOs in accordance with FATF criteria 8.2, 8.3 and 8.4 which included sustainable outreach and education programs, and risk-based supervision and monitoring manuals for NPOs Representatives from the Ministry of Justice in Fiji were satisfied with the work and noted that the manual was comprehensive and easy to understand. Task 9.3: Deliver mentoring and training for law enforcement The PACD program, through a respected asset recovery expert, provided short-term targeted technical assistance to Papua New Guinea to ensure that a baseline priority plan was in place to allow PNG to progress with critical reforms and targeted implementation in financial investigations and asset management. The project was in response to an urgent request for assistance to meet the priority recommended AML/CFT/CPF actions included in the 2024 PNG MER and the 2024 SIP workshop outcomes from November 2024. The project covered:

• Remote engagement and pre-planning with the RPNGC and other key stakeholders.

• In-country operational planning support to the RPNGC in developing a structured, priority plan

for targeted and sequenced implementation of SIP workshop outcomes. This included interagency workshops, case-focused planning, review of guides and operational planning tools and advisory support.

• Remote desk-based support, including follow up and future state planning, updated guides and an end of project report to the RPNGC and APG Secretariat summarising key outcomes and future plans. The project was a success and the RPNGC have requested follow up assistance. Task 9.3.1: Asset confiscation support and mentoring for Tonga The PACD program funded an asset confiscation mentoring project in Fiji and Tonga to enhance the law enforcement capacity of those Pacific members. An external asset recovery law enforcement expert delivered the projects through on-the-job training and operational support to the competent authorities in both jurisdictions. Across several week-long visits to Fiji and Tonga, the expert aided investigators in progressing urgent casework and assisted in developing standard operating procedures (SOPs), identifying evidence, devising investigation plans, and sharing analytical tools and templates that were relied upon to support ongoing cases. The visits were also conducted in conjunction with an expert from the Australian AGD, who provided strategic asset confiscation policy design support. The hands-on mentoring approach was well received by the authorities, and workshops conducted throughout the visits saw widespread participation by relevant agencies in both jurisdictions. The operational case support similarly saw several positive outcomes, including the successful development of restraint applications and preparation of several money laundering charges. In light of these outcomes, the Tongan Director of Public Prosecutions directly requested that the project be extended and the PACD program funded the expert to conduct an additional two-week visit to Tonga in late 2024. Task 9.3.2: Asset confiscation support and mentoring for Fiji See details in Task 9.3.1. Task 9.4: Deliver mentoring and training for supervisors At the Pacific Supervisors' Forum in Brisbane in July (see Activity 10), AML/CFT supervisors from the region highlighted their changing TA needs in relation to supervision. Members noted that they are seeking additional modes of assistance to complement training, including more on the job assistance,

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mentoring and the conduct of joint supervision, to enhance knowledge and outcomes. The PACD program had intended to fund supervision mentoring between the Solomon Islands and PNG, and Palau and PNG but due to timing constraints this project has been moved into the next financial year.

A mentoring project with the New Zealand DIA focused on DNFBP supervision had been paused, but planning for the project will continue in the next financial year. Sub-Task 9.4.2: Joint Money Transfer Operator (MTO) supervision The Pacific directorate collaborated with Australia, New Zealand, Tonga and Samoa on opportunities for joint AML/CFT supervision. The Pacific directorate developed two programs on joint supervision, one between Australia, New Zealand and Samoa, and the other one between Australia, New Zealand, and Tonga. These programs focus on the top local remitters / money transfer operators (MTOs) remitting to and from Tonga and Samoa. The program includes collaboration between the jurisdictions, and guidance on how to take fast tracked priority steps to intensify AML/CFT guidance, outreach and risk-based supervision of a priority set of remitters. The project with Tonga went through to completion, with lessons learned shared between regulators. The project with Samoa has seen delays due to conflicting priorities from participant jurisdictions but is expected to be delivered next financial year. Task 9.5: Deliver mentoring and training for Financial Intelligence Units There have been nil updates on this task in this financial year. Task 9.6: Deliver mentoring and training for relevant government policy agencies There have been nil updates on this task in this financial year. Task 9.7: Provide assistance for other capacity building requests on an ad-hoc basis from Pacific There have been nil updates on this task in this financial year. Sub-Task 9.7.1: Provide sponsorship for FATF Standards training The Pacific directorate has taken steps towards future delivery of FATF standards training to greater numbers of officers amongst Pacific members. During the reporting period, the FATF released the delivery materials of the Standards Training Course (STC) so that FSRBs and other organisations could deliver this training outside of Korea for the first time. The STC enhances participants' understanding of the FATF Standards on AML/CFT and the implementation of effective measures to combat ML/TF. It is an intermediate level training, designed for AML/CFT practitioners with prior exposure to the FATF standards, and is delivered through a series of e-learning, presentations, group discussions and small group activities. The Pacific directorate has been working with the Training and Capacity directorate to develop an STC which will be delivered to Pacific participants in Auckland next year.

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Activity 10. National implementation planning and coordination support

Task 10.1: Provide support to Pacific jurisdictions to implement the recommendations from their Mutual Evaluation Report In May 2025 the Pacific Deputy Director travelled to PNG as part of the PACD program activity supporting planning by the RPNGC (see also Task 9.3). The visit included a workshop with the PNG Office of the Public Prosecutor (OPP), FASU, and RPNGC in which members from each agency discussed how to progress several cases which had been stalled for a number of years. The visit also included ICRG-related briefings to the Independent Commission Against Corruption (ICAC) and RPNGC executive on steps to be taken to progress through the ICRG action plan. In May 2025 the APG Secretariat hosted the RPNGC, the OPP, and AFP members who are deployed to PNG and those in the Criminal Assets Confiscation Taskforce for technical briefings on the ICRG. The day-long discussions focused on PNG's preparation for the ICRG process, and how the AFP and APG Secretariat can support the RPNGC and OPP through this process. In June 2025 the Pacific Director and Deputy Director travelled to PNG to brief the PNG Technical Working Group (TWG) and National Coordination Committee (NCC) on preparations for their upcoming grey listing. At the TWG briefing, the Director worked through the current progress report which the group had submitted to the APG Secretariat for feedback on, including progress against the deficiencies identified in the MER. At the briefing to the NCC, the Deputy Director outlined the key dates that PNG will need to prepare for, the statutory reforms that will need to be implemented, and the importance of strong leadership throughout this process. The briefing also contained reflections on the progress that PNG had already made and reinforced the PACD program's continuing support. Task 10.2: Deliver Strategic Implementation Planning (SIP) Workshops to Pacific jurisdictions Sub-Task 10.2.1: Nauru SIP workshop The Pacific Director and a Policy Officer visited Nauru to deliver a SIP workshop in January. The visit focused on improving the conditions for banking services and ongoing financial inclusion initiatives, as well as protecting the investment and revenue conditions in Nauru from financial crime. The workshop ensured that officials from Nauru increased their understanding of the recommended actions included in the MER and the practical steps Nauru agencies should prioritise to achieve those actions. The workshop focussed on several areas including strategic context for the AML/CFT system, what effectiveness looks like, stress-testing existing strategic planning including TA, international cooperation, domestic coordination, contingency planning, pathways to Egmont membership, and strategic opportunities with the global 5th round. The APG Secretariat also held a one-day workshop focused on the FATF standards and regional AML/CFT implementation experience sharing. The SIP workshop visit resulted in a summary of priority TA needs which was shared with TA providers to request assistance and support coordination of TA. Sub-Task 10.2.2: Marshall Islands SIP workshop The Pacific Director delivered the Marshall Islands SIP workshop in June 2025, following the adoption of their MER at the 2024 APG Annual Meeting. The SIP workshop supported the Marshall Islands' AML/CFT Council agencies to consider priority steps for each of the recommended actions in the MER. The workshop resulted in a detailed SIP workshop outcomes document provided to the AML/CFT Council, which sets out the full details of the prioritised actions with a particular focus on AML/CFT efforts to protect CBRs. The SIP workshop visit included briefings with the private sector and diplomatic corps representatives, and it resulted in a summary of priority TA needs which was shared with TA providers to request assistance and support coordination of TA.

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Sub-Task 10.2.3: Timor-Leste SIP workshop The PACD program supported the APG Secretariat to deliver the Timor Leste SIP workshop in June 2025, following the adoption of their MER at the 2024 APG Annual Meeting. The delegation included representatives from the UNODC, the Portuguese Government, and the APG Secretariat. The PACD program funded the travel for the APG Secretariat members and for the representative from Portugal. The workshop was delivered to a 13-agency joint group which considered policies, procedures and activities to address the key deficiencies identified in Timor-Leste's MER, and on opportunities for enhanced interagency cooperation and better-targeted technical assistance and training. Timor-Leste still requires TA support in key areas including beneficial ownership, customs, tax, asset recovery, development of a national anti-corruption strategy, and targeted financial sanctions. The delegation also provided a briefing to the diplomatic corps on priority steps which Timor-Leste need to take after the workshop. Attendees included Australia, Malaysia, New Zealand, the Philippines, Portugal, the United States, the ADB and the UNODC. The SIP workshop resulted in a summary of priority TA needs, which was shared with TA providers to request assistance and support coordination of TA. Sub-Task 10.2.4: PNG SIP workshop In December the PACD program delivered a SIP workshop to PNG, following the adoption of PNG's MER at the 2024 APG Annual Meeting. The APG delegation included the Pacific Director and Deputy Director, and another APG Deputy Director who had worked on PNG's ME. All relevant PNG agencies took part, and the PNG government welcomed a wide range of TA donors and providers to attend and contribute to the entire workshop. This included Australian government representatives (the AFP, AGD), the UNODC and United Nations Development Programme (UNDP), United States Treasury, and the ADB. The SIP workshop was jointly hosted by FASU and the Department of Justice & Attorney General (DJAG). The workshop was held over three days, to consider policies and activities to address the key deficiencies identified in PNG's MER. Attendees included the PNG Chief Secretary (who opened the workshop), and over 100 representatives from contributing agencies to the NCC. The APG delegation focused on opportunities for enhanced interagency cooperation and better targeted TA&T, and in addition to the workshop provided briefings to the diplomatic corps and to the private sector on priority steps. The NCC adopted the summary outcomes of the SIP workshop and committed to address the deficiencies identified in the MER. The workshop also resulted in a summary of priority TA needs, which was shared with TA providers to request assistance and support coordination of TA. Following the workshop, the Pacific Director and Deputy Director travelled to Brisbane to brief the Commissioner of the RPNGC, who was unable to attend the workshop in Port Moresby (the RPNGC has a high number of actions in the MER which need to be addressed). The meeting resulted in an exchange of letters which added to the list of priority TA needs that were shared with TA providers to request assistance and support coordination of TA. Sub-Task 10.2.5: Tonga SIP workshop The Pacific directorate held virtual follow up TA coordination meetings with Tonga to follow on from the May 2024 SIP workshop visit, including the status of priority TA needs. The outcomes and expenditure of the May 2024 Tonga SIP workshop are reported in last year's PACD program annual report, but there were some miscategorised funds from that financial year which were moved over into the PACD program accounting records after that annual report was completed. These are included in the detailed expenditure section of this report. Sub-Task 10.2.6: Fiji SIP workshop This will occur in 2027 or 2028. Sub-Task 10.2.7: Vanuatu SIP workshop This will occur in 2027 or 2028.

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Sub-Task 10.2.7: Niue SIP workshop This will occur in the 2025-2026 financial year. Task 10.3: Provide support to Pacific jurisdictions to prepare for upcoming Mutual Evaluations

The APG Secretariat conducted a high-level visit to Fiji in April to brief leaders on strategic opportunities to harness the momentum of the upcoming APG ME process to deliver on Fiji's national interests. The visit was led by the APG's Japanese Co-Chair, Deputy Vice Minister of Finance for International Affairs Mitsutoshi Kajikawa and supported by the Pacific Director. The APG delegation observed the need for critical reforms including urgent legislative amendments to strengthen targeted financial sanctions legislation and the addition of more staff to the Ministry of Justice to ensure key statutory reforms on beneficial ownership of companies/trusts and NPOs. The visit also identified the need to prioritise many actions including enhancing interagency coordination, adjusting priorities and policies at national and agency level (as per updated findings from Fiji's national risk assessment), and to prioritise results on asset recovery. The visit resulted in a summary of priority TA needs, which was shared with TA providers to request assistance and support coordination of TA.

Based on an invitation from the Prime Minster of Vanuatu, an APG delegation visited Port Vila in August 2024 to provide intensive ME preparation assistance with two years before Vanuatu's next ME. The APG delegation included representatives from the United States Treasury, the United Kingdom's HM Treasury, and the Director and Deputy Director of the Pacific directorate. High level meetings were held with Prime Minister Charlot Salwai, the Attorney General, the Office of the Public Prosecutor, and many other agencies. Workshops were held with the joint agency working groups (supervisory and law enforcement) to consider prioritised policies and activities that deliver effective AML/CFT measures to address the greatest risks faced by Vanuatu. The APG delegation also held meetings with the private sector, diplomatic corps, and development partners, to brief them on the need for Vanuatu to prioritise its ME preparation and to deepen risk-based implementation of AML/CFT measures to ensure positive results with the ME. The PACD program will continue to support Vanuatu's AML/CFT priorities and will work to identify fast-tracked technical assistance in preparation for Vanuatu's upcoming ME. The visit resulted in a summary of priority TA needs, which was shared with TA providers to request assistance and support coordination of TA. An additional TA coordination support visit had been planned for this financial year, however due to a severe earthquake in December 2024 this was postponed until the coming financial year. Sub-Task 10.3.3: Pre-ME support to Niue This occurred in the 2023-2024 financial year. Sub-Task 10.3.4: Pre-ME support to Samoa This will occur in the 2025-2026 financial year. Sub-Task 10.3.5: Pre-ME support to Palau This will occur in 2027 or 2028. Sub-Task 10.3.6: Support the delivery of Pre-ME Workshops (shared task with 1.4.1 above) See details in Sub-Task 1.4.1.

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Task 10.4: Provide support to Pacific jurisdictions to coordinate their technical assistance Sub-Task 10.4.1: Tuvalu Implementation Support The Pacific directorate met with Tuvalu delegates in the margins of the Pacific Banking Forum and held calls to discuss TA coordination and implementation planning during the reporting period. A TA coordination support visit to Tuvalu had been planned in this financial year, however after consultation with the FIU it was agreed that the visit should be postponed until after they attended the 2025 TA Forum. The visit is now planned for the next financial year.

A TA coordination support visit was scheduled this financial year to Samoa, however due to the election in August 2025, this has now been moved to the following financial year.

Activity 11. Assessor Workforce Development

Task 11.1: APG Assessor training Sub-task 11.1.1: Provide sponsorship for Pacific members to attend assessor training The program funded one man from Nauru and one man from PNG to attend assessor training during the reporting period. Sub-task 11.1.2: Provide mentoring support for Pacific members who will or have attended See task 11.2 and task 11.3. Sub-Task 11.1.3: Support Pacific Assessors to participate in the Mutual Evaluations of other Pacific In the reporting period, the program funded one man from the Solomon Islands and one woman from Fiji to be assessors on the ME of Niue. See also task 11.3. Task 11.2: Develop and deliver Follow Up Report (FUR) training program The Pacific directorate developed a program to support new assessors from Pacific Jurisdictions between completing assessor training and commencing a follow up report or an ME. The training program was piloted internally with new staff in the APG Secretariat, and on review it was decided that it needed modifications before being delivered externally. The program will be implemented in the next financial year. See also task 11.3. Task 11.3: Develop additional training and mentor programs for Pacific assessors as required The Pacific directorate is developing a program to support Pacific assessors through the ME process, including working towards the option of a hybrid secondment into the APG Secretariat. This work will commence in the 2025-2026 financial year. See also task 11.2.

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Sub-Task 11.3.1: Assist Pacific jurisdictions to develop plans to meet their assessor contribution targets While the Pacific directorate outlined options for some Pacific members, this will work will commence in the 2025-2026 financial year.

Activity 12. Other focussed capacity development (addressing legislative/policy frameworks, bank de-risking issues, asset recovery, etc.)

The PACD program has continued to support targeted capacity development projects at the request of Pacific jurisdictions, as outlined in Activity 9.

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Cross-cutting Contributing Objective: Enhanced benefits and roles for women in relation to AML/CFT activities in the Pacific

Cross Cutting Activity 1 (G1): Scoping study of benefits, challenges, needs and risks associated with AML/CFT systems/outcomes affecting Pacific women, and defining why an enhanced role of women is important to AML/CFT systems in the region

Cross Cutting Task 1.1: Compile research on impact of ML/FT and on the AML/CFT work on women in the Pacific, in order to better target mainstreaming activities This work has been budgeted for and will commence in the 2025-2026 financial year. Cross Cutting Task 1.2: Seek views of women from Pacific jurisdictions on their experiences At the 2024 TA Forum, the Secretariat sought Pacific members' feedback on actions to enhance the role of women in AML/CFT in the Pacific. Based on extensive feedback received, the APG Secretariat strongly reinforced to members that any program must be guided by the needs of women from the Pacific region who work in AML/CFT, for it to be a success. Feedback was also sought on potential initiatives or thematic areas to respond to the priority needs of Pacific women, or if members have any specific expertise in this area which could be used or replicated regionally. This scoping exercise received scattered feedback from members, and the PACD program has continued to engage with members on this issue. See Cross Cutting Sub-Task 2.1.1 below for more details. The APG Ad Hoc Group on strategic AML/CFT Leadership included interviews with a number of Pacific women leaders in AML/CFT roles. Input from the interviews contributed to the Phase 1 report of the Ad Hoc Group which was reported to the 2025 APG Annual Meeting.

Cross Cutting Activity 2 (G2): All PACD program activity designs to be gender

Cross Cutting Task 2.1: Gender mainstream all PACD program activity designs The Pacific directorate has commenced work on gender mainstreaming all PACD program activities. As part of that focus the directorate is taking further steps to encourage nominations from Pacific members to APG events reflect the greatest diversity of participants. Currently nominations for assessor training include the following note: Nominations are welcome, irrespective of the applicant's racial or ethnic origin, opinions or beliefs, gender, sexual orientation, health, or disabilities. More work on the gender mainstreaming of all PACD program activities will be conducted in the next financial year. Sub-Task 2.1.1: Develop guidelines, policies, and arguments for how to ensure all PACD program activities are gender-mainstreamed At the 2024 Annual Meeting the APG established a Diversity and Inclusion (D&I) Network to best support the regional AML/CFT workforce. This program complements the work of the PACD program as the Network is developing a diversity and inclusion strategy for consideration at the 2025 APG Annual Meeting. Amongst the Network's two female Co-Chairs, one is a woman from Nauru who has been actively engaged in this work. The PACD program offered sponsorship for her to attend the 2025 Annual Meeting to speak to the Plenary about the work of the Committee but due to operational requirements she was unable to attend. The PACD program will continue to offer support to her in this role, and to the finalisation and implementation of the APG D&I Strategy.

ASIA/PACIFIC GROUP ON MONEY LAUNDERING / PACD PROGRAM 27

Cross Cutting Task 2.2: Collect gender-disaggregated data for all PACD program activities The PACD program maintains a gender-disaggregated database of participants on PACD program- sponsored travel sponsorship and participants at PACD program events. This reporting framework will be expanded to included gender disaggregated data for all activities in the next financial year. Cross Cutting Task 2.3: Gender mainstream jurisdiction-level APG planning for Pacific jurisdictions This work will commence in the next financial year.

Cross Cutting Activity 3 (G3): Increase the number of women from the Pacific who are assessors on MEs in the global 5th round

Cross Cutting Task 3.1: Training program targeted to women in AML/CFT to become ME assessors for the global 5th round See details in cross cutting task 3.2 below. Cross Cutting Task 3.2: Support program/s targeted to women in AML/CFT to become assessors for the global 5th round The Pacific directorate is developing a pilot scholarship program to support women from Pacific jurisdictions to become assessors on MEs. The program will launch in the next financial year. Sub-Task 3.2.1: Support for and implementation of the APG breastfeeding fund The PACD program administered the breastfeeding fund supported by a voluntary contribution received from the UK to support women in AML/CFT involved in mutual evaluations who have breastfeeding commitments. The Pacific directorate supported the preparation for the use of the fund for a woman from Fiji to attend the 2025 APG Annual Meeting with her child and a carer.

ASIA/PACIFIC GROUP ON MONEY LAUNDERING / PACD PROGRAM 28

Detailed Expenditure 2024-2025

The following section provides a summary of 2024-2025 expenditure against the costed work plan in the PACD Program Business Plan 2024-2025. There is an underspend for 2024-25 of NZD$225,062.79 1 primarily due to delays in the delivery of projects caused by limitations on several jurisdiction's capacity to receive the assistance. The underspend will be reallocated to the 2024-2025 work plan, noting several projects are ongoing.

(1 AUD = 1.09124 NZD, as of 27 July 2025) 1 (1 AUD = 1.09124 NZD, as of 27 July 2025) 2

Sub-task 1.1.1: Use Annual Meeting / TA Forum to enhance engagement with key stakeholders Sub-task 1.1.3: Provide sponsorship for Pacific members to attend the $44,364.81 APG Annual Meeting ASIA/PACIFIC GROUP ON MONEY LAUNDERING / PACD PROGRAM 29 Sub-task 1.2.1: Support Pacific members to attend and contribute to non-Task 9.3.1: Asset confiscation support and mentoring for Tonga Expenditure Sub-task 1.1.2: Support Pacific members to attend and contribute to the Task 9.3: Deliver mentoring and training for law enforcement: RPNGC Task 8.2: Deliver Annual TA Forum $5,480.00 $4,361.74 $31,924.02 $81,476.65 Activity 9. Provider of last resort (short notice/ad-hoc) capacity development assistance APG forums and workshops (PILON Oct, PFIC Nov, PILON Feb) Task 5.4: PSCF sponsorship $19,734.78 Task 9.3.2: Asset confiscation support and mentoring for Fiji $0.00 Activity (NZD)annual APG Typologies Workshop Sub-task 5.1.1: Sponsorship to PF RA Workshop $30,014.96 Task 5.7: Supervisors Forum (2024) $31,925.42 Sub-Task 9.1.1: NCBF legislation for Cook Islands $114,893.67 $0.00 $22,875.82 Priority Planning Support Sub-Task 9.4.2: Joint Money Transfer Operator (MTO) supervision $0.00 Activity 5. Directly support regional discussion/actions [See Activity 1] Activity 1. Increased Direct Engagement Activity 8. Technical Assistance Forum input

yet to be allocated travel expenses - travel expenses that have been accrued but unable to separate into individual trips at the 3time of reporting

Sub-task 11.1.1: Provide sponsorship for Pacific members to attend $18,494.46 Sub-Task 11.1.3: Support Pacific Assessors to participate in the Mutual ASIA/PACIFIC GROUP ON MONEY LAUNDERING / PACD PROGRAM 30 Task 10.1: Provide support to Pacific jurisdictions to implement the $15,990.88 Evaluations of other Pacific jurisdictions recommendations from their Mutual Evaluation Report (PNG) Sub-Task 10.2.1: Nauru SIP workshop $8,396.48 Sub-Task 10.2.2: Marshall Islands SIP workshop $13,976.83 Sub-Task 10.2.3: Timor-Leste SIP workshop $14,366.92 Sub-Task 10.2.4: PNG SIP workshop $14,189.20 Sub-Task 10.2.5: Tonga SIP workshop $2,032.01 $0.00 $5,167.75 Sub-Task 10.4.1: Tuvalu Implementation Support $0.00 $0.00 MERL Framework $0.00 Standard administrative costs $6,038.43 Domestic travel $5,693.84 Learning and development $0.00 Unallocated expenses -$4,261.46Staff Budget $802,496.90 TOTAL $1,289,634.10 Other Expenditure Activity 10. National implementation planning and coordination support Activity 11. Assessor workforce development

PACD Program Design Risks and Assumptions

A3. Acute revenue pressures remain for Pacific This had an impact on the following projects this jurisdictions with associated capacity challenges financial year: and loss of human capital- challenges for AML/CFT • Sub-Task 9.4.1: DNFBP supervision A5. Major country-level events (climate change During the reporting period, Vanuatu experienced a mentoring effects, acts of god, political developments) don't 7.3 magnitude earthquake in which 14 people died

• Sub-Task 9.4.2: Joint Money Transfer undermine member's ability to move ahead on and government services were redirected, impacting Operator (MTO) supervision AML/CFT work preparations for their upcoming ME and ability to A2. Financial crime trends and basic capacity to A4. Short-notice revenue raising schemes are This pattern of worsening situation with drug While this remains an ongoing concern in the region, receive TA. • Sub-Task 10.4.1: Tuvalu Implementation A8. Support continues from members and from the A1. Geopolitical situation in the Pacific and within This remains the case aside from a reduction in respond remain broadly consistent, noting the trafficking in the region has continued in the reporting implemented before ML/TF risk controls are in this did not have a direct impact on the PACD This remains the case aside from a reduction in A6. Pressures on Pacific members' correspondent This remains an ongoing priority concern in the Support the DAP Group remains broadly continuous with worsening situation with drug trafficking and place. Promoters of such schemes target PICs (eg A7. Pacific jurisdictions remain engaged in the DAP group for PACD programs, including the APG's funding from the United States which has impacted funding from the United States which has impacted period. program in the reporting period. Samoa will have an election called at short notice in banking relationships continues, including pressures region, and has had a direct impact on the PACD This has not changed in the reporting period. ASIA/PACIFIC GROUP ON MONEY LAUNDERING / PACD PROGRAM 31 strong and overlapping offers for AML/CFT the UNODC. The PACD program remains unaffected. organised crime, in part from 'returnee' serious Please see the individual sections for more CBI, DAO sector, etc), particularly the legislative August 2025 which has delayed the planned PACD PACD program and in APG membership agreed TA coordination role US and UNODC programs. The PACD program A9. Pacific jurisdictions and organisations recognise for debanking and derisking (categories of program in the reporting period as related projects This has not changed in the reporting period. Risk/Assumption Situation in 2024-2025 Financial Year offenders branch of government requirements the need for gender considerations in AML/CFT work information. program TA visit. remains unaffected. This has not changed in the reporting period. customers, services and products) are prioritised.

Annex A - PACD Program Design (Full)

Substantive actions to enhance risk-based AML/CFT systems by leadership and technical personnel of: Contributing Objective 2 Sub-task 1.4.1: Provide sponsorship for Pacific Task 1.4: Strategic Implementation - Pacific governments and private sectors Contributing Objective 1 Sub-task 1.1.2: Support Pacific members to Sub-task 1.2.1: Support Pacific members to Sub-task 1.2.2: Provide sponsorship for Pacific Task 1.2: Other forums and workshop Increased regional coordination to enhance risk-based AML/CFT systems by: members to attend Mutual Evaluation-related Planning workshops, Mutual Evaluation Activity 1. Increased Direct Sub-task 1.1.1: Use Annual Meeting / TA Forum Task 1.1: Specific APG-delivered events Sub-task 1.1.4: Provide sponsorship for Pacific Sub-task 1.1.3: Provide sponsorship for Pacific - regional multilaterals Increased awareness of, and demand for, support available from APG/PACD, including implementation planning, TA coordination, ASIA/PACIFIC GROUP ON MONEY LAUNDERING / PACD PROGRAM 32 attend and contribute to the annual APG attend and contribute to non-APG forums and members to attend the non-APG forums and Sub-Task 1.3.2: Diplomatic engagement in Sub-Task 1.3.3: Meetings with private sector in Activity 2. Increased Media Presence Activity 3. Expanded Supporting Goal: To support economic stability, safety and security of Pacific Islands communities by strengthened and targeted efforts Task 1.3: Meetings Task 2.1: Develop press releases and Task 3.1: Prepare layered supporting - Pacific jurisdictions Workshops (shared task with 10.3.6 below) workshops, High-Level Visits Engagement to enhance engagement with key stakeholders members to attend the Typologies Workshop members to attend the APG Annual Meeting - donors and providers and other APG services, contributing to the Overarching Objective Objectives / Activities Typologies Workshop workshops workshops relevant jurisdictions relevant jurisdictions materials Pacific Jurisdictions against financial crime Tasks Sub-Tasks engage with relevant journalists Task 2.2: Social media engagement Task 2.3: PACD Newsletter materials for all above - donors and providers

Activity 6. Integrate regional Task 6.1: Develop and update briefing Contributing Objective 3 Activity 4. Identify or create full range Activity 9. Provider of last resort Sub-Task 9.1.1: NCBF legislation for Cook Task 4.1: Develop and maintain a database Task 9.1: Legislative drafting issues/views into Contributing Task 5.2: Joint Supervision support Sub-task 5.2.1: Sponsorship of Pacific notes on each Pacific Jurisdiction's Task 8.3: Support or develop additional Increased capacity that enhances risk-based AML/CFT systems of selected stakeholders Activity 7. DAP meeting input Task 7.1: Convene Pacific-focussed DAP ASIA/PACIFIC GROUP ON MONEY LAUNDERING / PACD PROGRAM 33 (short notice/ad-hoc) capacity Islands Task 5.5: Contribute to Pacific Banking of coordination forums/working Activity 5. Directly support regional Objectives 1 & 3 activities Activity 8. Technical Assistance Task 9.3.1: Asset confiscation support and Task 9.3.2: Asset confiscation support and and calendar of AML/CFT forums and Task 5.1: Regional PF risk assessment Sub-task 5.1.1: Sponsorship to PF RA jurisdictions to conduct join supervision Task 5.3: Support emerging regional AML/CFT political priorities, as agreed to Task 8.1: Maintain up to date records of TA Sub-task 8.1.1: Pacific TA Overviews technical assistance activities as they Task 9.2: Reviews of Non-Profit Task 9.3: Deliver mentoring and training for meetings a minimum of four times per year Sub-Task 9.1.2: NCBF model legal framework groups required discussion/actions Joint Forum input development assistance mentoring for Tonga mentoring for Fiji working groups Workshop activities together discussions / actions as they emerge Task 5.4: PSCF sponsorship Forum events and programs Task 5.6: World Bank CBR project Task 5.7: Supervisors Forum with the jurisdiction needs of Pacific jurisdictions Sub-Task 8.1.2: Pacific TA Calendar Task 8.2: Deliver Annual TA Forum emerge Organisation Sector law enforcement

Activity 10. National implementation Task 10.1: Provide support to Pacific planning and coordination support jurisdictions to implement the Sub-Task 9.7.1: Provide sponsorship for FATF Sub-Task 10.2.1: Nauru SIP Sub-Task 10.4.1: Tuvalu Implementation Task 9.7: Provide assistance for other Task 10.2: Deliver Strategic Task 10.3: Provide support to Pacific Task 10.4: Provide support to Pacific Sub-Task 10.3.6: Support the delivery of Pre-Activity 11. Assessor workforce Sub-task 11.1.1: Provide sponsorship for Task 11.1: APG Assessor training ASIA/PACIFIC GROUP ON MONEY LAUNDERING / PACD PROGRAM 34 Task 9.4: Deliver mentoring and training for Sub-Task 9.4.2: Joint Money Transfer Operator Standards training Support Task 9.5: Deliver mentoring and training for Task 9.6: Deliver mentoring and training for capacity building requests on an ad-hoc recommendations from their Mutual Implementation Planning (SIP) Workshops jurisdictions to prepare for upcoming jurisdictions to coordinate their technical ME Workshops (shared task with 1.4.1 above) Pacific members to attend assessor training Sub-Task 10.3.4: Pre-ME support to Samoa Sub-Task 10.3.5: Pre-ME support to Palau (MTO) supervision Sub-Task 10.2.2: RMI SIP Sub-Task 10.2.3: Timor-Leste SIP Sub-Task 10.2.4: PNG SIP Sub-Task 10.2.5: Tonga SIP Sub-Task 10.2.6: Fiji SIP Sub-Task 10.2.7: Vanuatu SIP Sub-Task 10.2.7: Niue SIP Sub-Task 10.3.3: Pre-ME support to Niue supervisors Financial Intelligence Units relevant government policy agencies basis from Pacific jurisdictions Evaluation Report to Pacific jurisdictions Mutual Evaluations

Cross Cutting Activity 1: Scoping Cross Cutting Task 1.1: Compile research study of benefits, challenges, needs on impact of ML/FT and on the AML/CFT and risks associated with AML/CFT work on women in the Pacific, in order to Activity 12. Other focussed capacity systems/outcomes affecting Pacific better target mainstreaming activities development (addressing Cross Cutting Activity 3: Increase the Cross Cutting Task 3.1: Training program Cross-cutting Contributing Objective Cross Cutting Activity 2: All PACD Cross Cutting Task 2.1: Gender Sub-Task 2.1.1: Develop guidelines, policies, Cross Cutting Task 3.2: Support program/s Sub-Task 3.2.1: Support for and Sub-task 11.1.2: Provide mentoring support for Sub-Task 11.1.3: Support Pacific Assessors to Sub-Task 11.3.1: Assist Pacific jurisdictions to legislative/policy frameworks, bank women, and defining why an number of women from the Pacific Task 11.3: Develop additional training and Cross Cutting Task 1.2: Seek views of Cross Cutting Task 2.3: Gender targeted to women in AML/CFT to become Enhanced benefits and roles for women in relation to AML/CFT activities in the Pacific Cross Cutting Task 2.2: Collect gender- activity designs to be gender mainstream all PACD activity designs and arguments for how to ensure all PACD targeted to women in AML/CFT to become implementation of the APG breastfeeding fund ASIA/PACIFIC GROUP ON MONEY LAUNDERING / PACD PROGRAM 35 who are assessors on MEs in the women from Pacific jurisdictions on their ME assessors for the global 5th round Pacific members who will or have attended participate in the Mutual Evaluations of other develop plans to meet their assessor de-risking issues, asset recovery, enhanced role of women is important A1. Geopolitical situation in the Pacific and within the DAP Group remains broadly continuous with strong and overlapping offers A2. Financial crime trends and basic capacity to respond remain broadly consistent, noting the worsening situation with drug Task 11.2: Develop and deliver Follow Up mentor programs for Pacific assessors as mainstream jurisdiction-level APG planning disaggregated data for all PACD Activities activities are gender-mainstreamed assessors for the global 5th round global 5th round Pacific jurisdictions contribution targets etc.) to AML/CFT systems in the region for AML/CFT assistance trafficking and organised crime, in part from 'returnee' serious offenders Report (FUR) training program required experiences for Pacific jurisdictions Risk/Assumptions

ASIA/PACIFIC GROUP ON MONEY LAUNDERING / PACD PROGRAM 36 A3. Acute revenue pressures remain for Pacific jurisdictions with associated capacity challenges and loss of human capital- A4. Short-notice revenue raising schemes are implemented before ML/TF risk controls are in place. Promoters of such schemes A5. Major country-level events (climate change effects, acts of god, political developments) don't undermine member's ability to A6. Pressures on Pacific members' correspondent banking relationships continues, including pressures for debanking and A8. Support continues from members and from the DAP group for PACD programs, including the APG's agreed TA coordination

A9. Pacific jurisdictions and organisations recognise the need for gender considerations in AML/CFT work challenges for AML/CFT implementation target PICs (eg CBI, DAO sector, etc), particularly the legislative branch of government move ahead on AML/CFT work derisking (categories of customers, services and products) A7. Pacific jurisdictions remain engaged in the PACD program and in APG membership requirements role

Annex B - PACD Program MERL Framework

Objective 1 Increased awareness of, and demand for, support available from APG/PACD, including planning, TA coordination, and other APG services, contributing to the Overarching Overarching Objective OO1. Number Objective CO1.2 Number -Response type (positive, Substantive -Response type (positive, CO1.1 Number actions to enhance CO1.3 Number list) of -Media type(s) involved (if list) of media risk-based substantive applicable) list) of formally items -Media type(s) involved Retrospective MEs list) of involved Past ME Retrospective recorded mentioning (print/TV/radio/social media, media by leadership and instances in results media responses to APG/PACD etc.) monitoring, technical which systems arising Positive involved monitoring, APG/PACD support or where Media personnel of: APG/PACD involved dialogues from -Improvement type(s) (specific formal where Objectives / Indicators Indicator Indicator Baseline Indicator direct records attributable involved possible monitoring - Pacific guidance is Positive dialogues Media APG/PACD-possible Activities Valance Disaggregates Approach Source engagement AML/CFT All new governments and dialogues closely Media monitoring assisted All new +ve = more -responses issues instances private sectors replicated in the monitoring -Response topic(s) (specific AML/CFT effects) -Guidance topic(s) (specific AML instances is better may be positive, -responses recorded - regional media or activities in the recorded ASIA/PACIFIC GROUP ON MONEY LAUNDERING / PACD PROGRAM 37 -ve = less is negative or may be positive, multilaterals guidance of Pacific tag (y/n) better mixed negative or - donors and members/othertag (y/n) tag (y/n) mixed tag (y/n) providers s

1.1.1 Numbers -Gender(s) of relevant -Jurisdiction (s) -Request topic(s) (specific AML stakeholders/or-Gender-Organisation type(s) -Media type(s) involved -Jurisdiction (s) CO1.4 Number ganisations involved (mem. (print/TV/radio/social media, -Media type(s) involved directly gov./bank/DAP/etc.)-Specific 1.2.2 Number of etc.) (print/TV/radio/social media, list) of relevant -Jurisdiction (s) Activity 1. All new Event other direct etc.) requests for forums, years' Modified email -Specific SM platform(s) Increased Direct Positive Jurisdiction(s)-Position(s) -Event instances registrations/journalist involved Program 1.2.1 Number of years' workshops, Positive engagements Activity 2. inbox system involved Engagement type-Engagement topic(s) recorded minutes engagements records new media involved Program received by Positive requests 1.2.3 Number of meetings and (where Increased Media Positive and phone (specific AML areas/CFT areas)-releases years' releases records APG/PACD to involved (where APG/PACD Program related possible) Presence records Positive years' SM Heightened gender relevance 1.1.1) facilitate possible) provided 1.2.4 Number of social media records activities -posts tag (y/n) positive -Response type (nil, partial or hits to -By SM post/platform posts double counting years' data ASIA/PACIFIC GROUP ON MONEY LAUNDERING / PACD PROGRAM 38 AML/CFT full) APG/PACD Positive -Other data analytics, as Site analytics of individuals (where action social media available (platform dependent) avoided possible) tag (y/n) tag (y/n) tag (y/n) tag (y/n) posts

Objective 2Increased regional coordination to enhance risk-based by: - Pacific jurisdictions - Donors and providers

-Confliction focus/foci (specific -Coordination focus/foci -Over-burdened area(s) (specific CO2.3 Number -Duplication focus/foci (specific CO2.4 Number CO2.1 Number CO2.2 Number AML areas/CFT areas)-Past ME Past ME Past ME list) of MEsOther results MEs 1.3.1 Number results MEs list) of list) of resultsOther list) of formal APG/PACD-past formal uncoordinated assessmentsSformal list) of new or formal assisted, jointly Program unnecessary Negative assessmentsAcompeting Negative Activity 3. AML/CFT Negative Positive years' ystematic involved improved involved planned and involved records duplication in ll new 1.2.5 Number of approaches to Expanded -Supporting material topic(s) Program Position(s) (personnel involved)-All new supporting Positive years' All new implemented regional instances relevant articles Program improving risk-Supporting records overburdening dialogues Positive years' instances dialogues materials materials instances dialogues AML/CFT AML/CFT recorded released in APG records based AML/CFT materials local personnel effects)-Heightened gender ASIA/PACIFIC GROUP ON MONEY LAUNDERING / PACD PROGRAM 39 newsletters effects) recorded produced and effects) recorded regional effects) efforts newsletter systems tag (y/n) or other distributed by tag (y/n) resources APG/PACD tag (y/n) tag (y/n) tag (y/n)

CO2.5 Number CO2.6 Number list) of -Improvement focus/foci list) of other -Coordination focus/foci -Forum/group focus/foci (not activity-2.4.1 Number -Specific purpose focus/foci based) Past ME -Request topic(s) (specific AML -Forum/group title (existing or systems/outcoresults MEs areas/CFT areas)-CO2.7 Number list) of existing -Forum/group title (existing or 2.5.1 Number proposed) APG/PACD mes arising Jurisdiction(s)-Regional or potential proposed) assisted Program from formal Activity 4. Identify coordination tag (y/n)-Activity 5. Directly Positive years' Positive forums/working list) of requests Modified email list) of regional years' support Program regional involved records APG/PACD-involved or create full range All new years' support regional Positive groups Program received by APG inbox system discussions (where records assisted, All new of coordination Neutral instances Positive requests discussion/actions identified as records to facilitate and phone supported by possible) between Pacific coordinated instances dialogues forums/working recorded Specific organisation(s) (where required for regional records APG/PACD involved jurisdictions, effects) AML/CFT effects) recorded groups required involved-Position(s) (personnel possible) specific involved coordination(subetween Pacific regional involved)-Response type (nil, regional bset of CO1.4) ASIA/PACIFIC GROUP ON MONEY LAUNDERING / PACD PROGRAM 40 tag (y/n) tag (y/n) partial or full)-Heightened tag (y/n) and DAPs, and gender relevance tag (y/n) purposes tag (y/n) between DAPs OO1.)

-Capacity use focus/foci 2.5.2 Numbers 2.8.1 Number CO3.1 Number MEs of relevant -Forum/group focus/foci 2.7.1 Number -TA Activity focus/foci (specific stakeholders list) of -TA Activity focus/foci (specific list) of Past ME directly -Forum/group title list) of examples in AML areas/CFT areas)- Objective 3 results 2.6.1 Number -Gender All new examples in which DAP APG/PACD-Increased capacity supported instances Forum which a DAP years' records, Activity 8. members have years' records, supported that enhances risk-involved formal dialogues Activity 6. Integrate list) of Disaggregated regional recorded registrations has provided where Technical provided where TA forum increased Positive Positive Activity 7. DAP DAP meeting Positive based AML/CFT Follow-up regional from CO1 and discussions Past records, Forum regionally-Positive available Assistance Forum regionally-availableAll minutes capacity being All new meeting input involved minutes systems of Initial supported by involved where minutes issues/views into regional As per 'regional coordination' CO3 indicators focussed TA All new input focussed TA Position(s) (personnel involved)-new instances used to Positive instances selected -User gender(s) survey/dialogusupported APG/PACD available considerations tagged indicators using regional based on instances based on recorded implement recorded stakeholders e iterations capacity -double Objectives 1 & 3 being integrated requests made recorded requests made effects)-Heightened gender effects) ASIA/PACIFIC GROUP ON MONEY LAUNDERING / PACD PROGRAM 41 effects) counting of into Contrib. tags or discussions or discussions individuals tag (y/n) Objectives 1 & 3 held during DAP held at the TA systems tag (y/n) tag (y/n) avoided meetings Forum

-Specific capacity development -Policy focus/foci (specific AML CO3.2 Number CO3.4 Number CO3.3 Number activity/sub-activity -Capacity use focus/foci -Improvement focus/foci MEs -Capacity development type(s) MEs MEs -Official policy name list) of list) of list) of positive 3.9.1 Number of (training, mentoring, TA, etc.) -Policy approver AML/CFT Past ME organisations/s-Capacity development Past ME Past ME -Approval date APG/PACD-policies/legislatresults takeholders focus/foci (specific AML results results Participant supported ion formally successfully All new -Gender-Organisation type(s) registrations increased systems arising approved/passeformal dialogues Positive -Gender instances involved formal dialogues formal dialogues CO3.5 Number involved (mem. Positive Program from Positive involved capacity being Positive d as a result of Follow-up APG/PACD-recorded Follow-up Follow-up of Pacific-based gov./bank/DAP/etc.)-Specific records used to create APG/PACD-APG/PACD-Initial supported Initial Initial assessors involved or improve supported Activity 9. Provider Activity 10. Past ME supported survey/dialogusupported capacity -User gender(s) survey/dialogusupported survey/dialogusupported successfully Positive Jurisdiction(s)-Position(s) -ME records AML/CFT-capacity effects) of last resort (short National records drafting e iterations capacity involved e iterations capacity e iterations capacity completing Specific ME -Regional effects) related policies notice/ad-hoc) Activity 11. projects effects) Mutual coordination tag (y/n -will be y in ASIA/PACIFIC GROUP ON MONEY LAUNDERING / PACD PROGRAM 42 and legislation for strategic capacity planning and Assessor Evaluations all cases)-Heightened gender planning tag (y/n) workforce CO3.2/OO1.1) tag (y/n) tag (y/n) CO3.1) support

Cross-cutting Objective Enhanced benefits and roles for women in relation activities in the Pacific

CCO1.3 Number Follow-up Follow-up CCO1.1 Number Follow-up list) of -Experience type (positive, supported CCO1.2 Number -Challenge focus/foci (specific supported list) of supported capacity capacity -Influence focus/foci (specific capacity gender-specific -Issue focus/foci (specific AML list) of case -Challenge type (professional, positive/negativchallenges studies personal, mixed) e experiences being Targeted highlighting Targeted of Pacific Targeted addressed All new surveys/dialoghow women All new surveys/dialogwomen All new surveys/dialogthrough instances ues have influenced Positive instances ues professionally/pActivity 12. Other Positive instances ues activities that recorded Disaggregated or shaped recorded Disaggregated ersonally focussed capacity tag (y/n) involved recorded Disaggregated focus on involved from other AML/CFT involved from other affected by from other AML/CFT-indicators strategies and indicators AML/CFT (addressing indicators related crimes using policies in the using activities (either legislative/policy effects) using disproportionat'Heightened Pacific effects) 'Heightened as workers in frameworks, bank 'Heightened ely affecting effects) gender gender ASIA/PACIFIC GROUP ON MONEY LAUNDERING / PACD PROGRAM 43 these areas or de-risking issues, gender women relevance' CCO1.1) relevance' as members of asset recovery, relevance' tags tags etc.) the public) tags CCO1.1)

-Experience type1 (positive, Cross cutting Follow-up Activity 1: Scoping -Experience type2 (benefits, study of benefits, challenges, needs, risks [to be -Strategy/Policy focus/foci supported -APG/PACD activity challenges, needs refined by data]) (specific AML areas/CFT areas)-capacity name/reference CCO1.4 Number and risks -Issue focus/foci (specific AML Inclusion effect(s) on women -Issue focus/foci (specific AML CCA2.1 Number associated with (positive, negative, mixed)-participantsTaCCA1.1 list) of Pacific AML/CFT -issue type (professional, Official policy name-Policy rgeted -issue type (professional, Numbers (and (national or list) of systems/outcomes personal, mixed) approver-Approval date-All new surveys/dialogCross cutting personal, mixed) detailed lists) of Study findings Study findings regional) instances in affecting Pacific instances uesDisaggregActivity 2: All PACD All new issues Cross cutting CCA3.1 Number AML/CFT which scoping Program women, and recorded ated from activity designs to Positive instances identified Activity 3: Increase of Women strategies/policistudy findings records defining why an other be gender recorded the number of successfully es that explicitly were used to enhanced role of involved indicators women from the completing MEs Past ME include gender shape women is involved Positive ME records using involved Pacific who are as formal records considerations APG/PACD important to effects)-Regional coordination 'Heightened assessors on MEs assessors -Specific ME ASIA/PACIFIC GROUP ON MONEY LAUNDERING / PACD PROGRAM 44 tag (y/n) gender in the global 5th in the region effects) -Regional coordination tag (y/n -relevance' effects) Assumptions A1. Geopolitical situation in the Pacific and within the DAP Group remains broadly continuous with strong and overlapping A2. Financial crime trends and basic capacity to respond remain broadly consistent, noting the worsening situation with drug A3. Acute revenue pressures remain for Pacific jurisdictions with associated capacity challenges and loss of human capital- A4. Short-notice revenue raising schemes are implemented before ML/TF risk controls are in place. Promoters of such round CO3.5) will be y in all cases) (risks) tags offers for AML/CFT assistance trafficking and organised crime, in part from 'returnee' serious offenders challenges for AML/CFT implementation schemes target PICs (eg CBI, DAO sector, etc), particularly the legislative branch of government

ASIA/PACIFIC GROUP ON MONEY LAUNDERING / PACD PROGRAM 45

A5. Major country-level events (climate change effects, acts of god, political developments) don't undermine member's ability A6. Pressures on Pacific members' correspondent banking relationships continues, including pressures for debanking and A8. Support continues from members and from the DAP group for PACD programs, including the APG's agreed TA A7. Pacific jurisdictions remain engaged in the PACD program and in APG membership requirements A9. Pacific jurisdictions and organisations recognise the need for gender considerations in AML/CFT work to move ahead on AML/CFT work derisking (categories of customers, services and products) coordination role