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In that year, in Moscow, a ministerial conference of the Group of Eight (G-8) countries on combating transnational organized crime stated that the ministers had “agreed to consider putting certain responsibilities, as appropriate, on those professionals, such as lawyers, accountants, company formation agents, auditors, and other financial intermediaries who can either block or facilitate the entry of organized crime money into the financial system.”45 The 2003 revisions to the Forty Recommendations of the FATF implement the G8’s “Gatekeeper” initiative by extending basic AML/CFT prevention requirements, including the reporting requirements, with some qualifications, to a list of “designated non-financial businesses and professions” that includes casinos; real estate agents; dealers in precious metals and precious stones; lawyers, notaries, and other independent professionals and accountants in certain defined circumstances; and trust and company service providers.
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