A risk-based approach is not necessarily an easy option, and there may be barriers to overcome
when implementing the necessary measures. Some challenges may be inherent to the use of the risk-based
approach. Others may stem from the difficulties in making the transition to a risk-based system. A number
of challenges, however, can also be seen as offering opportunities to implement a more effective system.
The challenge of implementing a risk-based approach with respect to terrorist financing is discussed in
more detail at paragraphs 41 to 45 below.