On 3 May 2024, the public consultation launched by the Financial Action Task Force (FATF) to revise Recommendation 16 (R.16) and its Interpretation (INR.16) came to an end. In this context, Adan supports VerifyVASP's response to the FATF.

As a reminder, this initiative aims to adapt existing standards to technological innovations and changes in business models in the payments and financial services sectors. More specifically, the proposed revisions aim to enhance the transparency of payments while respecting the principle of technological neutrality. In addition, they seek to clarify the roles and responsibilities of the various players in the payment chain and to improve the quality of information relating to the originators and beneficiaries of payments. The revisions are designed to align with international messaging standards and Legal Entity Identifiers (LEI), while incorporating increased transparency requirements for card transactions and refining exemption criteria to better address risks.

In our view, VerifyVASP's response addresses several points that align with the main objectives of improving payment transparency and maintaining technological neutrality. In particular, the association agrees with the proposed limitation of exemptions, recognising the importance of maintaining consistency and transparency in payments. This approach would ensure better monitoring of transactions while preserving the need for exemptions in specific situations, provided that alternative transparency measures can be implemented in a technology-neutral manner. However, we also have concerns about the practical challenges associated with some aspects of the proposed revision. A more nuanced approach is needed to balance data transparency with privacy protection.

All stakeholders are grateful to the FATF for allowing the voice of the industry to be heard through this consultation and strongly support these revisions which improve payments transparency while promoting financial inclusion.