Global Digital Finance (GDF) submitted a response to the Financial Action Task Force’s (FATF) public consultation on its draft Guidance supporting the implementation of the strengthened Recommendation 16 (R.16) on Payment Transparency.
GDF supports FATF’s objective of increasing payment transparency and combating money laundering, terrorist financing and fraud, while emphasising the importance of a technology-neutral and proportionate approach that can accommodate evolving payment architectures.
The response focuses on the application of the Guidance to virtual assets, virtual asset service providers (VASPs), stablecoins and hybrid payment models. Key recommendations include greater clarity on responsibilities across fiat-to-stablecoin payment chains, recognition of interoperable data standards such as IVMS 101, proportionate treatment of digital and hybrid wallets, and recognition of blockchain analytics and privacy-preserving technologies within Travel Rule compliance. GDF also calls for greater international convergence on Travel Rule requirements and stronger coordination between AML/CFT and data-protection frameworks.
Overall, GDF supports an implementation framework that delivers consistent payment-transparency and financial-crime outcomes across traditional, virtual-asset and hybrid payment systems while allowing the underlying technology and infrastructure to continue to evolve.
Submitted:
21/08/2026