GDF Response to FATF Public Consultation on Proposed Revisions to R.16/INR.16
Overall GDF is supportive of the aim of the proposed revisions to the FATF Recommendation 16 (R.16) and of the FATF’s intent of developing requirements which are both technology-neutral while also aiming to help make cross-border payments faster, cheaper, more transparent, and more inclusive. Our aim in the response is to concisely summarise our feedback as presented in the recent FATF meetings. Given the nature and scope of GDF’s work, our response focuses specifically on Question 15 and how R.16 revision applies to Virtual Assets (VA). The six key points of our feedback are as follows:
Key Points of Feedback
1. Guidance needed on if purchase of VA would qualify as ‘cash or cash equivalent’;
2. Support for Option 1 (the Instruction Route) in payment chain identification as well as further guidance;
3. Recommended addition of IVMS101 where examples of market standards are highlighted within the guidance;
4. The VA industry is leading in mandatory beneficial name alignment and this type of compliance innovation can support best enhanced practice across the broader financial services industry;
5. Support for Option 1 in alignment of originator and beneficiary information given that appropriate data privacy standards are being maintained; and
6. Encouragement for a collaborative effort between the FATF and the Global Privacy Assembly (GPA) to address data privacy and R.16 VA, providing clarity to market participants.
