Overall, GDF is supportive of objectives and aims set out in the FATF’s Public Consultation on AML/CFT and Financial Inclusion – Updated FATF Guidance on AML/CFT Measures and
Financial Inclusion. Our key points of feedback are:
1. We remain supportive of the ‘proportionality’ wording which particularly crucial as it relates to VASPs, as well as the broader financial services ecosystem; and
2. We remain supportive of a risk-based approach from the FATF that enables both VASPs and financial institutions to implement appropriate compliance measures that are aligned to their risk profile while also being practical and efficient.