Overall, GDF is supportive of the aim of the proposed revisions to the FATF Recommendation 1 and its Interpretive Note, with corresponding changes to Recommendations 10 and 15 and related Glossary definitions as well as of the FATF’s intent to better align these recommendations with measure to promote financial inclusion.
Our two key points of our feedback are as follows:
1. We strongly support the replacement of the term ‘commensurate’ with the term ‘proportionate’;
2. We strongly support a risk-based approach to the application of measures for the assessment of money laundering (ML) and terrorist financing (TF).