Overall, GDF GDF is broadly supportive of the aim of the proposed revisions to the FATF
Recommendation 16 (R.16) and of the FATF’s efforts to develop requirements which are both technology-neutral while also aiming to help make cross-border payments faster, cheaper, more transparent, and more inclusive. Our key points of feedback are:
1. We strongly support the elements of FATF’s proposed revisions to R.16 which seek to clarify the requirements in areas such as addresses and name screening and may, if adopted by national regulators, lower the burden on VASPs while fulfilling the Travel Rule’s aims; and
2. We support integration of the Legal Entity Identifier (LEI) into FATF’s Recommendation 16 for originator and beneficiary identification.