Adan supports VerifyVASP’s response to the public consultation on Recommendation 16 regarding payment transparency, initiated by the Financial Action Task Force (FATF)

On May 3, 2024, the public consultation launched by the Financial Action Task Force (FATF) to revise Recommendation 16 (R.16) and its Interpretation (INR.16) came to a close. In this context, Adan supports the response that VerifyVASP submitted to the FATF.

As a reminder, this initiative aims to adapt existing standards to technological innovations and changes in business models within the payments and financial services sectors. More specifically, the proposed revisions aim to enhance payment transparency while upholding the principle of technological neutrality. Furthermore, they seek to clarify the roles and responsibilities of the various participants in the payment chain and to improve the quality of information regarding payment initiators and beneficiaries. These revisions are designed to align with international messaging standards and Legal Entity Identifiers (LEIs), while incorporating enhanced transparency requirements for card transactions and refining exemption criteria to better address risks.

In our view, VerifyVASP’s response addresses several points that align with the key objectives of improving payment transparency and maintaining technological neutrality. In particular, the association supports the proposed limitation of exemptions, recognizing the importance of maintaining consistency and transparency in payments. This approach would ensure better oversight of transactions while preserving the need for exemptions in specific situations, provided that alternative transparency measures can be implemented in a technology-neutral manner. However, we also express concerns regarding the practical challenges associated with certain aspects of the proposed revision. A more nuanced approach is needed to balance data transparency with privacy protection.

All stakeholders are grateful to the FATF for giving the industry a voice through this consultation and strongly support these revisions, which enhance payment transparency while promoting financial inclusion.


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