The FATF is conducting a second public consultation on proposed revisions to Recommendation 16 (R.16), its Interpretive Note (INR.16), and the related Glossary of terms. The aim of these revisions is to ensure that R.16 remains fit for purpose in a rapidly evolving financial landscape, supporting more efficient, secure, and inclusive cross-border payments while preserving financial integrity.

The Global NPO Coalition on FATF has submitted feedback, raising key concerns regarding the requirements around ‘originator and beneficiary’ data fields. Many nonprofit organizations around the world operate as unincorporated associations, and imposing identifiers such as LEI/BIC/UID could result in financial exclusion. We also flagged issues with the proposed ‘address’ and ‘date of birth’ requirements, which may put vulnerable communities at risk or restrict their access to funding.

Read our submission here.