The Global NPO Coalition on FATF has submitted written input following its participation in a recent consultation on the draft Guidance Paper accompanying the revised FATF Recommendation 16 and its Interpretive Note.

While recognizing the objective of strengthening transparency in cross-border payments and combating financial crime, the Coalition raises concerns about potential implementation impacts of the Standard on nonprofit organizations and the communities they serve.

The submission draws attention to key issues, including policy coherence with financial inclusion objectives, the practical implications of structured data and identification requirements, and risks related to data protection and privacy. It calls for clearer, more proportionate guidance to ensure consistent application of the risk-based approach and to avoid unintended consequences, including financial exclusion.

The full submission is available here.