The June 2025 FATF Plenary concluded with several developments of significance to civil society and financial inclusion efforts. Highlights include:

New Procedures to Address Unintended Consequences (UIC)
The FATF adopted new procedures aimed at preventing Unintended Consequences during follow-up processes, including the ICRG (grey-list) process. This marks progress on a long-standing ask of the Global NPO Coalition on FATF, as much of the empirically documented NPO suppression occurs during these stages.

Following the Coalition’s regular post-plenary engagement with the FATF Secretariat, it was confirmed that a UIC trigger mechanism has been introduced into FATF procedures. The mechanism can be triggered for FATF members by two parties: one FATF member and either another FATF member, an FSRB member, the IMF, or the World Bank. The procedure applies to all FATF and FSRB members unless an FSRB opts to develop its own process. UIC reports must fall within the scope of the FATF Standards as they relate to NPOs (not limited to Recommendation 8).

While the Coalition appreciates this step and acknowledges that discussions at the Plenary were contentious, it is disappointed by the limited scope of the trigger mechanism. It does not include all FATF Observers or any independent voices such as UN Special Rapporteurs, nor does it allow for direct civil society submissions. Furthermore, the procedures were not opened to public consultation, which the Coalition considers a missed opportunity.

Financial Inclusion and De-risking
FATF adopted updated guidance supporting simplified measures in low-risk cases, aligned with the 2025 revisions to Recommendation 1 and its Interpretive Note, as well as consequential changes to Interpretive Notes 10 and 15. The guidance reflects an expanded understanding of financial inclusion, encompassing not only access, but also appropriate usage and financial literacy (para 15).

It states that “financial exclusion represents a real risk to achieving effective implementation of the FATF Standards” (para 1) and highlights that the FATF has long 'identified financial exclusion as an important money laundering (ML)/terrorist financing (TF) risk' (para 3). The guidance further emphasizes the ‘importance of financial exclusion for understanding a country’s risk and context and the impact that disproportionate implementation of the FATF Standards can have on an effective AML/CFT regime. The 2025 revision of the FATF Standards require countries to allow and encourage simplified measures in assessed lower risk scenarios…’ (para 13).

On de-risking, the guidance clearly states that:
“Wholesale de-risking is contrary to the RBA and contributes to broader financial exclusion… Different regulatory, supervisory, and policy responses may be required to correct de-risking” (para 14).

A new national risk assessment toolkit and revisions to the assessment methodology aim to strengthen the risk-based approach.

Cross-Border Payments
Changes to Recommendation 16 were approved to improve the transparency and efficiency of cross-border payments. FATF noted its continued engagement with civil society in this area to help align reforms with privacy and inclusion objectives.