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Executive Summary
We welcome FATF’s intention to better align its Recommendations with measures to promote financial inclusion. We broadly support the suggested changes. We note however that certain issues are nuanced and need to be carefully considered.
We note that the stated purpose of the proposed changes is to address unintended consequences of AML/CFT measures. As the FATF seeks to make improvements, we suggest that care be taken to limit the potential for other unintended consequences to arise.
We are grateful to the FATF for opening the consultation. We consider that effective governance includes active industry outreach, engagement, and consultation – both before and after changes, as well as periodically. This approach ensures proportionality and supports the appropriate evolution of requirements and guidance.
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AFME general comments on FATF proposals
Identification of targeted population
We welcome and encourage the intention to promote financial inclusion. It is unclear however whether the implied excluded population is thought to be composed of natural or legal persons. Financial inclusion is a worthy goal to pursue, but the appropriate measures to take for a homeless or for an otherwise vulnerable individual will differ markedly from those taken for a small or medium sized enterprise, an NGO, or a corporate. It may be helpful for FATF to reflect on the intended population it seeks to assist, and to tailor its