On 8th December 2023, the Wolfsberg Group and the Institute of International Finance (IIF) submitted a joint response to the FATF’s public consultation on its Risk-Based Guidance on Recommendation 25 (Beneficial Ownership and Transparency of Legal Arrangements).

We believe that providing competent authorities and regulated entities with adequate, accurate (i.e. verified) and up-to-date Beneficial Ownership information is key to ensure the effectiveness of the whole system in combatting financial crime. Further, we believe that regulated entities should be able to rely on this information and that it should be available to support their financial crime risk management obligations including but not limited to customer due diligence.

We are grateful to the FATF for their continued engagement with the private sector. Our responses to the specific issues referenced in the consultation, as well as some additional points of feedback, can be read below.