Wolfsberg Group Response to FATF public consultation on R.16/INR.16

The Wolfsberg Group is pleased to provide feedback to the Financial Action Task Force on the proposed revisions to Recommendation 16 and its Interpretative Note. The payments industry has evolved significantly since these guidelines were first issued and we welcome the initiative to update them. We believe that ‘a payment is a payment’ and that any entity, regardless of how it is described or refers to itself, should be subject to R.16 in line with the principle of ‘same activity, same risk, same rule’. In our response we highlight the importance of future proofing the Recommendation by adopting ISO20022 terminology, of the vitally important role that operators of payment market infrastructure (PMIs) have to play because, quite simply, if mandated information cannot fit into a message, then either that PMI must build the capacity to handle the information or it should not permit activity that requires such information to use it. Our response also highlights the importance of using the right tool for the job at hand and not to try and use R.16 for controls that would be addressed more appropriately by R.10 on customer due diligence.