Public Consultation on AML/CFT and Financial Inclusion - Updated FATF Guidance on AML/CFT Measures and Financial Inclusion

Paris, 25 February 2025 -

The Financial Action Task Force (FATF) is considering proposals for the update of the FATF Guidance on AML/CFT measures and financial inclusion (the updated Guidance). This is part of FATF’s programme of work to address the unintended consequences of AML/CFT measures. FATF is inviting views and comments on the updated Guidance from interested stakeholders.

The updated Guidance proposed for public consultation reflects the recently adopted amendments to the FATF Standards with increased focus on proportionality and simplified measures in the risk-based approach, updates the concept and state of financial inclusion and its relevance to financial integrity, as well as provides additional guidance and updated best practice examples of implementation of the risk-based approach in AML/CFT regime, with particular focus on simplified measures in lower risk scenarios. 

The FATF would particularly welcome views on the following issues: 

• Is the discussion on the concept of financial inclusion and its relevance to financial integrity and financial exclusion risk in Chapter 1 sufficiently comprehensive?
• Is the guidance on assessment of areas of lower risks for implementation of simplified measures in Section 2.2.3 of Chapter 2 sufficient to inform balanced risk assessments? 
• Is the explanation on recently adopted Standards revisions, for example on the concepts of proportionality, encouragement of simplified measures, tailoring measures to identified risks, etc., in Section 2.3 of Chapter 2 sufficiently comprehensive?
• Would further guidance and examples on tailoring measures to address financial inclusion needs in non-lower risk situations be required? If so, please provide relevant inputs and examples.
• Does the guidance in Section 3.2.2 and Section 3.2.3 of Chapter 3 provide sufficient clarity on the roles of supervisors and regulated entities in implementing the risk-based approach to promote financial inclusion?
• Would further guidance and examples be required on the risks associated with non-face-to-face business relationships and transactions and how to mitigate them? If so, please provide relevant examples.
• Do the examples in the boxes throughout the Guidance and the annexes provide enough details on the range of approaches to implement the risk-based approach? 

Please provide your response, including any drafting proposals FATF.Publicconsultation@fatf-gafi.org with the subject-line “Comments of [author] on the draft FATF FI Guidance”, by Friday, 4 April 2025 (18h00 CET).

While submitting your response, please indicate the name of your organisation, the nature of your activity, and your contact details. Please note that all submissions received during public consultation will be shared with FATF delegations.  At this stage, the FATF has not approved the updated Guidance and will consider the views received to revise the text.

You may insert any specific drafting proposals directly in the attached text of the draft in tracked changes. 

We will use your contact information only for the purpose of this public consultation and for further engagement with you on this issue. 

The draft text is available here.

Thank you for your input in advance.