The EACB welcomes the opportunity to contribute to the FATF consultation on the draft Guidance on Recommendation 16.
Enhancing transparency throughout payment chains is a shared objective, and the draft Guidance provides useful clarifications on several key aspects of Recommendation 16. In particular, the introduction of the payment chain concept represents an important step forward in clarifying the respective responsibilities of the various actors involved in payment transactions.
At the same time, successful implementation will require that the future framework remains practical, proportionate and operationally feasible for financial institutions. Given the significant technological and operational developments that will be necessary to comply with the revised requirements, a gradual implementation approach beyond 2030 would help ensure a smooth and effective transition.
The contribution focuses on the following key areas:
- Supporting a gradual and proportionate implementation of Recommendation 16, recognising the significant technological and operational developments that financial institutions will need to undertake to comply with the revised requirements.
- Providing greater clarity on key concepts and definitions, including hybrid payment chains, emerging payment methods, cross-border payment transfers and the allocation of responsibilities among actors in the payment chain.
- Ensuring the practical and operational feasibility of new data-sharing models, while carefully assessing their implications for transaction monitoring, sanctions screening, data protection, operational resilience and the efficiency of real-time payment processing.
- Facilitating effective implementation of payment transparency requirements within card payment ecosystems, including through enhanced cooperation with card schemes and greater clarity regarding the role of payment facilitators, aggregators and other payment service providers.
- Addressing potential challenges arising from sanctions screening and financial crime prevention requirements, including the practical implications of de minimis thresholds and the use of alternative customer information for screening purposes.
- Promoting greater harmonisation and legal certainty across payment infrastructures, particularly regarding the identification of sponsored issuers and the consistent application of AML/CFT obligations throughout payment chains.
- Providing additional practical examples and implementation guidance to support the consistent application of Recommendation 16 across different payment methods, business models and market participants.
- Ensuring that compliance obligations remain proportionate and risk-based, while preserving the efficiency, competitiveness and smooth functioning of payment services, including instant payment solutions