The consultation window is now open for the Financial Action Task Force (FATF)’s revisions to its Guidance on AML/CFT and Financial Inclusion. As discussed in previous blogs, the Guidance has a real impact on the financial inclusion of millions worldwide, and the financial inclusion community has a critical role to play in informing and shaping the Guidance. But what is it that stakeholders can do?
Stay informed
The draft revised guidance was released on February 25 on the FATF website, and will remain open for feedback until April 4, 2025. It’s essential for stakeholders to familiarize themselves with the contents of the draft, and consider the impact of the proposed changes.
1. Analyze the draft
Identify strengths and weaknesses – especially areas where the Guidance can be improved, asking questions such as:
- Does it provide sufficient guidance on appropriate indicators and factors to be used to assess money laundering and terrorist and proliferation financing risks as lower or even as low?
- Does it clarify FATF’s position on how much or how little residual risk can be tolerated when control measures are simplified?
- Does it guide regulators, supervisors and institutions to identify overly cautious compliance responses and take effective corrective actions?
- Will the Guidance help regulators and supervisors adopt effective responses to address undue de-risking (also known as de-banking)?
- What are new perspectives or guidance that you find valuable and that should not be lost in any post-consultation amendments?
2. Engage in dialogue
Engage with other stakeholders, including policymakers, regulators, technical assistance providers, financial institutions, and civil society groups. Collective engagement is key to ensuring that the revisions are well-rounded and address the needs of the financial inclusion community. It is also important to foster dialogue around potential gaps or areas where the Guidance could go further in promoting inclusion.
3. Submit feedback
FATF welcomes written comments from stakeholders. The financial inclusion community can provide thoughtful and constructive feedback grounded in practical experience, highlighting areas where the Guidance could better support inclusion initiatives. The consultation is a chance to share real-world examples of how a risk-based approach (e.g., simplified measures) has been successfully implemented in lower-risk scenarios, and to advocate for conditions that would enable its broader application in a financial inclusion context, especially in smaller economies that are still working towards higher levels of compliance with FATF standards.
Reach out to CGAP
Please don’t hesitate to contact CGAP with any questions or concerns about the revisions. CGAP has long supported FATF’s effort to better align integrity requirements with financial inclusion efforts and can provide guidance on navigating the current consultation process. Feel free to reach out to us at [email protected].
In our next blog post, we will take a closer look at the draft guidance, breaking down key changes and what they mean for financial inclusion. Stay tuned for our deep dive coming soon!
