BAFT broadly supports FATF’s draft implementation Guidance for Recommendation 16 and its goal of improving payment transparency, while emphasizing that implementation should remain risk-based, proportionate, technology-neutral and globally consistent. BAFT recommends greater clarity around terminology, alignment with ISO 20022, the role of payment market infrastructures, virtual accounts, data-storage models, and the distinction between existing KYC/CDD verification and payment-message requirements. BAFT also stresses that implementation must account for differences in payment systems and institutional capabilities, particularly in lower-capacity jurisdictions, to avoid unnecessary payment rejections, overcompliance and financial exclusion. Finally, BAFT calls for a pragmatic balance between transparency, privacy and fraud prevention, including risk-based alignment checks rather than strict exact matching and flexibility for instant-payment environments.
