This document presents OpusDatum’s formal response to the Financial Action Task Force’s (FATF) second public consultation on proposed revisions to Recommendation 16 (R.16) and its Interpretive Note, submitted on 14 April 2025.

As a financial crime compliance advisory firm, OpusDatum welcomes the FATF’s efforts to modernise R.16 in light of evolving payment technologies. The response supports key elements of the proposed revisions such as harmonised data requirements, flexible fraud prevention mechanisms, and proportional sanctions screening and offers practical implementation feedback grounded in client advisory experience.

Notably, the submission raises two critical issues for further consideration:

1. The lack of a voluntary self-reporting mechanism for wire transfer compliance breaches.

2. The opaque governance of internal risk assessments conducted by payment service providers.

Additional commentary is provided on data field definitions, RFI process standardisation, digital wallet regulation, and implementation timelines.

The full version of our response is available for download below and includes detailed analysis and recommendations.