On April 18, 2025, the IIF submitted its response to the Financial Action Task Force's (FATF) Second Public Consultation on Recommendation 16 on Payment Transparency (Rec. 16). In its response, the IIF acknowledges that many recommendations from the first consultation have been incorporated, while highlighting several key outstanding concerns.

The IIF continues to support FATF's commitment to transparency, technology-neutrality, and the principle of 'same activity, same risk, same rules' in the evolving global payments ecosystem. The organization recognizes the critical objective of preventing criminal exploitation of payment systems while ensuring information availability to relevant authorities. The response highlights three persistent concerns: implementation costs that will be significantly higher than anticipated; the need for further reduction in required data flows to align with data minimization principles; and the risk of inconsistent implementation across jurisdictions creating technical fragmentation.

Key recommendations include harmonizing thresholds across transaction types, acknowledging both ISO 20022 and ISO 8583 standards, extending card payment exemptions to comparable non-card payment instruments, modifying cross-border cash withdrawal requirements, and maintaining flexibility in the 2030 implementation timeline. The IIF believes the revised proposal reflects a more proportionate and risk-based approach that better aligns with making cross-border payments faster, cheaper, more transparent, and more inclusive, while maintaining their safety and security. 

The IIF further encourages continued stakeholder dialogue as FATF finalizes there proposals, emphasizing the need for clarity on risks, proportionality in mitigation measures, and minimization of unintended consequences.