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FATF: consultation on review of Special Recommendations

The FATF is planning a review of the 40 Recommendations. Is there a hidden agenda?

The Financial Action Task Force is to produce an interpretive note to Special Recommendation VII of the measures produced after 11 September 2001. The FATF asks for specific comment on the following:

- Scope and Definitions: Does the proposed Interpretative Note clearly define the types of transactions and entities that are covered?

- Some national systems currently permit de minimis thresholds regarding customer identification or reporting under anti-money laundering laws and regulations. Please provide any comments on whether thresholds are appropriate and if so, why and at what amounts.

World Money Laundering Report: Online asks another question. Is this a sly suggestion that cash transaction reporting should become obligatory under the FATF Recommendations at the next major review? If so, it may be prudent to await the results of the FinCEN review of the cost-benefit analysis of cash transaction reporting - or is this proposal a way of undermining the FinCEN review for internal US Treasury political purposes?

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