On 25 October, FATF advised that it is conducting a review of Recommendation 25 and its Interpretive Note (R.25/INR.25) on the transparency and beneficial ownership (BO) of legal arrangements. FATF is also considering amendment of the definition of beneficial ownership in the glossary to provide more clarity regarding legal arrangements. The objective is to improve R.25 and its Interpretive Note to better meet its stated objective to prevent the misuse of legal arrangements for money laundering or terrorist financing. In particular, FATF would welcome comments on the following:
- Are FATF proposals adequate to mitigate the risk of misuse of legal arrangements and to ensure access to BO information?
- Are proposals clear and are there any issues which need further clarification or that should be addressed in guidance?
- What is the expected impact of the proposals on legitimate activity? In particular, what are the challenges for implementation?
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