On 26 October 2022, the Financial Action Task Force (FATF) launched a public consultation on Recommendation 25 and its interpretive note (R.25/INR.25) on the transparency and beneficial ownership of legal arrangements. The FATF is also considering amending the definition of beneficial ownership in the glossary to provide more clarity regarding legal arrangements.

The FATF’s 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. The FATF welcomes in particular comments on the following specific issues:

  1. Are FATF proposals adequate to mitigate the risk of misuse of legal arrangements and to ensure access to BO information?
  2. Are proposals clear and are there any issues which need further clarification or that should be addressed in guidance?
  3. What is the expected impact of the proposals on legitimate activity? In particular, what are the challenges for implementation?

The deadline for responses is 6 December 2022. At this stage, the FATF has not approved any draft amendments to R.25/INR.25. The FATF will consider the submissions received and proposals for revisions at its February 2023 meetings.