As an organization, we are alarmed by the Financial Action Task Force’s proposed card exemption revisions in the Explanatory Memorandum and draft revisions to Recommendation 16 released on February, 26 2024. If adopted, the revisions would create a situation in which increasing compliance requirements through more stringent FATF standards would violate the FATF’s commitment to a risk-based approach.

Read the response submitted by the Consumer Choice Center below.