FATF Gatekeepers Likely to Settle on a Modified Swiss Version of the Law

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Tuesday, July 1, 2003
Bruce Zagaris
The Financial Action Task Force on Anti-Money Laundering (FATF) is continuing to prepare its revision of the Forty Recommendations. One of the areas it will address are the gatekeeper requirements. In this regard, FATF is intending to apply due diligence requirements to the financial activities of non-financial businesses or professions. For the first time FATF has allowed the private sector to submit written and oral comments on the options paper and has engaged in a dialogue with the private sector. The obligation to report suspicious transactions will apply only to activities listed in Recommendation 13. In summary, FATF appears ready to adopt the more limited Swiss approach to the gatekeeper. However, in line with the FATF approach on many other issues it will likely expand the scope of coverage in the near future, as it perceives a need.