Notabene Responds to Draft Guidance on Implementation of FATF Recommendation 16

On 21 August 2026, Notabene submitted its response to Guidance to Support Strengthened FATF Recommendation 16, the Financial Action Task Force's public consultation on how the Travel Rule should work under the revised standard.

Our submission makes six recommendations, starting with the one that affects the most customers: FATF should state plainly that due diligence on a counterparty means checking the company you're transacting with — not running full KYC on its entire customer base.