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Welcome to EQUITY ISSUES, a short note on a relevant issue in the private equity and venture capital industry.

If you would like to discuss any of the points we raise below, please contact me or one of our other lawyers.  


Claire Cummings

020 7585 1406



FATF’s 2018 private sector consultative forum: FinTech and RegTech aspects

The Financial Action Task Force (FATF) recently published a press release providing a summary of issues discussed at its private sector consultative forum, held in Vienna on 23 and 24 April 2018.  The forum is designed to give private sector representatives the opportunity to engage directly with the FATF and its members on anti-money laundering (AML) and counter-terrorist financing (CTF) issues.  Two topics discussed as part of FATF’s ongoing FinTech/RegTech work are digital identification and crypto assets.

Participants met to discuss the private sector’s experience of using digital IDs to identify and verify their customers as part of the on-boarding process. Similarly, public and private sector representatives also met to discuss the regulatory landscape for crypto assets, and the extent to which the current FATF standards and guidance adequately address the recent developments in this area.

On digital identification, participants discussed the private sector’s experience of using digital IDs for the purpose of customer due diligence as part of the on-boarding process. General benefits of digital IDs were highlighted as well as the different challenges met (e.g. technology/security/risk management/data use). The discussion focused on the application of the FATF recommendations in a digital ID context, and sought to identify any potential need for clarification and/or change in the FATF recommendations to support the growing use of digital IDs for the conduct of the customer due diligence process by reporting entities.  

Regarding crypto assets, public and private sector participants discussed the regulatory landscape for crypto assets, and the extent to which the current FATF standards and guidance adequately address the recent developments in this area. In light of the diverse nature of the crypto landscape, participants noted the importance of clarifying the different definitions used, the need for a co-ordinated global approach, and the importance of the private and public sector continuing to engage on these issues.


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Tel: + 44 20 7585 1406
Mob: + 44 7734 057 327

Cummings Law
42 Brook Street
London Greater London W1K 5DB
United Kingdom

20 02 2019


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