FATF Targeted Review on Virtual Assets: Results Due June 2027

RegReportingDesk card: FATF, Financial Action Task Force, International

On 30 October 2026 the Financial Action Task Force (FATF) launched a targeted review to accelerate how jurisdictions implement its Standards on virtual assets (VAs) and virtual asset service providers (VASPs). The FATF targeted review is aimed primarily at jurisdictions with materially important VASP activity, selected on the basis of their current assessment status. Initial results are due in June 2027, with further results in October 2027.

The decision came out of the FATF Plenary held in Paris from 28 to 30 October 2026, and its premise is that implementation of the virtual asset Standards remains uneven across the Global Network, and criminal networks keep exploiting both the cross-border nature of virtual assets and the implementation gaps between national regimes. For a crypto-asset service provider (CASP, the MiCA term that broadly corresponds to the FATF’s VASP), the review may eventually provide additional public information for existing due-diligence decisions. The FATF announcement itself introduces no new CASP filing or legal duty. Under Article 19b of Directive (EU) 2015/849, as transposed in each Member State, a CASP entering a cross-border correspondent relationship with a non-EU respondent must determine, from publicly available information, the quality of supervision over that respondent.

From June 2027 the FATF will publish findings on implementation, primarily in jurisdictions with materially important VASP activity. The findings may provide public jurisdiction-level evidence relevant to the supervision-quality assessment under Article 19b(1)(b), depending on their content. The FATF has not yet specified the structure or level of detail of the published results. June 2027 is therefore a suitable internal review checkpoint, rather than a new statutory deadline.

Related reading: our analysis of the FATF seventh targeted update and the Travel Rule enforcement gap

The FATF targeted review calendar, from declaration to results

  • April 2026: FATF Ministerial Declaration. The October Plenary describes its virtual asset decision as a response to it.
  • 16 July 2026: seventh targeted update on the implementation of Recommendation 15 (R.15), with the updated table of jurisdictions with materially important VASP activity in its Annex A.
  • 28 to 30 October 2026: FATF Plenary in Paris. Targeted review launched on 30 October.
  • June 2027: initial results of the targeted review published.
  • 10 July 2027: Regulation (EU) 2024/1624 (the AMLR) applies, Directive (EU) 2015/849 is repealed, and the deadline falls for AMLA guidelines under AMLR Articles 32 and 37(3).
  • October 2027: further results of the targeted review published.

The June and July 2027 dates have unrelated origins, but they land together. The first results arrive in the month before the AMLR starts to apply and moves the CASP correspondent rule out of the Directive and into a directly applicable regulation, with the same core measures.

What the FATF announced, and what it left undefined

The FATF’s release of 30 October keeps the mutual evaluation and follow-up processes of the Global Network as the primary mechanisms for assessing implementation and identifying recommended actions for jurisdictions. The targeted review comes on top, justified by the urgency of the risks in the VA/VASP sector. It is “primarily focused on jurisdictions with materially important VASP activity (MIVA), based on their current assessment status”. A subsequent follow-up monitoring and accelerated reporting process comes after it, and the FATF says both are intended to reinforce accountability, enhance transparency and drive timely action to help jurisdictions address identified deficiencies.

Alongside the review, the FATF will work with relevant jurisdictions through ongoing engagement, training and capacity-building, and it encourages donors and technical assistance providers to prioritise support for jurisdictions facing significant R.15 implementation challenges.

The Plenary outcomes page, published the same day, frames the decision as a response to the FATF Ministerial Declaration of April 2026 and adds two details. The review “will be based on objective criteria”, and it sits alongside accelerated follow-up processes. The illicit purposes it lists behind the decision include fraud, scams, sanctions evasion, money laundering, terrorism financing and proliferation financing.

Neither text publishes those criteria, names a jurisdiction, or explains what assessment status means in practice. The two texts also describe the target group slightly differently: “primarily focused” in the release, “will focus” on the Plenary page. Until the FATF publishes more, any list of in-scope jurisdictions is an inference.

What the review leaves untouched

The release title speaks of accelerating global implementation of the FATF Standards relating to virtual assets, and implementation is its whole subject. Recommendation 15, amended in October 2018 to bring VAs and VASPs within the FATF’s AML/CFT requirements, and its Interpretive Note, adopted in June 2019, form the core framework for implementation, alongside other FATF Recommendations applicable to VAs and VASPs. The 30 October announcement contains no amendment to either, and it does not touch the Travel Rule, which applies the payment transparency requirements of Recommendation 16 to the virtual asset context.

The FATF Standards are addressed to countries. A CASP’s obligations come from the law of the jurisdiction that authorises it. In the EU that means Regulation (EU) 2023/1114 (MiCA) for authorisation, Regulation (EU) 2023/1113 for the information accompanying crypto-asset transfers, and Directive (EU) 2015/849, replaced by the AMLR from 10 July 2027, for customer due diligence. The seventh targeted update does contain recommendations addressed to VASPs, framed as what VASPs “should” do.

The review is also separate from the FATF’s public lists. The same Plenary updated its statements on jurisdictions under increased monitoring and jurisdictions subject to a call for action, and removed Bulgaria, Côte d’Ivoire, the Democratic Republic of the Congo and Monaco from increased monitoring. Neither the release nor the Plenary page connects the targeted review to those lists. Four FATF outputs will cross a CASP compliance desk over the next year, and they do different jobs:

FATF output What it covers Timing Effect for an EU CASP
Mutual evaluation and follow-up reports Technical compliance ratings and effectiveness, including R.15 Rolling; 149 jurisdictions assessed on R.15 as of April 2026 No automatic trigger; from 10 July 2027, among the reports the Commission and AMLA take into account (AMLR Articles 29, 30 and 32)
MIVA table (Annex A of the targeted update) Self-reported R.15 steps plus assessed R.15 ratings, for FATF members and jurisdictions meeting the materiality criteria Latest update 16 July 2026 Inclusion carries no risk indication; a data source for counterparty reviews
Targeted review Implementation, primarily in MIVA jurisdictions, selected on assessment status Results June and October 2027, then follow-up monitoring and accelerated reporting None announced; results may provide information relevant to supervisory quality, depending on their content
Increased monitoring and call for action Jurisdictions with strategic AML/CFT/CPF deficiencies Latest statements 30 October 2026 Until 10 July 2027, taken into account by the Commission when identifying high-risk third countries under Article 9 of Directive (EU) 2015/849, with enhanced due diligence under its Article 18a; from that date, taken into account under AMLR Articles 29 and 30, with enhanced due diligence for identified countries

Inclusion in the materially important group is no verdict either. In Annex A to the seventh targeted update, the FATF states that neither the open-source data used to compile the table nor the blockchain analytics data used to verify it rests on any assessment of illicit finance risk or of compliance with the Standards. A jurisdiction’s inclusion therefore carries no indication, positive or negative, about its degree of risk or its level of compliance with R.15.

Inside the materially important VASP activity group

The selection method dates from the June 2023 Plenary and has two limbs: trading volume above 0.25% of global trading, and/or a large virtual asset user base, meaning the top 30 jurisdictions by VA ownership and adoption rates. The FATF published the first table in March 2024, covering all FATF members and 20 further jurisdictions with materially important VASP activity. The 2025 update added nine non-FATF jurisdictions that newly met the criteria and the 2026 update two more. The FATF puts the jurisdictions in the table at approximately 97 percent of the global VA market.

One change sits in a footnote. The user-base limb now uses a different inclusion threshold, because the open-source data on user numbers behind the earlier threshold is no longer freely accessible. The criteria are unchanged.

The table records seven implementation steps per jurisdiction, from conducting a VA/VASP risk assessment to passing the Travel Rule, followed by its R.15 rating and the year that rating was assigned. The step answers come from a self-reported survey run from February to June 2026, and the report states that survey responses have not been independently verified.

The rating column deserves a second look. The FATF notes that ratings may not reflect the current progress made by jurisdictions, and the dates make the point: Sweden and Switzerland both show LC from 2020, while Greece, Portugal and Spain show N/A because they had not yet been assessed against the revised Standards on VAs and VASPs. The rating is the date-stamped finding of an assessment; the step columns are the jurisdiction’s own account of where it stood in mid-2026.

The April 2026 baseline shows the scale of the gap. Of 149 jurisdictions assessed on R.15, one was compliant, 51 largely compliant (34%), 64 partially compliant (43%) and 33 non-compliant (22%). Only 59 of the 149 (40%) met or mostly met criterion 15.4 on licensing or registering VASPs, and 48 met or mostly met criterion 15.3 on assessing risk and applying a risk-based approach. My working assumption is that assessment status refers to where a jurisdiction stands in its mutual evaluation and follow-up cycle, the same information the rating column carries. The FATF has not said so.

The table also lists EU Member States. For an EU-licensed CASP the review can therefore reach two places at once: the third countries where its counterparties sit, and possibly its own home jurisdiction.

Where the review meets EU counterparty due diligence

Article 19b of Directive (EU) 2015/849, inserted by Article 38 of Regulation (EU) 2023/1113 and applicable through Member State implementation from 30 December 2024, covers qualifying cross-border correspondent relationships involving crypto-asset services with non-EU respondent entities providing similar services, including crypto-asset transfers. It expressly excludes providing advice on crypto-assets under Article 3(1), point (16)(h), of MiCA. From 10 July 2027, AMLR Article 37 governs these relationships, with the advice exclusion retained through the definition of crypto-asset services in AMLR Article 2(1), point (8). When entering into such a business relationship, and in addition to standard customer due diligence, Member States must require the CASP to:

  • determine whether the respondent entity is licensed or registered;
  • gather sufficient information to understand the respondent’s business and to determine, from publicly available information, its reputation and the quality of supervision;
  • assess the respondent’s AML/CFT controls;
  • obtain senior management approval before establishing the new correspondent relationship;
  • document the respective responsibilities of each party;
  • for payable-through crypto-asset accounts, be satisfied that the respondent has verified the identity of, and performs ongoing due diligence on, the customers with direct access, and can provide relevant CDD data on request.

The due diligence information must be updated on a regular basis or when new risks emerge in relation to the respondent, and Article 19b(2) has the CASP use it to determine risk-sensitive mitigating measures. Recital 60 of Regulation (EU) 2023/1113 explains why the rule exists: unregistered and unlicensed entities pose a potentially higher risk, which is “especially relevant as long as the implementation of the FATF standards relating to crypto-assets at global level remains uneven”. The FATF’s 30 October release opens with the same diagnosis.

Article 19b(3) mandated EBA guidelines on the criteria for this assessment, including the minimum action where the respondent is not registered or licensed. The EBA’s amending Guidelines on ML/TF risk factors (EBA/GL/2024/01), published on 16 January 2024 and applicable from 30 December 2024, extend those guidelines to CASPs and cite Article 19b as part of their legal basis.

From 10 July 2027, Article 37 of the AMLR carries the same six measures, the same update trigger and the same risk-sensitive mitigation into a directly applicable regulation, and Article 77 of Directive (EU) 2024/1640 repeals Directive (EU) 2015/849 from that date. Article 37(3) gives AMLA until 10 July 2027 to issue guidelines on the assessment criteria and the minimum action where a respondent is not registered or licensed. The broader EU timeline is in our guide to the EU AML package and the 10 July 2027 countdown.

One limb is easy to over-read. A jurisdiction-level finding can inform the second limb, the quality of supervision. The first limb, whether a particular respondent holds a licence or registration, turns on a fact about that entity, established from entity-level evidence such as the competent authority’s public register, where one is available.

A strong result for its home jurisdiction proves nothing about an unlicensed operator based there, and a weak result does not disqualify a licensed one. Article 19b(2) asks for measures calibrated to the respondent, with the jurisdiction as one input.

Publication of a targeted review result can justify reassessing a respondent’s supervisory environment. The specific Article 19b update trigger relating to new risks is engaged when new risks emerge in relation to the respondent; publication alone, particularly of favourable or unchanged findings, does not establish that condition. Scheduling a review after each FATF publication remains a prudent internal control rather than an express statutory deadline.

Reading the MIVA table against a counterparty file

The July 2026 table can be put to work before any review result exists. The mapping below is my own reading; the FATF does not link its columns to EU law, and each step answer is self-reported.

MIVA table column Counterparty question it informs
Legislation requiring VASPs to be registered or licensed and apply AML/CFT measures Can the respondent’s licence or registration be verified at all (Article 19b(1)(a))?
Supervisory inspection conducted, or VASPs in the current inspection plan What does public information show about the quality of supervision (Article 19b(1)(b))?
Enforcement or other supervisory action taken against VASPs Same limb: is supervision exercised in practice?
Travel Rule passed or enacted for VASPs Does the counterparty’s own regime require it to obtain, hold and transmit originator and beneficiary information?
Stablecoin issuers required to be registered or licensed when they qualify as VASPs Relevant where stablecoin flows dominate the relationship
R.15 rating and date of assessment When was the independent R.15 assessment performed, and how should its age be considered alongside the separate, unverified 2026 survey responses?

Jurisdictions that prohibit VAs and VASPs show N/A in the licensing, stablecoin, inspection, enforcement and Travel Rule columns, because the FATF treats those steps as not relevant to a prohibition regime. N/A records the prohibition. It says nothing about whether the prohibition is enforced, and the seventh targeted update warns that prohibition frameworks, while allowed by the Standards, can represent significant risks to the VASP and global financial system if not enforced effectively.

Offshore VASPs: the exposure that sits in the retail book

The seventh targeted update defines offshore VASPs (oVASPs) as VASPs that provide services to clients in jurisdictions outside their jurisdiction of incorporation or physical location. Where an oVASP is incorporated or physically located in a jurisdiction with weak or underdeveloped AML/CFT/CPF regulatory and supervisory frameworks, the FATF says this can increase the risk of abuse in its home jurisdiction and in the host jurisdictions where it offers products and services.

The report then describes a pattern that lands on licensed VASPs and financial institutions. oVASPs reach trading, liquidity and fiat on- and off-ramps through accounts held at licensed onshore VASPs or financial institutions. Nested activity can be legitimate, but the FATF reports oVASPs deliberately misrepresenting themselves as retail users when opening such accounts, then processing illicit transactions significantly exceeding typical retail volumes while accounting for only a marginal share of the host VASP’s total activity.

That pattern defeats a control design built around declared counterparties. Article 19b applies where a CASP establishes a qualifying correspondent relationship with a non-EU respondent providing similar crypto-asset services. An oVASP misrepresenting itself as a retail customer may bypass correspondent-relationship controls at initial onboarding. If monitoring subsequently identifies the true nature of its activities, the CASP should reassess the relationship, including whether Article 19b applies, and implement appropriate AML/CFT measures.

The FATF recommends that VASPs conduct enhanced due diligence of oVASPs, detect accounts used by oVASPs misrepresenting themselves as retail users, restrict or exit higher-risk relationships, and monitor relevant fiat on- and off-ramp activity. Separately, from 10 July 2027, AMLR Article 39(2) requires EU CASPs to ensure that their accounts are not used by shell institutions to provide crypto-asset services and to maintain internal policies, procedures and controls to detect attempts to use their accounts for unregulated crypto-asset services.

Host-jurisdiction licensing covers only part of the problem. Of 114 jurisdictions with VASP licensing or registration requirements, 50 (44%) reported requiring licensing or registration where a VASP is created or located in the jurisdiction, and 39 (34%) reported a more extensive approach that also requires certain offshore VASPs to be licensed or registered if they meet other requirements. The update summarises the measures jurisdictions have adopted, from activity-based licensing anchored on targeted marketing, onboarding of residents and use of domestic payment rails, to app-store takedowns and restrictions on access to domestic financial intermediaries, and refers to the FATF’s March 2026 report on offshore VASPs for detail. Stablecoin misuse and peer-to-peer transfers through unhosted wallets sit on the same risk list; our coverage of the FATF stablecoins and unhosted wallets report sets out that strand.

Country risk scoring once results are published

From 10 July 2027 the AMLR gives country risk an EU-level reference point. Article 32 requires AMLA to issue guidelines by that date on the money laundering and terrorist financing risks, trends and methods involving geographical areas outside the Union, to take into account evaluations, assessments or reports of international organisations and standard setters when doing so, and to review the guidelines at least every two years. Article 34(3) then requires obliged entities assessing the risks of a business relationship or occasional transaction, outside the cases covered by Section 2 of that Chapter on third-country policies, to take into account at least the Annex III factors of potential higher risk and those AMLA guidelines. A published FATF targeted review result is a standard setter’s report; whether and how AMLA draws on it is for AMLA to decide.

The FATF’s own suggestion on country risk is addressed to jurisdictions. Citing its 2021 Updated Guidance on a risk-based approach for VAs and VASPs, the seventh targeted update says jurisdictions should consider the risks of VA transfers with jurisdictions that have taken no steps towards regulating or banning VASPs and, subject to their own ML/TF/PF risk assessment, may consider designating all VASPs from jurisdictions that do not effectively implement licensing or registration requirements as higher-risk.

A blanket uplift for every jurisdiction in the MIVA table would wrongly treat table membership as a risk indicator. Annex A includes FATF members as well as non-member jurisdictions selected using material VASP activity criteria; the FATF explicitly states that inclusion does not indicate a jurisdiction’s level of risk or compliance. The defensible inputs are the findings: ratings with their dates, the survey answers, and from June 2027 the review results, each held in the model as dated evidence with a source reference and kept apart from entity-level facts such as a respondent’s licence. Whether the FATF will publish its results jurisdiction by jurisdiction or in aggregate is not stated in either text.

For VASPs licensed in a jurisdiction under review

The review addresses governments and supervisors. A VASP feels it through its own authority’s response, whether that takes the form of legislation, licensing decisions, inspections or enforcement. The seventh targeted update tells jurisdictions that have already taken steps to implement R.15 to prioritise practical supervisory activity, and its public-sector recommendations include off-site and on-site inspections with feedback on the effectiveness of AML/CFT/CPF compliance frameworks, including the Travel Rule, and effective measures to identify and sanction persons that conduct VASP activity without the required licence or registration. Those recommendations predate the review and describe what the FATF considers effective implementation. They do not forecast what any particular authority will do.

On decentralised finance the July 2026 numbers are small. Among 142 responding jurisdictions, only four had imposed licensing or registration requirements on DeFi arrangements and two had actually licensed or registered such arrangements in practice. Our analysis of the FATF DeFi report on control covers when an arrangement falls within the Standards.

Frequently Asked Questions

Does the targeted review cover EU Member States?

Neither FATF text names a jurisdiction. Six EU Member States that are not FATF members, namely Cyprus, the Czech Republic, Estonia, Lithuania, Malta and Poland, appear in the July 2026 MIVA table, which places them in the materially important group by the FATF’s own criteria. The release adds a second filter, current assessment status, which the FATF has not defined publicly. Whether FATF members such as France or Germany fall within the review’s primary focus is not stated.

A counterparty’s home jurisdiction is in the MIVA table. Does that trigger enhanced due diligence?

Inclusion by itself triggers nothing. Where the relationship is a qualifying correspondent relationship with a non-EU respondent, the Article 19b measures apply because of the type of relationship, whichever jurisdiction the respondent is based in. Until 10 July 2027, Directive (EU) 2015/849, as transposed, requires enhanced due diligence for business relationships or transactions involving high-risk third countries identified by the Commission, and in other cases of higher risk identified by Member States or obliged entities. From that date, Commission identification of third countries can trigger prescribed enhanced due diligence under AMLR Articles 29, 30 and 31, and Article 34(1) requires enhanced due diligence in other cases of higher risk identified by obliged entities through their own assessment. Under both regimes a country need not appear on a Commission list for its geographical risk factors to contribute to a higher-risk relationship requiring enhanced measures.

A prospective counterparty says it operates from a jurisdiction that explicitly prohibits VASPs. What does the table add?

It records the jurisdiction’s self-reported prohibition rather than independently verifying the current legal position. Under the FATF table convention, the licensing, inspection, enforcement and Travel Rule columns are marked N/A for jurisdictions reporting a prohibition. The FATF’s own picture of enforcement is mixed: in the 2026 survey, 16 of 21 jurisdictions explicitly prohibiting VAs and VASPs reported taking supervisory or enforcement action against VASPs operating illegally, against 9 of 17 in the 2025 update, while the report’s key findings say jurisdictions taking a prohibition approach have not progressed in taking such action.

A prohibition recorded in the FATF table does not, by itself, establish an individual respondent’s licensing or registration status. Under Article 19b(1)(a), the CASP must determine whether the respondent is licensed or registered. To support that determination, it should identify the relevant jurisdictions and licensing requirements and verify any claimed licence or registration against the competent authority’s public register or other reliable official evidence, where available. Those entity-level findings, rather than the FATF table entry alone, determine the Article 19b(1)(a) assessment. The minimum action for unregistered or unlicensed respondents is the subject of the Article 19b(3) mandate and, from 10 July 2027, of AMLA’s Article 37(3) guidelines.

If the June 2027 results are favourable for a counterparty’s jurisdiction, can the firm relax its measures?

The Article 19b measures apply to qualifying cross-border correspondent relationships involving crypto-asset services with a non-EU respondent providing similar services, subject to the exclusion for providing advice on crypto-assets. They do not apply automatically to every relationship with a non-EU counterparty. Where the relationship falls within scope, a favourable jurisdictional assessment does not remove the prescribed due diligence measures. What can move is the calibration under Article 19b(2): a better supervisory picture is a legitimate input to the risk-sensitive measures, provided the file records the result, its date and why it changed the assessment. Entity-level facts, such as the respondent’s licence and its own AML/CFT controls, still need their own evidence.

Does the review require changes to Travel Rule messaging?

In the EU, the originator and beneficiary information that must accompany transfers of crypto-assets comes from Regulation (EU) 2023/1113, which has applied since 30 December 2024. The review concerns how jurisdictions implement and supervise the rule, and the 30 October announcement leaves that data set as it is.

Who chooses the jurisdictions, and can the private sector feed in?

The FATF selects them on objective criteria it has not published. Neither text describes a private-sector input route for the review. The seventh targeted update, a separate exercise, drew on consultations with private sector stakeholders and on data from blockchain analytics firms used for verification.

Key Takeaways

  • June 2027 and October 2027: targeted review results publish. Set a fixed internal window after each publication for refreshing the files of counterparties based in the jurisdictions covered.
  • Now: pull the July 2026 MIVA table row and the R.15 rating year for every jurisdiction where the firm holds a non-EU VASP relationship.
  • Each file for a qualifying correspondent relationship under Article 19b should keep two separate evidence fields: entity licence or registration (Article 19b(1)(a)) and jurisdiction supervision quality (Article 19b(1)(b)), with a date and source recorded against the second.
  • Country risk models: add review results from June 2027 as dated evidence with source and publication date; MIVA membership alone is no scoring input.
  • Retail onboarding and monitoring: include an oVASP nesting scenario, meaning accounts opened as retail users that process volumes significantly exceeding typical retail activity.
  • By 10 July 2027: AMLA’s Article 32 guidelines on third-country risk and Article 37(3) guidelines on CASP correspondent relationships are due; procedures citing Article 19b need re-referencing to AMLR Article 37 from that date.

Sources and References

  • FATF, Launch of targeted review process to accelerate global implementation of FATF Standards relating to virtual assets (30 October 2026): FATF press release
  • FATF, Outcomes FATF Plenary October 2026 (30 October 2026): FATF Plenary outcomes
  • FATF, Seventh Targeted Update on Implementation of the FATF Standards on Virtual Assets/VASPs (16 July 2026), including Annex A, the MIVA table: FATF publication page; full report PDF as republished by FIAU Malta: PDF
  • FATF, Understanding and Mitigating the Risks of Offshore Virtual Asset Service Providers (March 2026): FATF publication page
  • FATF, The FATF Recommendations (Recommendation 15 and its Interpretive Note; Recommendation 16): FATF Recommendations
  • FATF, Updated Guidance for a Risk-Based Approach to Virtual Assets and Virtual Asset Service Providers (October 2021): FATF guidance
  • Regulation (EU) 2023/1113 on information accompanying transfers of funds and certain crypto-assets, including recital 60 and Article 38 inserting Article 19b into Directive (EU) 2015/849: EUR-Lex
  • Directive (EU) 2015/849 (fourth AML Directive), Articles 9, 18, 18a and 19b: EUR-Lex
  • Directive (EU) 2018/843, Article 1, points (5), (10) and (11), amending Articles 9 and 18 of Directive (EU) 2015/849 and inserting its Article 18a: EUR-Lex
  • Regulation (EU) 2024/1624 (AMLR), Articles 2, 29, 30, 31, 32, 34, 37, 39 and 90: EUR-Lex
  • Directive (EU) 2024/1640 (AMLD6), Article 77: EUR-Lex
  • Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA): EUR-Lex
  • EBA, EBA issues guidance to crypto-asset service providers to effectively manage their exposure to ML/TF risks (16 January 2024), EBA/GL/2024/01: EBA press release

Before the first targeted review results in June 2027

June 2027 sits close enough to 10 July 2027 that the first review results and the move from Article 19b to AMLR Article 37 will reach the same procedures within weeks of each other. The preparation that pays off is mapping which non-EU VASP relationships depend on which jurisdictions, and which evidence in each file covers the entity and which covers its supervisor. The decision to take this quarter is who reviews each affected relationship file when the FATF publishes, written into the counterparty due diligence procedure as a named trigger.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.

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