The Financial Action Task Force (FATF) settled the treatment of net settlement in June 2025. Where a net settlement results from payments carried out on behalf of customers, information about the underlying transactions need not accompany it. The requirements of Recommendation 16 (R16) continue to apply to those underlying transactions. The first half of that proposition is easy to read as a concession. The second half is where the work sits.On 24 June 2026 the FATF published the draft guidance