The European Banking Federation has responded to the Financial Action Task Force’s consultation on draft guidance for implementing Recommendation 16 on Payment Transparency. It supports preserving originator and beneficiary information throughout the payment chain but calls for a risk-based and proportionate approach that reflects each participant’s role and responsibilities. The federation argues that financial institutions should be able to rely on information available within their part of the payment chain and should not face requirements covering information they cannot reasonably obtain or control. It also says implementation should not add customer identification, verification or due diligence obligations beyond existing requirements and should remain flexible enough to work across different payment models and infrastructures.