February 5, 2026.

Introduction

Most readers will know that the origin of this topic, like many others, related to changes in anti–money laundering, counter‑terrorist financing and counter‑proliferation regimes is found in the FATF Recommendations, also known as the “International Standards.”

The FATF Recommendations, first issued in 1990, have undergone numerous modifications. Some revisions have been broad and substantive, while others have resulted only in targeted adjustments. This is the case with Recommendation 24, “Transparency and beneficial ownership of legal persons” and its Interpretive Note, both of which were amended and adopted at the October 2024 FATF Plenary following a complex consultation process involving countries, organizations and even private‑sector stakeholders.

Recommendation 24 was revised, among other aspects, to include an obligation for countries to adopt effective measures ensuring that shareholders and directors acting as nominees are not misused for money laundering or terrorist financing purposes.