Though the title of the publication suggests a limited scope, the FATF-publication on Cross-Border Payments [*] shows the general inadequacy of the AML/CFT legislation as adopted by FATF. The only subject that is typical for cross-border payments, is the correspondent banking relationships. The failures include amongst others:

• Unnecessary double work.
• Problems caused by different legal systems in countries.
• Different requirements on identification and verification of customers and beneficial owners.
• Different definitions of ‘beneficial owner’.
• Inconsistent supervisory approaches across jurisdictions.
• Over compliance by financial institutions in fear of sanctions by the authorities.
• High costs.

In the report nothing is to be found on the effectivity of the measures.

FATF has created a bureaucratic monster that is not certain to help fight crime.

Quote from the conclusion

[*] Announcement, report (pdf).