Comments on the Draft FATF Guidance on Recommendation 16 (Payment Transparency)

These comments respond to the FATF public consultation on the draft Guidance for Recommendation 16 (Payment Transparency), opened in June 2026. They address four questions of the Explanatory Memorandum: Question 3 (data-storage models, Chapter 4), Question 11 (coverage of payment methods, Chapter 8), Question 12 (data protection and privacy, Chapter 9) and Question 7 (virtual account numbers, Section 5.5). The submission examines an architecture rather than a jurisdiction: payment and value-transfer systems organised around a regulated registry operator, in which participants are identified once at onboarding, every transfer is recorded in a single ledger, and full originator and beneficiary information is held by the operator rather than transmitted within each payment message. The evidence base is a complete capture of all publicly disclosed placements in one such market since 2022 (4,323 tokenised issues), combined with a parallel dataset of 8,525 conventional corporate bond issues, published information-system rules of a licensed operator, and 17 issuance decisions. Reported findings include the near-absence of secondary circulation (96.3% of Q1 2026 turnover is primary placement), a median term to maturity of 126 days, and the absence of a measurable price penalty for the closed identified circuit at placement (989 matched pairs across 43 issuers; median premium 0.00 percentage points). The core proposal is to recognise storage-based models through a functional test (availability, verification, retrievability and control at the level where the information is held) rather than a message-format test, subject to five conditions including independent oversight and a data-protection framework. Companion proposals cover graduated, perimeter-based application of requirements in registry-operator systems, recognition of selective-disclosure identity technology, and by-design answers to the virtual-account-number risk. An annex presents proposed drafting insertions in the context of the relevant chapters of the draft Guidance. Limitations of the evidence are set out explicitly. Submitted in a personal academic capacity.