Berlin 6.0
The Berlin 6.0 DARTE session took place on June 15th, 2026, in collaboration with the European Commission, Bitvavo, and N26. This edition departed from the usual structure of DARTE sessions, inviting participants to question the FATF framework itself rather than confining the discussion to how the industry should operate within it. The roundtable examined the current revision of the FATF Recommendations and what a more proportionate, effective, and rights-respecting alternative might look like.
Three themes anchored the discussion. Nadine Kari (N26) opened with an examination of Recommendations 10, 15, and 20 on customer due diligence, new technologies, and suspicious transaction reporting, exploring how data fragmentation, AI governance, and the absence of FIU feedback shape the operational reality of the current regime. Zornitsa Daskalova (Zodia) followed with a proposal to repurpose Recommendation 16 from the bulk transmission of identity data into participation in qualifying intelligence-sharing networks anchored in rule-of-law safeguards. Dr. Agata Ferreira (Status) closed the technical sessions with a proposal to revise Recommendation 33 and introduce two new Recommendations, 41 on independent evidence-based evaluation and 42 on fundamental rights safeguards, addressing the absence of any mechanism to evaluate whether the regime achieves what it sets out to achieve.
A theme that ran through all three discussions, and one that BlackVogel has been raising across global forums in recent weeks, is the distinction between measuring how effectively institutions comply with the standards and asking whether the standards themselves achieve what they were built to do.
FATF Recommendations 10, 15, and 20: Customer Due Diligence, New Technologies, and Suspicious Transaction Reporting
Call to Actions
The first session examined three FATF Recommendations that together define the operational core of the AML compliance regime: Recommendation 10 on customer due diligence, Recommendation 15 on new technologies, and Recommendation 20 on suspicious transaction reporting. Participants discussed the structural fragmentation of CDD data across siloed systems, the deployment of ML and AI in fraud and AML without the formal risk assessment the framework implies, and the volume of low-value alerts generated under current STR regimes against the absence of structured feedback from FIUs. The discussion also surfaced significant disagreement on whether the right response is more data sharing, suspicion sharing with rule-of-law safeguards, or a shift toward proof-based architectures using verifiable credentials and zero-knowledge infrastructure, alongside a foundational concern that the framework's design predates the technological environment it now operates in and that adding complexity may compound rather than resolve its dysfunction.
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Recognize external KYC as a basis for lifting the €1,000 SHW restriction, allowing CASPs to verify third-party counterparties via eID, remote ID verification, or digital identity wallet checks, and replacing an ineffectual blanket prohibition with a proportionate, evidence-based control.
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Establish a whitelist of DORA-compliant Travel Rule service providers maintained at industry or regulatory level, bringing transparency to compliance posture, supporting interoperability, and reducing exposure to non-EU data access risks.
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Extend the Travel Rule standard to include beneficiary identification fields necessary for conclusive AML and EDD checks and a payment explanation field for B2B use cases, designed with explicit data minimisation and privacy safeguards.
Repurposing Recommendation 16: From Bulk Data Transmission to Intelligence Sharing
Call to Actions
The second session proposed a fundamental rethinking of FATF Recommendation 16, the Travel Rule, arguing that the obligation should be repurposed from the bulk transmission of personal identity data to participation in a qualifying, vendor-neutral intelligence-sharing network in which financial institutions, VASPs, FIUs, and law enforcement are full participants. Participants discussed the cost-benefit failure of the current regime, where USD 206 billion in annual compliance spend coincides with confiscation of only around 1% of EU criminal proceeds, the privacy and fraud cost of mandatory bulk transmission of identity data to honeypot repositories, and the structural problems with peer-to-peer data exchange between obliged entities in a global framework that includes jurisdictions where rule-of-law protections cannot be assumed. The discussion also surfaced strong support for moving from data transmission to proof sharing through verifiable credentials and zero-knowledge infrastructure, and broad consensus that the role of financial institutions should be reframed as enablers of law enforcement rather than as private agents of crime prevention.
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Repurpose Recommendation 16 from bulk data transmission to qualifying intelligence-sharing networks, with FATF supplying the legal standard on vendor neutrality, interoperability, participant vetting, and governance, building on models such as Singapore's COSMIC, the EU's TRACE project, and Article 75 of the EU AML Regulation.
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Anchor any sharing architecture in rule-of-law safeguards including a defined suspicion threshold, pseudonymisation, data-protection impact assessment, independent audit, and a redress mechanism that gives the data subject the right to be informed, to challenge, and to have a flag removed across the network where upheld.
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Move from data transmission to proof sharing through verifiable credentials and zero-knowledge infrastructure, allowing institutions to verify what they need to verify without transmitting personal data or creating new honeypots.
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Reframe the role of financial institutions as enablers of law enforcement, not as private agents of crime prevention, with redirected compliance spend or membership contributions strengthening FIU and law enforcement capability, while preserving targeted financial sanctions under Recommendations 6 and 7.
FATF Recommendations 33, 41, and 42: Statistics, Evidence Standards, and Fundamental Rights Safeguards
Call to Actions
The third session addressed a structural blind spot at the heart of the FATF framework: the absence of any mechanism to evaluate whether the regime achieves what it sets out to achieve. The proposal advanced a shift from a compliance-driven model to an evidence-based and rights-respecting one through three coordinated reforms: a revision of Recommendation 33 on statistics to require effectiveness, cost, and exclusion data; a new Recommendation 41 on independent evidence-based evaluation against measurable outcomes; and a new Recommendation 42 on fundamental rights safeguards including procedural protections, redress mechanisms, and minimum access rights to financial services. Participants discussed the "success theater" produced by current activity-based metrics, examples of authorities reporting thousands of SARs yielding only a handful of cases, the realignment of FATF incentives away from procedural compliance toward demonstrated effectiveness, and the practical question of how independent research into regime effectiveness can be enabled without expanding the existing surveillance perimeter.
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Reform Recommendation 33 to require independently verified statistics on de-banking and refusals disaggregated by customer category, compliance costs, outcome ratios linking SARs to investigations and convictions, and customer complaints and redress outcomes.
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Introduce a new Recommendation 41 on independent, evidence-based evaluation of national frameworks against measurable outcomes, including cost-benefit analysis and assessment of discriminatory impacts, replacing self-assessment with externally validated effectiveness data.
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Realign FATF-level incentives to reward demonstrated effectiveness in reducing financial crime rather than procedural compliance with the standards.
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Introduce a new Recommendation 42 on fundamental rights safeguards, including procedural protections for termination and denial decisions, minimum access rights to basic banking services, a presumption of inclusion that reverses the burden onto institutions to justify exclusion, time limits on exclusion with a right of review, and accessible low-cost redress mechanisms for affected individuals.
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