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FinCrime Institute
Category: International Bodies and Standards

Recommendation 15

Also known as: R.15, FATF Recommendation 15, R.15/INR.15, New Technologies (FATF Recommendation)
Simply put

Recommendation 15 is one of the FATF Recommendations, the international standards for combating money laundering and terrorist financing. It requires countries and financial institutions to identify and manage the money laundering and terrorist financing risks that can arise from new and emerging technologies. It is best known for extending these standards to virtual assets and the businesses that deal in them.

Formal definition

Recommendation 15 ("New Technologies") is a FATF standard requiring countries and obliged entities to identify and assess the money laundering and terrorist financing (ML/TF) risks that may arise in relation to the development of new products, new business practices, and new or developing technologies, and to take measures to manage and mitigate those risks. As a FATF Recommendation, R.15 is an international standard rather than binding law; its obligations take legal effect only as adopted into individual jurisdictions' frameworks, and implementation varies accordingly. R.15 was amended in October 2018 to bring virtual assets (VAs) and virtual asset service providers (VASPs) within scope, with an accompanying Interpretive Note (INR.15) adopted in June 2019 setting out how the FATF standards apply to VAs and VASPs. FATF continues to track jurisdictions' implementation of R.15/INR.15, including through assessments of jurisdictions with materially important virtual asset sectors. Practitioners should confirm specific national requirements, thresholds, and definitions against the applicable local regulation, as these are not uniform across regimes.

Why it matters

Recommendation 15 matters because it is the mechanism through which the FATF standards keep pace with technological change rather than being frozen at the point they were written. By requiring countries and obliged entities to identify and assess the money laundering and terrorist financing risks arising from new products, new business practices, and new or developing technologies, R.15 establishes a forward-looking obligation that applies before a given technology becomes mainstream. This is significant for compliance programs because it means risk assessment cannot be limited to established products and channels; emerging delivery mechanisms and innovations fall within scope even where specific rules have not yet caught up.

The Recommendation acquired particular prominence when it was amended in October 2018 to bring virtual assets (VAs) and virtual asset service providers (VASPs) within scope, followed by an Interpretive Note (INR.15) adopted in June 2019 setting out how the FATF standards apply to VAs and VASPs. This extension gave the international AML/CFT framework a common reference point for regulating a sector that previously sat largely outside traditional obliged-entity regimes. FATF continues to track jurisdictions' implementation of R.15/INR.15, including in jurisdictions with materially important virtual asset sectors, which underscores that adoption remains uneven and ongoing.

Because R.15 is a FATF standard rather than binding law, its practical effect depends entirely on how individual jurisdictions transpose it into their national frameworks. Practitioners should treat R.15 as setting expectations that inform local rules, not as a directly enforceable obligation in itself, and should confirm the specific requirements, thresholds, and definitions that apply in each relevant jurisdiction.

Who it's relevant to

Virtual asset service providers (VASPs)
Businesses dealing in virtual assets are the group most directly affected by the 2018 amendment and INR.15, which brought VAs and VASPs within the scope of the FATF standards. How these standards translate into concrete obligations depends on how each jurisdiction has implemented R.15/INR.15, so VASPs should confirm the specific requirements applicable in every jurisdiction in which they operate.
Financial institutions and obliged entities
Under R.15, financial institutions are expected to identify, assess, and manage the ML/TF risks associated with new and emerging technologies and new products or business practices. This applies not only to virtual assets but to technological innovation more broadly, meaning risk assessment processes should account for new delivery channels and products before they are deployed.
Compliance officers and risk professionals
Those responsible for AML/CFT programs use R.15 as a reference point for building forward-looking risk assessment and product-approval processes. Because the Recommendation is a standard rather than binding law and its adoption differs across regimes, these professionals must map R.15 expectations to the specific national rules, definitions, and thresholds that govern their institution.
Policymakers and regulators
National authorities are responsible for transposing R.15 into enforceable domestic frameworks and for ensuring obliged entities are subject to appropriate measures. FATF monitors jurisdictions' implementation of R.15/INR.15, including in jurisdictions with materially important virtual asset sectors, making implementation status a live concern for regulators.

Inside R.15

New Technologies (Original Scope)
FATF Recommendation 15 originally addressed the money laundering and terrorist financing risks arising from new or developing technologies and products. It calls on countries and obliged entities to identify and assess such risks and to take appropriate measures to manage and mitigate them, typically through a risk-based approach applied before the launch of new products, practices, or delivery mechanisms.
Extension to Virtual Assets and VASPs
In October 2018 FATF amended Recommendation 15 to bring virtual assets (VAs) and virtual asset service providers (VASPs) within its scope. This established that countries should assess and mitigate the ML/TF risks associated with virtual asset activities and providers as part of the new technologies standard.
Interpretive Note (June 2019)
In June 2019 FATF adopted an Interpretive Note to Recommendation 15 setting out how the standards apply to virtual assets and VASPs. It clarifies expectations around licensing or registration, supervision, and the application of preventive measures such as customer due diligence and record-keeping to VASPs.
Standard, Not Binding Law
Recommendation 15 is part of the FATF Recommendations, which are international standards rather than directly binding law. Its requirements take legal effect only when transposed into national frameworks, and the precise obligations, thresholds, and definitions may differ across jurisdictions.
Risk-Based Application
The recommendation frames its expectations around identifying, assessing, and managing risk rather than prescribing uniform controls. Obliged entities are generally expected to conduct risk assessments of new technologies and virtual asset activities and apply proportionate mitigating measures.

Common questions

Answers to the questions practitioners most commonly ask about R.15.

Does FATF Recommendation 15 only deal with virtual assets and VASPs?
No. Recommendation 15 is titled 'New Technologies' and its core, longstanding obligation is broader: it requires countries and obliged entities to identify and assess the money laundering and terrorist financing risks arising from new or developing technologies and from new products, business practices, and delivery mechanisms, and to take measures to manage and mitigate those risks. The specific coverage of virtual assets (VAs) and virtual asset service providers (VASPs) was added later, but it sits within this wider new-technologies framework rather than replacing it. Treating Recommendation 15 as exclusively a 'crypto' standard overlooks its application to other emerging technologies and product innovations.
Were virtual assets and VASPs part of Recommendation 15 from the outset?
No. Virtual assets and VASPs were brought into scope through later revisions to the FATF standards. FATF amended Recommendation 15 in October 2018 to explicitly cover virtual assets and VASPs, and in June 2019 it adopted the Interpretive Note to Recommendation 15 setting out how the standards apply to them. The Recommendation itself predates these changes and originally focused on new-technologies risk more generally. It is important to attribute the VA/VASP scope to these 2018 and 2019 revisions rather than to the original text, and to recall that FATF Recommendations are international standards that take effect in a given jurisdiction only through domestic implementation.
How should an obliged entity operationalize the new-technologies risk assessment required under Recommendation 15?
In practice, entities generally embed this into their broader risk-assessment processes by identifying new or developing technologies, new products, and new delivery mechanisms before or at the point of launch, and assessing the associated ML/TF risks. This typically involves a pre-launch or pre-adoption assessment, documented risk-mitigation measures, and ongoing review as the technology or product evolves. The precise expectations depend on how the relevant jurisdiction has transposed the standard into national law and on guidance issued by the applicable supervisor, so entities should map their approach to the local regime rather than to the FATF text alone.
Which businesses may fall within the VASP definition when applying Recommendation 15?
The FATF Interpretive Note frames a VASP by reference to specified activities conducted as a business for or on behalf of another person, such as exchange between virtual assets and fiat currencies, exchange between different forms of virtual assets, transfer of virtual assets, safekeeping or administration of virtual assets, and participation in and provision of financial services related to an issuer's offer or sale of a virtual asset. Because national implementations vary, whether a particular business is treated as a VASP, and how that category maps to local licensing or registration categories, should be confirmed against the applicable domestic law and supervisory guidance rather than assumed from the FATF wording alone.
What are the main compliance obligations expected of VASPs once a jurisdiction implements the Recommendation 15 standards?
Where a jurisdiction has implemented the FATF standards for VASPs, they are generally expected to be licensed or registered and subject to AML/CFT supervision, and to apply preventive measures broadly comparable to those for other obliged entities, such as customer due diligence, record-keeping, and suspicious transaction reporting. The Interpretive Note also addresses obligations relating to the transmission of originator and beneficiary information for virtual asset transfers. The exact obligations, thresholds, and reporting mechanisms depend on the domestic framework, so VASPs should confirm requirements against the rules and supervisory guidance in each jurisdiction where they operate.
How does the information-transmission requirement for virtual asset transfers relate to existing wire-transfer rules?
The Interpretive Note to Recommendation 15 extends the logic of the wire-transfer standard (Recommendation 16) to virtual asset transfers, requiring that specified originator and beneficiary information accompany or be exchanged in connection with such transfers. Operationally this is often discussed as a data-sharing obligation between VASPs, but the precise scope, the data elements required, any applicable thresholds, and the timing of transmission are set by each jurisdiction's implementing rules. Entities should treat the FATF text as the standard and confirm the enforceable details against the applicable national regulation and supervisory guidance.

Common misconceptions

Recommendation 15 has always covered virtual assets and VASPs.
Recommendation 15 originally addressed new technologies generally. Virtual assets and VASPs were brought into scope by the October 2018 amendment, with the accompanying Interpretive Note adopted in June 2019.
Recommendation 15 is a binding legal requirement that applies uniformly worldwide.
It is an international standard issued by FATF, not directly enforceable law. Its effect depends on transposition into each jurisdiction's framework, and the resulting definitions, licensing requirements, and thresholds may vary.
Complying with Recommendation 15 eliminates the ML/TF risk posed by new technologies and virtual assets.
The recommendation calls for measures to identify, assess, and mitigate risk under a risk-based approach. Such measures manage and reduce risk but do not guarantee prevention of financial crime.

Best practices

Assess the ML/TF risks of new or developing products, practices, and delivery mechanisms before launch, and document the risk-based rationale for any mitigating measures adopted.
Confirm how Recommendation 15 has been transposed in each relevant jurisdiction, since obligations for virtual assets and VASPs, including licensing or registration requirements, may differ and should be checked against the applicable national regulation.
Where virtual asset activities are in scope, apply preventive measures consistent with the June 2019 Interpretive Note, such as customer due diligence and record-keeping, calibrated to assessed risk.
Treat Recommendation 15 as an international standard rather than binding law, and map its expectations to the specific statutory and supervisory requirements that actually apply to your entity.
Maintain a current understanding of the scope changes, particularly the October 2018 amendment and June 2019 Interpretive Note that extended coverage to virtual assets and VASPs, so that policies reflect the applicable version.
Review and update new-technology and virtual asset risk assessments periodically to account for evolving products and delivery channels, treating controls as measures to mitigate rather than eliminate risk.