Framework overlap

Does PCI SSF cover FATF Recommendation 16?

You hold PCI SSF and have been told to do FATF Recommendation 16. Here is how much overlaps, control by control.

15% of FATF Recommendation 16 you already have

PCI SSF already covers about 15% of FATF Recommendation 16, leaving 11 of 13 controls as genuinely new work.

Already covered 0 Likely covered 2 New work 11

No control in PCI SSF maps directly to one in FATF Recommendation 16. Everything counted as covered is covered because both map to the same third standard, which is what a crosswalk is, but it is an inference rather than a lookup.

What is genuinely new work

Nothing in PCI SSF reaches these. This is the list to scope.

R.16-VATR.Beneficiary
Beneficiary information requirements
R.16-VATR.CVDD
Counterparty VASP Due Diligence (CVDD)
R.16-VATR.CrossBorder
Cross-border transfer controls + intermediary VASP handling
R.16-VATR.DataQuality
Data accuracy, validation and quality assurance
R.16-VATR.Governance
Governance, training and independent testing
R.16-VATR.IVMS101
InterVASP Messaging Standard (IVMS101) and Travel Rule technical infrastructure
R.16-VATR.Originator
Originator information requirements
R.16-VATR.Record
Record retention for Travel Rule data (FATF R.11 + R.16)
R.16-VATR.Sanctions
Sanctions screening of Travel Rule data
R.16-VATR.Status
FATF R.16 Virtual Asset Travel Rule - corpus status, 2024 update + implementation pipeline
R.16-VATR.SunriseSproblem
Sunrise Problem - cross-jurisdictional implementation gaps
Show the 2 you already have
R.16-VATR.Scope
Scope and applicability of Travel Rule to VASPs (R.16 + Interpretive Note to R.15/R.16)
R.16-VATR.Unhosted
Unhosted (self-hosted / non-custodial) wallet transfers - 2024 Targeted Update

How this is calculated

Already covered means a mapping runs from a control in PCI SSF to that control. Likely covered means no direct mapping exists but both frameworks map to the same control in a third standard. New work means neither. We keep those separate rather than adding them into one friendlier number, because blending them would present a two-hop inference as a verified fact.

Coverage is not symmetric. Run it the other way and you will get a different number; both are correct.

From 332,959 cross-framework control mappings across 723 frameworks, 531 of them verified against their source documents. It does not tell you that you are compliant: a mapped control means the two standards ask for the same thing, not that you have done it.

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