# FATF R.23 — DNFBPs: Other measures - **Part of:** [[FATF Recommendations]] Extends the internal-control, group-wide programme, higher-risk-country, reporting and tipping-off/confidentiality requirements of Recommendations 18 to 21 to designated non-financial businesses and professions, including the requirement that DNFBPs forming part of a group implement a group-wide AML/CFT programme with group-wide information-sharing policies. Lawyers, notaries, other independent legal professionals and accountants must report suspicious transactions arising from the specified real estate, asset-management and company-formation activities; dealers in precious metals and stones must report suspicious transactions when they engage in a cash transaction at or above the designated threshold; and trust and company service providers must report suspicious transactions tied to their specified formation and administration activities. Legal professional privilege or professional secrecy exempts qualifying legal professionals from this duty. ## Keyed AMLR articles - [[AMLR Art. 3 - Obliged entities|AMLR Art. 3]] — Obliged entities - [[AMLR Art. 70 - Specific-entity reporting|AMLR Art. 70]] — Specific-entity reporting ## Swiss counterparts - [[GwG Art. 9 - Duty to report (to MROS)|GwG Art. 9]] — GwG Art. 9 Abs. 1bis requires dealers, and Abs. 1ter advisers, to report to MROS; Abs. 2 limits the duty of lawyers and notaries to financial transactions they carry out for a client and to information not covered by professional secrecy (StGB Art. 321). *(direct)* - [[GwG Art. 8d - Adviser organisational measures; training and|GwG Art. 8d]] — GwG Art. 8d requires advisers to take organisational measures, including staff training and controls. *(direct)* - [[GwG Art. 10a - Prohibition of information (no tipping-off)|GwG Art. 10a]] — GwG Art. 10a Abs. 5 prohibits dealers and advisers from telling the persons concerned or third parties that they have filed a report. *(direct)* - [[GwG Art. 15 - Audit duty for dealers|GwG Art. 15]] — GwG Art. 15 requires dealers to engage an audit firm to check their compliance; Abs. 5 makes the audit firm report where the dealer fails to. *(related)* ## Authoritative text > [!quote]- FATF Recommendation 23 — text of the Recommendation (FATF Recommendations, updated June 2026); interpretive note not reproduced > **23. DNFBPs: Other measures** > The requirements set out in Recommendations 18 to 21 apply to all designated non-financial businesses and professions, subject to the following qualifications: > (a) Lawyers, notaries, other independent legal professionals and accountants should be required to report suspicious transactions when, on behalf of or for a client, they engage in a financial transaction in relation to the activities described in paragraph (d) of Recommendation 22. Countries are strongly encouraged to extend the reporting requirement to the rest of the professional activities of accountants, including auditing. > (b) Dealers in precious metals and dealers in precious stones should be required to report suspicious transactions when they engage in any cash transaction with a customer equal to or above the applicable designated threshold. > (c) Trust and company service providers should be required to report suspicious transactions for a client when, on behalf of or for a client, they engage in a transaction in relation to the activities referred to in paragraph (e) of Recommendation 22.