The IIF and the Wolfsberg Group responded to a FATF consultation on amendments to FATF Recommendation 1 and its Interpretative Note. The changes would require countries and the private sector to identify and assess the risks of potential breaches, non-implementation or evasion of the targeted financial sanctions related to proliferation financing. Our comments support the intent of the proposals but emphasize the need to obviate duplication in mitigation efforts and increase effectiveness with concomitant law enforcement mandates around proliferation finance and more effective information sharing on proliferation risks.