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Cross Border Payments Survey Results

The document presents the findings of a FATF survey conducted to identify challenges in cross-border payments stemming from divergent AML/CFT regulations. It highlights that inconsistent implementation of these standards raises costs, reduces speed, and affects access and transparency in cross-border transactions. The report suggests that addressing these challenges requires harmonization of regulations and enhanced cooperation among jurisdictions while considering the unique risks and legal frameworks of each country.

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0% found this document useful (0 votes)

9 views38 pages

Cross Border Payments Survey Results

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Rudraneel Das

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Cross-Border Payments

Survey Results on
Implementation of the
FATF Standards
October 2021
The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes
policies to protect the global financial system against money laundering, terrorist financing and the financing of
proliferation of weapons of mass destruction. The FATF Recommendations are recognised as the global anti-money
laundering (AML) and counter-terrorist financing (CFT) standard.

For more information about the FATF, please visit www.fatf-gafi.org

This document and/or any map included herein are without prejudice to the status of or sovereignty over any
territory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area.

Citing reference:

FATF (2021), Cross-Border-Payments, FATF, Paris, France,

https://www.fatf-gafi.org/publications/fatfrecommendations/documents/cross-border-payments.html

© 2021 FATF/OECD. All rights reserved.

No reproduction or translation of this publication may be made without prior written permission.
Applications for such permission, for all or part of this publication, should be made to
the FATF Secretariat, 2 rue André Pascal 75775 Paris Cedex 16, France (fax: +33 1 44 30 61 37 or e-mail:
contact@fatf-gafi.org)

Photocredits coverphoto ©Gettyimages

Acknowledgements

The FATF would like to thank public and private sector stakeholders, including financial
institutions, technology developers, trade bodies and associations and other experts, for
providing valuable input and contributions for this report.

The work of this report was led by the FATF Secretariat (Ashish Kumar), with significant
input provided by a Group of Experts from the following FATF delegations: Brazil, Canada,
China, European Commission, France, India, Japan, Mexico, New Zealand, South Africa,
United Kingdom, the United States, as well as the IMF, World Bank, the Basel Committee
on Banking Supervision (BCBS), the Secretariat to the Middle East and North Africa
Financial Action Task Force (MENAFATF) and Qatar (nominated by the Group of
International Finance Centre Supervisors – GFICS).
2  CROSS-BORDER PAYMENTS: SURVEY RESULTS ON IMPLEMENTATION OF FATF STANDARDS

Table of contents

Acknowledgements .................................................................................................................. 1
Acronyms and Glossary .......................................................................................................... 3
Executive Summary ................................................................................................................ 4
1. Background ......................................................................................................................... 6
2. Results of the survey and industry feedback ....................................................................... 8
2.1. Respondents’ profile ............................................................................................................ 9
2.2. Contribution of divergent AML/CFT rules to challenges .................................................. 10
2.2.1. Cost and speed ............................................................................................................. 11
2.2.2. Access.......................................................................................................................... 12
2.2.3. Transparency ............................................................................................................... 13
2.3. Areas where inconsistent national approaches causes the biggest obstacles ...................... 13
2.4. Drivers of Challenges ......................................................................................................... 15
3. Key areas of divergence ..................................................................................................... 19
3.1. Identifying and verifying customers and beneficial owners ............................................... 19
3.2. Targeted financial sanctions screening ............................................................................... 20
3.3. Sending and receiving customer/transaction information .................................................. 22
3.4. Establishing & maintaining correspondent banking relationships ..................................... 24
3.5. Transaction Monitoring and filing STRs ............................................................................ 25
3.6. Onboarding & maintaining agents ...................................................................................... 26
3.7. Other areas ......................................................................................................................... 27
4. AML/CFT measures not stemming from the FATF Standards, causing challenges ......... 28
4.1. Key national measures leading to challenges ..................................................................... 28
4.2. Challenges in information sharing ...................................................................................... 29
5. Conclusions and suggestion from the industry to address key challenges ......................... 32

Acronyms and Glossary

AML/CFT Anti-Money Laundering/Countering the Financing of Terrorism

BB Building Block

CDD Customer Due Diligence

Digital Wallet Provider Digital wallet or e-wallet providers give the customer an opportunity to
have their credit and debit cards in a digital format on their mobile phone
or wearable device. Wallets can also link to bank accounts

DNFBP Designated Non-financial Business and Profession

EDD Enhanced Due Diligence

Electronic Money EMI is an institution that has been granted authorization to issue
Issuer (EMI) electronic money (e-money). E-money is a monetary value, represented
by a claim on the issuer, which is: i) stored on an electronic device (e.g. a
card or computer); ii) issued upon receipt of funds in an amount not less
in value than the monetary value received; and iii) accepted as a means of
payment by undertakings other than the issuer

FATF Financial Action Task Force

FinTech FinTech in broader sense means technologically enabled financial

innovation that could result in new business models, applications,
processes or products with an associated material effect on financial
markets and institutions and the provision of financial services

HRTC High Risk Third Country

INR. Interpretive Note to Recommendation

KYC Know Your Customer/Know Your Client

ML/TF Money Laundering/Terrorist Financing

MSB Money Service Business

MVTS Money or Value Transfer Service

NBFI Non-banking financial institutions

Payment Service PSPs can be traditional PSPs (banks, credit or depository institutions) or
Provider (PSP) non-bank PSPs such as money or value transfer services (MVTS). In some
jurisdictions, electronic money issuers are categorized as PSPs

SDD Simplified Due Diligence

STR Suspicious Transaction Report

TM Transaction Monitoring

TFS Targeted Financial Sanctions

UNSCR United Nations Security Council Resolution

Executive Summary

1. Enhancing cross-border payments is a key priority of G20 in order

to achieve faster, cheaper, more transparent, and more inclusive cross-border
payment services, while maintaining their safety and security; thereby
facilitating economic growth, international trade, global development and
financial inclusion. At its October 2020 Finance Ministers and Central Bank
Governors meeting, the G20 endorsed the Roadmap for Enhancing Cross-
border Payments, which comprises 19 Building Blocks (BBs). FATF is leading
the work on BB5. This Building Block focuses on identifying areas where
divergent AML/CFT rules or their implementation cause friction for cross-
border payments, and considering how these could be addressed. It may,
however, be noted that that some of those differences may be necessary or
justified based on different underlying risks or different legal systems.
2. The FATF, in consultation with BCBS conducted an industry survey
between December 2020 and March 2021. The objective of the survey was to
identify key areas of divergence in implementation of AML/CFT requirements,
which create frictions for cross-border payments and their potential solutions.
The survey and the subsequent technical dialogue with the industry
participants has revealed that divergent implementation of AML/CFT
requirements seems to contribute to challenges for cross-border payments in
a number of ways. While some of these issues may not exclusively relate to
cross-border aspects, inefficiencies caused by inconsistent implementation of
AML/CFT rules and regulations and other related and over-lapping
requirements seem to be areas causing friction for cross-border payments.
3. Raising costs seems to be the main consequence of divergent
implementation, followed by reduced speed, access and inconsistent levels of
transparency. Based on the survey response, areas where inconsistent national
approaches seem to cause the biggest obstacles for the private sector are: i)
identifying and verifying customers and beneficial owners; ii) sanctions
screening; iii) sending and receiving customer/transaction information; and
iv) establishing and maintaining correspondent banking relationships. There
also appears to be an overlap in key challenges. For example, differing
requirements on identification and verification of customers and beneficial
owners create challenges in other areas (sanctions screening, correspondent
banking, sharing of customer information). Divergent interpretation and
implementation of R.16 requirements across jurisdictions seem to cause
challenges for sharing of necessary information and sanctions screening
processes.
4. Key drivers of these frictions identified by the private sector include
conflicting laws and regulations (where national laws and regulations in
different jurisdictions contradict each other or have incompatible
requirements); rules which exist in all jurisdictions, but are interpreted or
applied in different ways or to different extents and inconsistent supervisory
approaches across jurisdictions, notwithstanding different risk and context of
jurisdictions. Challenges caused by varied interpretation and implementation

of data protection and privacy rules and data localisation requirements also
have a cross-cutting impact across the whole range of areas of divergence.
5. Survey responses also highlighted frictions caused by AML/CFT
measures implemented at national levels, which are not stemming from the
FATF standards. These include some jurisdictions establishing rules based
filing expectations, including requirements to report all cross-border
transactions for exchange control considerations, limited use of innovative
services and new technologies and inconsistent national application of or over
compliance with requirements. Some of these issues fall outside of the FATF
remit and may create unwarranted friction.
6. The FATF will take a holistic view on the challenges identified,
including through ongoing dialogue and engagement with the private sector in
order to identify potential solutions. This should include consideration of the
related previous and ongoing work of the FATF, and the work being pursued
by other international organisations, in order to ensure synergy and avoid
duplication. Any potential solution envisaged should be practical and realistic,
and should result in meaningful improvements in efficiency and effectiveness
of national measures, processes, procedures and practices, without
compromising AML/CFT safeguards.

1. Background
7. Enhancing cross-border payments is a key priority of G20. The FSB
set out a three-stage plan including an initial assessment (completed in April
20201), identification of building blocks (completed in June 20202); and
preparation of a roadmap (completed in October 20203) in order to enhance
global cross-border payment arrangements. The roadmap was endorsed by
G20 in October 2020.
8. The roadmap has 19 Building blocks (BB) with BB5 focused on
AML/CFT. The delivery of BB5 is being driven by the FATF in collaboration
with the Basel Committee on Banking Supervision (BCBS). It focuses on
identifying areas where AML/CFT rules or their implementation cause friction
for cross-border payments, and considering how these could be addressed. It
includes the following actions:

Action 1
Further harmonisation of AML/CFT and KYC requirements among countries
FATF and BCBS to consider where further October 2020 – October
harmonisation among jurisdictions could remove 2021
barriers to cross-border payments, and develop
proposals for such further harmonised requirements
(without compromising AML/CFT safeguards)

Action 2
Review evaluation program for national CDD measures and supervision
FATF to conduct a Strategic Review of FATF Mutual October 2020 – October
Evaluation programme, which will provide an updated 2021
basis for evaluations of national CDD measures and
supervision

Action 3
Enhanced cooperation in AML/CFT supervisory matters
FATF to publish Guidance on international cooperation October 2021 – June 2022
among AML/CFT supervisors

Action 4
Development and implementation of technologically innovative solutions for AML/CFT
FATF and other relevant bodies to consider October 2021 – June 2022
development of Guidance or changes in Standards in
order to remove obstacles and promote a more
standardised use of new technologies for applying
AML/CFT controls

1
www.fsb.org/2020/04/enhancing-cross-border-payments-stage-1-report-to-
the-g20/
2
www.fsb.org/2020/07/building-blocks-for-a-roadmap-to-enhance-cross-
border-payments-letter-to-the-g20/
3
www.fsb.org/2020/10/enhancing-cross-border-payments-stage-3-roadmap/

9. The FATF, in consultation with BCBS, conducted an industry survey

between December 2020 and March 2021. The objective was to gather
feedback from payment services providers, including banks, MVTS and other
stakeholders in order to identify key areas of divergence in implementation of
AML/CFT requirements, which create frictions for cross-border payments and
their potential solutions. It is acknowledged that some of those differences may
be necessary or justified based on different underlying risks or different legal
systems.

2. Results of the survey and industry feedback

10. The survey remained open until 15 March 2021, and 173 complete
responses were received. This report provides an analysis of the quantitative
and qualitative input gathered in the survey and subsequent discussions with
the industry. This report is a stocktake of key challenges caused by divergent
implementation of AML/CFT standards, based on the feedback provided by the
private sector and does not necessarily reflect the FATF’s opinion.
11. One hundred ten of the respondents are banks (65%), sixteen are
payment service providers and the rest are spread across various categories,
including associations, FinTech firms, electronic money issuers and others. The
dominance of banks in the survey is not surprising, considering their role in
the global cross-border payments market. However, extensive submission was
provided by other sectors as well, which has been taken into account in the
drafting of this report. Most of the respondents are operating in multiple
geographical regions with value of cross-border transactions being processed
by them ranging from less than 50 million USD/Euro to more than 100 billion
USD/Euro. Almost 71% of the respondents operate in 1-10 jurisdictions and
6% in more than 100 jurisdictions. Responses received were from institutions
operating in jurisdictions classified under different income groups, ranging
from low to high.
12. A statistical and graphical representation of the profile of
respondents who contributed to the survey is as follows.

2.1. Respondents’ profile4

Profile of respondents Chart 2: Geographical areas of operation

Region No. of institutions* %
11% Banks
5% Africa 43 11.6
Digital Wallet Providers
Latin America and the Caribbean 44 11.9
10% Electronic Money Issuers
Northern America 54 14.6
FinTech Asia 111 30.0
6%
1% 65% Payment Service Providers
2% Europe 87 23.5
Association/Trade bodies Oceania 31 8.4
Others * Several institutions operate in multiple regions

Chart 3: Number of jurisdictions in which operating Chart 4: Approx. value of cross-border transactions
Range No. of % processed
institutions Range No. of institutions %
1-10 123 71.1 Less than 50 million 57 33.0
11-49 29 16.8 50-99 million 14 8.1
50-99 11 100-499 million 16 9.2
6.3
500-999 million 13 7.5
100 and above 10 5.8 1-100 billion 51 29.5
More than 100 billion 22 12.7

Chart 5: Income classification of

jurisdictions operating in
Income level No. of institutions* %
High income 71 24.8
Upper-middle income 68 23.8
Lower-middle income 98 34.3
Low income 49 17.1
* Several institutions operate in multiple jurisdictions

4
Respondents providing these services are categorised following a functional
approach, based on their contribution to the survey, rather than as per strict legal
definition. Institutions may provide multiple services and may be categorised
differently in different jurisdictions, in accordance with national legal or
regulatory framework. Please refer to Acronyms and Glossary page of the report
for further description of key terms.

2.2. Contribution of divergent AML/CFT rules to challenges

13. As an overarching mandatory question, the survey solicited

responses on how significantly divergent AML/CFT rules among jurisdictions
contribute to challenges for cross-border payments, noting that some of those
differences may be necessary or justified based on different underlying risks
or different legal systems. According to the respondents, these challenges are:
increased costs, reducing the speed or transparency and limiting access of
cross-border payments. A scale of 1-5 was set out to get structured responses
from participants, with 1 implying the least significant and 5, the most
significant challenge. Respondents were also requested to substantiate their
rating by providing specific examples and comments. A quantitative and
qualitative analysis of the responses received is tabulated below.

Table 1. Contribution of divergent AML/CFT rules to challenges

Contribution of Divergent No. of Institutions
AML/CFT Rules to Most Significant Moderately Minor Least
Challenges significant Significant Significant Significant
Raising cost 63 51 39 13 7
Reducing speed 49 46 45 22 11
Limiting access 35 30 59 28 21
Reducing transparency 24 26 40 38 45

Chart 6: Contribution of divergent AML/CFT requirements to

challenges
0 5 10 15 20 25 30 35 40

Raising cost

Reducing speed

Limiting access
Reducing
transparency

No. of Institutions (percentage) Most significant

No. of Institutions (percentage) Significant
No. of Institutions (percentage) Moderately significant
No. of Institutions (percentage) Minor significant
No. of Institutions (percentage) Least significant

14. Raising costs seems to be the main consequence of divergent rules:

almost 66% of respondents have identified raising cost as the ‘most significant’
or ‘significant’ challenge resulting from divergent AML/CFT rules. Fifty-five
percent of the respondents have identified reducing speed as the ‘most
significant’ or ‘significant’ challenge from divergent AML/CFT rules. Access
(38%) and transparency (29%) were identified as the third and the fourth
challenge in the scale of significance.
15. In the detailed narrative provided by respondents, there seems to
be a strong correlation between the challenge of increased cost and reduced

speed. Hence, the section below seeks to analyse the challenges in three parts:
a) cost and speed; b) transparency; and c) access.

2.2.1. Cost and speed

16. Many respondents indicated that generally, the complexity of
divergent AML/CFT rules leads to increased costs in system development,
monitoring and education. Several respondents highlighted the technological
costs associated with the need to incorporate high-end technology and ML/TF
surveillance solution that can build in all requirements from different
jurisdictions. Changing regulations frequently also increases costs because
new requirements mean financial institutions might have to invest in new or
reshaped processes, technology or training.
17. Many respondents cited inconsistent customer onboarding and due
diligence obligations as the biggest factor contributing to increased costs, and
reduced speed (this issue is further analysed in the thematic section C below).
This leads to delays in customers being able to open accounts and transfer
funds, and can lead to reduced access to financial services for those customers,
especially if profit calculations do not justify the related compliance costs. For
example, in some jurisdictions, it is common to register a customer with his or
her last name and the initials of their first name. Other jurisdictions, however,
require the full first name. This variance in requirements causes queries,
follow-ups and delay in transaction processing as sometimes the payment is
returned due to incomplete customer details, leading to additional costs.
18. Many respondents have indicated that the complexity of divergent
AML/CFT rules also adds to costs and delays by reducing the scope both for
process consolidation within financial groups and for reliance between
different financial entities. Varied approaches to, and wide interpretation of,
certain FATF Standards by different jurisdictions (e.g. of R.16 requirements on
address, including definition of ‘address’, national identity number, and place
of birth) often result in obtaining conflicting information that needs to be
reconciled through intensive manual processes and expert interpretation,
causing delays and increasing costs.
19. Responses received suggest that jurisdictions have adopted
different interpretations and inconsistent application of the R.16 “travel rule”.
Examples of differences include: what information is to be provided in the
payment instructions (different standards for the beneficiary field: address
only or name, address, account/reference number), inconsistent application to
all cross-border payment systems, particularly new and evolving systems,
inconsistent application to domestic payment systems, and different monetary
thresholds at which the “travel rule” should apply.
20. Requirements to conduct CDD on all occasional transactions in
some jurisdictions are said to cause transactions to be queued, which delays
the execution of the transactions. Implementation of AML/CFT regulatory
requirements at the settlement level often slows the process down, where
additional documentation (e.g. tax ID) is required.
21. Cross-border payments are viewed as higher risk transactions due
to their potential use in the ML/TF, as well as the possibility that they will
transit a sanctioned country. Since low-value payments can also be used to

finance terrorism or to fund AML/CFT predicate offences, and as sanctions

legislation applies regardless of amount, all cross-border payments need to be
sanctions-screened and any alerts investigated, which drives up costs and
reduces efficiency. Survey responses noted that as correspondent banks are
required to perform due diligence on their respondent banks, this leads to
perceptions that they become de facto supervisors, rather than being allowed
to place reliance on local supervision of their respondent banks. They also
noted that payments are scrutinized repeatedly at each step in the payment
chain in part because of the inability by each party to apply reliance on each
other.
22. Many respondents have highlighted that cost and speed of cross-
border payments processing are adversely affected due to manual processes
and the increased use of Requests for Information (RFI) (i.e. requests for CDD
information on the sender and/or receiver to the sending or receiving
institution). RFI processing is the most time consuming and therefore, an
expensive process for institutions providing cross-border payment services. A
transaction processed with the appropriate data on the sender and/or receiver
takes between 1-5 minutes to review when it generates a hit or an alert, against
2-5 days when it requires an RFI.
23. Denial of access to payment infrastructure was also cited as a
potential cause of increased costs. Certain national regulations (due to
prudential, AML/CFT or security reasons) do not allow non-bank financial
institutions access to local clearing systems to settle payments, even when the
institution is a full SWIFT member. This could add to the costs of customers of
such institutions. Denial of access to bank accounts in the country of operations
and country of pay-outs (e.g. to MVTS providers) was also highlighted as one
of the most significant issues. This has led to unregulated channels being used
instead, resulting in higher ML/TF risks and lower transparency.
24. Many respondents have highlighted sanctions screening and
transaction monitoring as one of the most significant cost elements, where
there are widely differing requirements, expectations and complexity between
different jurisdictions. The filtering process of transactions showing a hit
against various sanctions lists is labour-intensive, as it also needs to detect
information in free format fields, that causes false positives to be manually
checked by the staff, resulting in delays and increased costs.

2.2.2. Access
25. Some respondents noted that where local obligations on customer
identification are in excess of what national infrastructure could support (e.g.
on biometrics, tax id), this may lead to exclusion of a proportion of society from
formal remittance services. Requirements to obtain all KYC documentations, in
particular, for occasional transaction below monetary threshold, without
basing these requirements on consideration of ML/TF risks not only adds to
cost but often reduces access for those unable to produce the necessary
documentation.
26. Respondents noted that whereas the FATF Recommendations
create a common baseline to which financial institutions should comply, some
jurisdictions habitually “gold-plate” additional requirements. In the case of
cross-border payments, this can be disproportionately onerous and resource

intensive. One such example would be a requirement to conduct AML/CFT

monitoring of all transactions of clients based in or undertaken from and to a
high risk third country (HRTC) prior to execution, rather than post-facto. This
creates pressures on the available monitoring resources, slows down
payments, and runs the risk of monitoring staff taking an overly cautious
position on releasing the payment, leading to access issues.
27. According to survey respondents, additionally, there is
inconsistency in the regulatory requirements that pertain to various members
of the payments ecosystem, which creates an uneven competitive landscape
and does not instil equal accountability. They noted that this, coupled with the
application of less stringent AML/CFT regulation in certain jurisdictions,
renders them particularly high risk. This might place them outside of risk
appetite for certain activities such as cross-border transactions.

2.2.3. Transparency
28. Many respondents noted that AML/CFT regulations increase
transparency because they require more information to be contained in a
cross-border payment message. However, according to them, this information
does not often get carried-over into local clearing systems in some destination
jurisdictions. Inability to view the full path of a payment and the underlying
risks take away from correspondent banking the key element of trust. If
financial institutions do not trust their controls and not trust one another, this
inhibits the transparency and smooth process.
29. Conflict between AML/CFT laws and data protection regulations
might also affect the transparency of payments as KYC information cannot be
shared across jurisdictions. Lack of such sharing might lead to delays in
processing and screening. Lack of transparency in the underlying
payers/payees when processing aggregated payments from payment service
providers, MVTS or other payments related non-banking financial institutions
also adversely affects the transparency of transactions.

2.3. Areas where inconsistent national approaches causes the biggest

obstacles

30. The survey set out certain areas where inconsistent national
approach could cause the biggest obstacles. Respondents were asked to rank
their top three areas in order of priority, with an option to give feedback on
other areas not listed in the survey. Potential areas set out in the survey were:
i) Identifying and verifying customers and their beneficial owners; ii) Targeted
financial sanctions screening; iii) Transaction monitoring and filing STRs; iv)
Onboarding and maintaining agents; v) Establishing and maintaining
correspondent banking relationships; vi) Sending and receiving
customer/transaction information; and vii) others.
31. An analysis of the respondents’ response is as follows. In order to
facilitate cross-comparison among different areas as well as relative ratings
assigned by respondents to the survey, the table below provides a composite
weighted ranking of all areas. This is derived by assigning the weight of 1, 0.5
and 0.33 to Rank 1, Rank 2 and Rank 3 respectively.

Table 2.Areas highlighted as causing biggest obstacle

Area No. of institutions Weighted rank of areas
(with assigned weight 1 to
Rank 1, 0.5 to Rank 2, and
0.33 to Rank 3)
Rank 1 Rank 2 Rank 3 Composite weight
(Rank1*1+ Rank2*0.5+
Rank3*0.33)
Identifying & verifying customers &
beneficial owners 86 20 30 106
Targeted Financial Sanctions screening 22 42 23 51
Sending and receiving customer/transaction
information 19 28 42 47
Establishing & maintaining correspondent
banking relationships 22 28 30 46
Transaction monitoring & filing STRs 12 28 24 34
Onboarding & maintaining agents 3 18 9 15
Others 9 9 15 18

32. Identifying and verifying customers and beneficial ownership

information has been identified as the biggest obstacle with the highest
weighted rank of 106 among all the potential areas. This is followed by targeted
financial sanctions (composite weighted rank of 51), receiving and sending
customer/transaction information (composite weighted rank of 47) and
establishing and maintaining correspondent banking relationships (composite
weighted rank of 46). This analysis is consistent with detailed narrative
provided by the respondents as set out in paras 13-29 above. A further analysis
in each of these areas is set out in sections below.
33. The shortlisted areas identified by respondents contribute to all
four challenges of cost, speed, access and transparency in varying degree. An
analysis of responses received on this aspect is tabulated below.

Table 3. Challenges caused by potential areas of divergence

Contributing to (based on count of number Total
Potential areas of divergence of institutions) count
Cost Speed Access Transparency
Identifying & verifying customers & beneficial
owners 67 84 64 78 293
Sending and receiving customer/transaction
information 39 57 31 51 178
Targeted Financial Sanctions screening 47 55 30 37 169
Establishing & maintaining correspondent banking
relationships 40 38 52 33 163
Transaction monitoring & filing STRs 31 25 18 28 102
Onboarding & maintaining agents 11 14 13 8 46
Others 4 2 1 2 9

34. Data contained in table 3 and chart 8 are consistent with the general
trend of responses received as reflected in table 2. The top four areas:
identifying and verifying customers and beneficial owners; sending and
receiving customer/transaction information; targeted financial sanctions
screening; and establishing and maintaining correspondent banking
relationships were identified as contributing to all the four challenges of cost,
speed, access and transparency with varying degrees of impact.

2.4. Drivers of Challenges

35. In order to solicit structured responses, survey participants were

invited to indicate key drivers, which are causing challenges of increased costs,
reduced speed and limitation in access and transparency. The following five
options were set out in the survey, with a request to substantiate the response
with narrative:
a) Conflicts of law (where national laws and regulations in different
jurisdictions contradict each other or have incompatible
requirements);

b) Rules which exist in some jurisdictions but not others;

c) Rules which exist in all jurisdictions, but are interpreted or applied
in different ways or to different extents;
d) Inconsistent supervisory approaches across jurisdictions; and
e) Others (to highlight drivers not listed above).
36. Table 4 below highlights the statistical analysis of responses
provided by the survey respondents.

Table 4. Drivers of challenges caused in potential areas of divergence

Drivers of challenges (count of number of institutions)

Conflicts of law
(where Rules which
national laws exist in all
and Rules jurisdictions,
Inconsistent
regulations in which exist but are
Potential areas of divergence supervisory
different in some interpreted
approaches Others
jurisdictions jurisdiction or applied in
across
contradict s but not different
jurisdictions
each other or others ways or to
have different
incompatible extents
requirements)
Identifying & verifying customers &
beneficial owners 63 71 63 49 15
Sending and receiving
customer/transaction information 37 39 41 35 16
Targeted Financial Sanctions
screening 37 46 30 31 12
Establishing & maintaining
correspondent banking
relationships 26 33 39 31 10
Transaction monitoring & filing
STRs 26 23 23 21 6
Onboarding & maintaining agents 13 9 9 8 1

37. Table 4 and chart 9 and 10 indicate that conflicts of law; rules which
exist in some jurisdictions but not others; and different interpretation or
application of rules were highlighted as key drivers in the biggest area of
divergence, i.e. identifying and verifying customers and beneficial owners’. The
other key potential areas of divergence (sending and receiving
customer/transaction information; targeted financial sanctions screening; and
establishing and maintaining correspondent banking relationships) also
exhibited similar pattern. The role of inconsistent supervisory approaches,
notwithstanding different risk and context of jurisdictions, was also indicated
as a key factor across different areas of divergence.
38. An analysis of the detailed responses received from the survey
participants highlighted close interaction between drivers of challenges across
the potential areas of divergence. For example, differing requirements on
identification and verification of customers and beneficial owners create
challenges in other areas (e.g. meeting targeted financial sanctions obligations,
establishing and maintaining correspondent banking, sharing of customer
information etc.). Challenges caused by varied interpretation and
implementation of data protection and privacy rules were reported across the
range of potential areas of divergence.

39. This section, therefore, analyses each of these drivers holistically in

key areas of divergence, with a view to focus on main points raised by
participants. This analysis is set out below.

3. Key areas of divergence

3.1. Identifying and verifying customers and beneficial owners

40. This was highlighted as a biggest area of divergence. Factors

highlighted include differing documentation requirements, differences in risk-
based approach, divergent implementation of data protection and privacy
rules and perceived conflict between AML/data protection requirements, lack
of access to accurate beneficial ownership information and onerous CDD
obligations on directors, persons acting on behalf of corporate clients.
41. Many respondents noted that the primary way in which AML/CFT
practices impact on cross-border payments is through divergent national
requirements for customer due diligence. According to them, the
interpretation of risk-based approach and the application of simplified due
diligence (SDD) differs between jurisdictions, with some jurisdictions
permitting SDD in a very limited and prescriptive number of situations.
42. For example, some jurisdictions restrict the type of customer or
product that can be considered lower risk, and whether SDD can be applied,
without consideration of ML/TF risks posed in individual situations. This
approach could create an overly cautious approach for lower risk situations
and reduce the effectiveness of a firm’s ML/TF risk management function.
Participants highlighted that a prescriptive approach to CDD or specifying a
mandatory list of documents that should be obtained in all cases is an
ineffective way to reduce ML/TF risk. Rather, the CDD requirements, including
documentation required should be tailored to the type of client and exercised
using a risk-based approach instead of a prescriptive approach. In this
scenario, the costs remain disproportionately high to the level of risk posed by,
for example, low value transactions (and customers) in certain regions. It can
also exclude access for those without the ability to provide certain documents
or information, usually the ones at most need of financial inclusion.
43. Many respondents noted that rules-based over-compliance with
FATF Recommendations and institution of rules, which are not based on an
assessment of real risk could lead to unnecessary CDD requirements, adding to
costs and delays and takes the regulated sector’s focus away from genuine
financial crime prevention. Examples highlighted include differences about the
concept of beneficial owner and controlling ownership, lack of SDD measures
in appropriate cases such as in case of the public companies listed on a stock
exchange and subject to disclosure requirements, which impose requirements
to ensure adequate transparency of beneficial ownership and creating
obligations to verify the identity of the beneficial owner in all cases (rather than
take reasonable measures as provided under R.10). Other areas highlighted by
respondents include creating mandatory requirements to verify the identity of
all directors and to identify and verify the identity of individuals doing
transactions on behalf of corporate customers as well (rather than just retail
customers on power of attorney basis).
44. In some jurisdictions, there is a significant proportion of citizens
with no formal identity documentation. Responses suggest that mandatory
identity documentation standards for financial services (including cross-
border payments) therefore excludes this proportion of the population from

receiving much-needed services. Lack of digital alternatives were also cited as

factors leading to increased costs associated with on-boarding customers.
45. According to the respondents, in several jurisdictions, privacy and
AML laws continue to be enacted without proper alignment with each other,
which often creates conflict-of-law situations. Some jurisdictions require
through their AML rules that information of the counterpart of the transaction
is collected and shared, for monitoring and screening purposes, however,
privacy rules in the same jurisdictions do not allow sharing of the same items
of consumer information. Fragmented beneficial ownership information
collected by various agencies also creates challenges. Lack of centralised
registries for beneficial owners increase costs and causes delays.
46. Different CDD requirements regarding necessary documents are an
obstacle that prevents financial institutions establishing uniform IT systems
and conflict with uniform group-wide requirements. For example,
inconsistencies exist in country requirements on data points that should be
collected such as place of birth (which is not available in some ID documents),
date of birth, gender information, etc.
47. Inconsistencies highlighted in the survey response and the
subsequent technical dialogue with the industry referred to different data
points that should be collected for individuals empowered to control and
manage bank accounts of a corporate entity. Respondents noted that within the
European context, for example, a single Regional Corporate Treasurer or
Regional Financial Director may have access to multiple bank accounts in
various jurisdictions. However, the information that must be collected on this
individual to validate identity for the purpose of CDD differs in each
jurisdiction and does not appear to be based on consideration of ML/TF risks.5
For example, country of birth is required in some countries (only for resident
entities), but not others. City of birth is required in some countries, but not the
country of birth information, which is a mandatory requirement in others.
Similar inconsistency exists for gender information as well as information on
senior management and owners. KYC processes for most financial institutions
generally include a “country appendix” for the country in which the account is
opened, which often causes delay and create significant complexity when a
client falls in scope of multiple country appendices.

3.2. Targeted financial sanctions screening

48. Key areas highlighted in this section include inconsistent

requirements, conflicts of laws, different approaches of supervisors to
sanctions compliance, challenges caused by data transparency, different
national standards on beneficial ownership obligations and multiple sanctions
lists across jurisdictions with weak and often incomplete data.
49. One respondent noted that today around 5% of all cross-border
transactions are subject to additional sanctions-related review. Of this 5% of
transactions items that cause alerts in automated screening systems, over

5
Despite these national differences in CDD, obligations related to the information
accompanying cross-border payments in the EU are fully harmonised through EU
Regulation 2015/847.

99.9% are ultimately closed as false-positives. The delay caused by manual

reviews , which are required to be done prior to execution, negatively impacts
customer experience, causes unnecessary delays in the payment cycle (tying-
up liquidity), creates unnecessary cost for financial institutions, financial
exclusion and does not significantly reduce sanctions evasion risk. These
sanctions impacts are multiplied as processes are duplicated by every
participant in the payment chain. In some cases (e.g. trade financing), financial
institutions can identify any sanctions related alerts only from trade
documents and not from SWIFT message, as these documents are more likely
to have information such as planned transit ports/origin/destination of
products and vessel. These documents are often paper-based and difficult to
digitize and incorporate into the transaction screening system. This, in turn,
requires time and effort to scrutinise every trade document to confirm that the
cross-border transaction does not violate any sanctions, leading to increased
costs and delays due to manual processing. Also, there is a possibility of the
change in the sanction list during the usance period (three to twelve months)
between the acceptance of documents and the payment at maturity. This would
require the real time screening during the usance period and potentially,
digitalisation of the information to be screened.
50. Participants cited conflicts of law and inconsistent requirements
across jurisdictions as key factors creating challenges. While many
jurisdictions also implement regional organisation-based sanctions, beyond
UN sanctions, some additionally promulgate autonomous sanctions regimes
based on their foreign policy or national security agendas, although these
sanctions are outside the remit of the FATF standards. From a sanctions-
screening perspective, this can mean that there are parties targeted by a
certain jurisdiction but not others and therefore there are different screening
requirements based on jurisdictions. Additionally, data available on sanction
lists are usually incomplete and do not provide enough information so that
financial institutions can make informed decisions, resulting in the large
number of false positives.
51. According to survey participants, there are different expectations
by jurisdictions for financial institutions to identify additional parties for
screening based on their ownership and/or control. In some jurisdictions,
there is the 50% rule, which extends freezing obligations to parties owned 50%
or more by individuals and entities on the designated lists. While other
jurisdictions expect financial institutions to identify and act upon parties
controlled by a designated individuals and entities irrespective of ownership
thresholds. For financial institutions, this means they are required to develop
their own intelligence function to identify parties within the ownership and
control scope for screening. According to them, this consumes time and
resources in creation of vast sanctions screening lists, which may diverge from
institution to institution. These lists can become unwieldy and ineffective as
they exceed the number of parties expressly designated by applicable
authorities, and there is a statistically low chance of a positive alert for
designated targets or the parties they own or control. This focus on screening
the lists can consume time and resources that can otherwise be used for more
practical risk mitigation efforts, which respondents felt would do more to
reduce sanctions evasion.

52. Responses suggest that inconsistent implementation of complex

sanctions requirements on a national level complicates institutions’ abilities to
implement sanctions compliance controls and can lead to over-screening in a
multitude of jurisdictions. Some respondents noted that while UN sanctions
are required to be implemented by all member states, each jurisdiction takes
their own approach to implementation. In addition, in some jurisdictions,
expectations of sanctions requirements have been misinterpreted to include
certain historical UN sanctions targets related to certain jurisdictions of
concern that no longer require real time screening. Some jurisdictions, have
established the requirement to screen all transactions for any jurisdiction in
which there are parties targeted by list-based sanctions, making the sanctions
regime more expansive.
53. Financial institutions must comply with the varied regulatory
obligations that govern the industry. Some jurisdictions have laws or
regulations that may prohibit or restrict compliance with certain requirements
of the sanctions regime of another jurisdiction. Significant operational
resources are needed in order to scrutinise the potential exposure to financial
sanctions. As cross-border volumes increase, so does the need for incremental
resources to manage situations in which there may be conflicting legal
requirements.
54. Respondents noted that in such a scenario, challenges related to
transparency also manifest. Swift formats are not mandatory; certain data
elements are not mandatory and not consistent across industry, causing
challenges to cross-border payments. Transparency may also be impacted
where the payment instruction is a "bundled payment" as there may not be full
transparency in the underlying parties. Data privacy laws in some jurisdictions
are more stringent than others, resulting in limited available information on
sanctioned individuals and entities. This could cause difficulty in ascertaining
whether a potential match arising from sanctions screening is true or not.
55. Inconsistent supervisory approaches and regulations is another
factor highlighted by the respondents. Regulatory focus on this issue is not the
same across jurisdictions, therefore making institutions in some jurisdictions
potentially less inclined to have strict/consistent screening requirements. A
related challenge reported by institutions is that beneficial ownership levels
vary across jurisdictions, and so screening for sanctions against ultimate
beneficial owners is challenging.

3.3. Sending and receiving customer/transaction information

56. Key concerns highlighted in this area include lack of standardisation

in data formats and data elements, lack of information sharing due to data
protection and privacy concerns, lack of interoperability of cross-border and
domestic payments systems and different supervisory approaches for
monitoring of payments service providers and agents.
57. Many respondents highlighted platform/system/messaging
limitations in this context. For example, limitations in the number of characters
allowed in some SWIFT fields leads to incomplete information. Participants
have noted that jurisdictions are implementing clearing systems to enhance
the speed of cross-border payments and to account for pre-validation

requirements. However, as jurisdictions continue to implement individual

systems, standardization of payment formatting will become increasingly
difficult and the risks associated with differing message and field lengths that
lead to intentional abbreviation and unintentional truncation will remain.
58. R.16 seems not to be uniformly implemented across jurisdictions,
as there are no clear rules in some jurisdictions or those rules are
inconsistently implemented with one another. Respondents specifically
highlighted that there continues to be divergence in expectations on
beneficiary information. Some jurisdictions, for example, require name,
address and account number/reference number of the beneficiary in addition
to that of the originator. The format of an address varies from country to
country and different regulators have different expectations on what
constitutes a valid address (e.g. whether P.O. Box as address proof is
acceptable). Some jurisdictions require only the initials of the payee and the
beneficiary, while others insist on full name. This results in incomplete or
difficulty in sanctions screening by financial institutions, as they do not have
full names in all cases. Moreover, banks' practice of searching of listed persons
and entities by using keywords such as initials, aka (“also known as” nickname)
aiming to capture wide-ranging suspicious names of persons and addresses,
generates inefficiency with many false positive hits. It is also time consuming,
as resources have to be deployed to continuously go back to the counterparties
and request the information.
59. In addition, responses suggest that domestic consumer-oriented
payment systems are not designed for inter-operability with cross-border
systems. Divergent application on application of the standards, particularly
where a cross-order payment moves to a domestic payment system and lack of
interoperability between messaging and payments systems also create
challenges.
60. Privacy laws are said to often prevent the transfer of certain
customer data that the receiving jurisdiction requires. This places the payment
provider in a conflict of laws situation. Some jurisdictions require agents to see
all information, which then creates a risk of a breach of privacy laws. Despite
the fact that the payment provider is the licensed entity, which conducts the
monitoring for suspicious transaction, different supervisors require the same
type of monitoring to be conducted by agents as well. The divergent approach
to supervision creates frictions related to costs and speed.
61. Some respondents noted that greater clarity was needed on the role
of Money Service Businesses (MSBs)/Fintech type entities/payment
aggregators who initiate payments on the instruction of their underlying
clients and facilitate transfer of funds. There is a difference in interpretation of
the definition of a payment service provider (PSP) and whether these entities
should be considered a ‘PSP’ for the purpose of wire transfer requirements.
Because of the perceived ambiguity, different definitions of ‘PSP’ and licensing
requirements in different jurisdictions, these entities have been seen to
represent themselves as the originator (i.e. actual customer instead of the
initiating ‘PSP’) despite effectively acting in the capacity of a PSP.
62. Inconsistent supervisory approaches across jurisdictions is also
said to create challenges. The key inconsistency is lack of clear guidance on
how financial institutions that provide services to other payment service

providers, such as non-banking financial institutions (NBFI), should respond

to aggregated payments, bundled at a domestic level, sent cross-border as a
single transfer, and then disaggregated in a separate jurisdictions. In many
cases, clarity does not exist on the underlying payment transparency and
sanctions obligations for the financial institution facilitating these transfers on
behalf of the NBFI.

3.4. Establishing & maintaining correspondent banking relationships

63. The key challenges highlighted in this part include de-risking,

different approaches to nesting and on know your customers’ customers
(KYCC), inconsistencies in national treatment of money or value transfer
services, quality of information shared, varying national requirements on
conduct of enhanced due diligence for high risk jurisdictions and lack of
supervisory clarity on bundled payments.
64. Some respondent noted that different approaches to nesting are key
considerations that constitutes an obstacle in establishing and maintaining
correspondent banking relationships. The FATF published a guidance on
correspondent banking relationships in 2017.6 The guidance clarified that the
FATF Recommendations do not require financial institutions to conduct
customer due diligence on the customers of their customer (i.e. KYCC for each
individual customer). However, uneven implementation of the requirements
remains a challenge. Varying local regulatory expectations still exist on the
levels of KYCC due diligence that may be needed under certain circumstances.
Because of stringent regulations, compliance costs have risen causing
correspondent banks to stop servicing certain corridors that are considered
higher risk or are not profitable. These requirements then extend to national
banks that do not provide bank accounts to the money service companies that
send payments to these corridors. Therefore, money service companies cannot
get bank accounts or get their bank accounts closed.
65. Lack of compatibility between international and local clearing
systems was also highlighted. Institutions have differing views on whether
local clearing systems can be used for international transfers. Those who do
use it, may find systems not being compatible i.e. information truncating when
moved into the domestic clearing system. This could lead to non-compliant
payments and further delays in the transfer.
66. According to the respondents, divergent national requirements
might also exacerbate the impact of enhanced due diligence (EDD) for
correspondent banking relationships. Since an assessment of a potential
respondent’s control includes an interpretation of any difference between the
two frameworks, the additional complexity from divergent national
requirements add costs and delays. In some cases, it also requires follow-up
discussions. The cumulative burden can also result in limited access for

6
www.fatf-gafi.org/media/fatf/documents/reports/Guidance-Correspondent-
Banking-Services.pdf

respondents, particularly in certain jurisdictions where a perception of higher

risks already impose EDD burdens.
67. Differing document (physical versus electronic) and certification
requirements between jurisdictions and financial institutions are identified to
be another challenge by the respondents, adding time, confusion and further
cost to an already cumbersome process. While the majority of financial
institutions can accept an electronic format, there are some in certain
jurisdictions, which still stipulate the need for physical hard copy documents.
Further, certification requirements add an additional level of complexity and
misalignment between which documents need to be certified, who should
certify these documents and in what circumstances.

3.5. Transaction Monitoring and filing STRs

68. Key areas highlighted in this section include inconsistency and

unstructured data formats and elements, divergence in parameters to monitor
and report transactions, focus on more rather than better STRs, divergence in
threshold of reporting STRs, generation of high volumes of false positives and
a general focus on regulatory compliance rather than risk management.
69. Similar to responses in the previous areas, many respondents noted
that AML controls require accurate identification and classification of the
entities in a payment chain (e.g. the underlying originator and beneficiary).
Variations in data standards makes it difficult for AML controls to accurately
transform the data into a consistent format for analytical purposes. In
correspondent banking, AML investigations typically take place on originators
and beneficiaries that are account holders at other (cross-border) financial
institutions. Due to multiple payment formats, payment data needs to be
transformed and normalized, to be useful in automated transaction monitoring
systems. Payment data can often be inconsistent and unstructured, which
limits the ability to aggregate and analyse for AML detection purposes and
makes it more difficult to apply rules that are based on particular data, such as
originator jurisdiction.
70. Respondents noted that jurisdictions have a requirement to
monitor transactions, however, in some cases, each financial institution does
this differently, applying different parameters and without focus on risk. In
addition, employees carrying out transaction monitoring may apply a financial
institution’s risk appetite slightly differently. This sometimes leads to
inconsistent approvals/rejections of transactions downstream. Additionally,
certain jurisdictions require foreign MSBs to report transactions beyond a
threshold value, while others do not. Hence, time and money have to be spent
building out these reports. Finally, certain jurisdiction require standardised
purpose of payment codes, which can lead to lack of transparency regarding
exactly what a payment is for.
71. Some respondents noted that filing suspicious transaction reports
has become more about technical regulatory compliance rather than effective
risk management. Where any doubt exists, financial institutions are motivated
to file, and file as soon as possible, to avoid regulatory sanctions. Many
AML/TM controls generate a high volume of ‘false positive’ alerts with high
investigation costs. This can be caused by banks taking a defensive and risk

adverse approach due to regulatory pressure and lack of benchmarks,

guidance and tools for determining appropriate rule settings.
72. According to the participants, requirements also vary across
jurisdictions ranging from a need to report on unusual to requiring filing only
if there is reasonable certainty that a law has been broken. This results in a
need to have differing process in each country. The differing thresholds limit
the ability to use STR numbers filed as a universal indicator of risk by banks.
The fact that financial institutions generally have little insight into which STRs
are of use to regulators and law enforcement (due to lack of feedback) leads to
an inefficient allocation of resources and potentially missed transactions of
interest. A historical focus seemingly on more rather than better STRs
exacerbates the challenge. It was highlighted that there are different levels of
AML control in Transaction Monitoring (TM) across jurisdictions and,
therefore, the network is as strong only as its weakest link.
73. Some respondents noted that the cost of maintaining effective AML
controls can be a barrier for smaller banks and banks in jurisdictions where
regulators have higher expectations. Lack of proper application of risk-based
approach further compounds the problem.

3.6. Onboarding & maintaining agents

74. Key areas highlighted in this section include data protection and
privacy concerns, lack of access to accurate and reliable beneficiary ownership
information of agents, lack of effective controls by agents and lack of clarity on
role of third parties doing due diligence on behalf of institutions.
75. In line with previous discussion, some respondents noted that in
some jurisdictions, data protection and privacy laws often seem to conflict with
the ability to collect ownership information about agents. In some
jurisdictions, the lack of national registers, which can be used to verify
beneficial ownership of agents, could also be an impediment to validating the
information collected by the payment providers. There is a need for clearer and
reasonable rules regarding conducting background checks, in particular on
directors of publicly traded corporations. Some jurisdictions do not allow
reliance on another government entities’ controls of those types of
corporations.
76. Where a third party agent is responsible to conduct due diligence
on behalf of a regulated entity, responses suggest that there should be clear
guidance on the specific responsibilities for the parties involved. The use of
third parties is expensive and in some instances, it may not be able to provide
comprehensive compliance adherence from a legislative and operational
perspective.
77. Further, agents’ limited exposure to AML compliance, not having
similar standards in place as banks, also causes regulatory imbalance concerns
about compliance standards.

3.7. Other areas

78. Some participants highlighted data localisation as another key area

of concern. Some jurisdictions require holding and processing of all data
relating to financial services, including cross-border payments, locally. For
multinational businesses, this imposes significant additional costs, as there is
no ability to undertake AML/Compliance processes, such as customer
screening, at a global level in order to share costs across jurisdiction. Instead,
infrastructure costs must be duplicated locally. The higher compliance costs in
these jurisdictions reduces the opportunity for cost per transaction to be
lowered and to therefore be reflected in lower consumer fees.

4. AML/CFT measures not stemming from the FATF Standards, causing

challenges
4.1. Key national measures leading to challenges

79. Key issues raised in this section include rules based filing
expectation, requirements to report all cross-border transactions due to
exchange control considerations, excessive requirements for non-face-to-face
customers, multiple documentary sources and differences in data required and
the ownership threshold, restrictive requirements on innovative services and
new technologies and prescriptive and inflexible obligations such as on EDD on
all transactions undertaken from and to high risk third countries.
80. The survey solicited responses from the private sector on potential
challenges caused by national AML/CFT measures, which are not stemming
from the FATF Recommendations. Participants were invited to identify top
three national AML/CFT measures, which cause challenges for cost, speed,
access or transparency. Forty-seven respondents provided their contributions
in this area. An analysis of the responses received indicates that the areas
identified are diverse with varying degree of impact on the challenges.
81. For example, respondents have highlighted rules based filing
expectations, requirements to report 100% of cross-border transactions on a
daily basis (without any regard to ML/TF risk), threshold/aggregated
reporting of all electronic funds transfer and requirements to obtain additional
information on outgoing/incoming remittances to address exchange control or
other non-AML/CFT requirements as factors underpinning the key challenges.
82. Participants noted excessive requirements for non-face-to-face
customers and mandatory EDD measures for all customers and transactions in
relation to designated high risk third countries (without any scope for
individual risk assessment of such customers or transactions) as some of the
other key areas of concern. Responses also suggest that lack of regulatory
equivalence between the implementations across different jurisdictions means
that financial institutions are unable to rely on compliance activities conducted
by other financial institutions. This, together with lack of industry wide
standards on transaction information adhered to by all banks, also creates
additional complexities.
83. Some respondents noted that restrictive exchange control
regulation in certain jurisdictions results in the emergence of black market for
remittances. This raises the costs of remittance due to scarcity of hard
currencies. This could also lead to increased ML/TF risks as customers would
need to make use of unregulated markets to remit funds due to the restrictive
exchange controls.
84. Some participants highlighted restrictive regulatory requirements
on innovative services and new technologies and the misplaced trust on legacy
transaction monitoring systems more than new RegTech and parallel use of
legacy and new technological solutions leading to duplications. In addition,
overflow of STR filings and lack of meaningful feedback were also highlighted
as factors leading to increased costs. Overly strict approach to tipping off also
causes concern in some cases as even transactions monitoring analysts are

prohibited from access to the STR information or any indication whether STR
was filed based on their analysis. This prevents feedback loop and practical
training to the frontline staff.
85. Some respondents noted that the inconsistent national application
of supranational requirements by member States cause significant burden on
global financial institutions that need to tailor compliance procedures to each
country’s set of requirements. An example of this is the need for greater
common standards regarding high risk third country measures. HRTC risk
factors should be aligned with FATF’s assessment of country risks, which
would further harmonize risk management requirements across the region.
Prescriptive and inflexible obligations such as on EDD on all transactions
undertaken from and to HRTC regardless the client risk rating, adds to the
complexity and costs. This not only generates a large amount of workload that
does not mitigate risk, but also leads to financial exclusion and business
disadvantage.
86. Forty six respondents highlighted all four challenges (cost, speed,
access and transparency), with varying degree of impact. The following table
highlights the combined effect of these measures on challenges for cross-
border payments based on the feedback received. It may be noted that for the
purpose of analysis, the table below presents the impact on these four
challenges based in percentage terms, based on all the responses received in
this section of the questionnaire. Cost remains the key concern, with 31%of
responses citing it as the biggest challenge, closely followed by other
challenges.

Table 5. Impact of top three national measures

Impact of top three National AML/CFT Measures not stemming from FATF % of respondents
Recommendations
Increased costs 31
Reduced Speed 25
Limiting Access 23
Reduced transparency 21

4.2. Challenges in information sharing

87. This section of the questionnaire covered challenges relating to

information sharing. Participants were asked if challenges in information
sharing (group wide or with other financial institutions), within or across
jurisdictions, impede cross-border payments and to what extent. One hundred
twenty six participants responded to this question, with 77 of them confirming
it as a challenge for cross-border payments. An analysis of the responses
received is set out in the tables and charts below.

Table 6. Challenges in information sharing and nature of impact

Potential areas of Count of number of institutions
friction
Cost Speed Access Transparency
40 52 39 48
Nature of impact (No. of Institutions)
Challenges in
information sharing Most Significant Moderately Minor Significant
significant Significant

25 30 18 3

88. Out of 76 respondents who ranked the challenge posed by

constraints on information sharing, 72% (55/76) considered it as ‘significant’
or ‘most significant’ factor. The key factors underpinning the challenges
identified include conflicts in application of banking laws and data protection
and privacy laws inhibiting sharing of CDD information, including source of
funds with correspondents, data localisation restrictions, manual processing of
CDD information leading to reduced speed and cost escalations, inability to
monitor transactions globally and inefficient sanctions screening processes.
89. Failure to share information between financial institutions for
reasons of confidentiality, including for legal impediments, seems to reduce the
speed of processing transactions, as it is necessary to carry out an in-depth
investigation of the process, which often is not possible due to challenges in
timely flow of information.
90. Many respondents noted that one of the main issues pertaining the
personal data protection considerations is the legitimate ground for processing
personal data for the purposes of fighting financial crime. In the context of the
AML/CFT framework, obliged entities have three main legal obligations: to
perform customer due diligence checks, to monitor transactions and to report
suspicious activity. Sharing information with public sector authorities may not
be considered by certain national data protection authorities to fall within
these hypotheses. Given these considerations, there currently exists
uncertainty as to the most appropriate ground for sharing information for
AML/CFT purposes. This uncertainty leads to divergent approaches at the
national level, which ultimately may impede cross-border exchange of
information within groups.
91. Further, due to local data privacy legislation, firms often have to on-
board the same customer separately in multiple jurisdictions as they cannot
share relevant onboarding data within the group or with affiliates. This leads
to delays and extra cost for cross border payments, and also knock on effects
in terms of user access to cross-border payments in jurisdictions where data
sharing is an issue.
92. Technical interoperability of legal entity data was also identified by
the respondents as a major challenge in information sharing that greatly
impedes cross-border payments. It was highlighted that information sharing
can only be effective if the information transmitted from financial institutions
clearly identifies the involved parties with standard identifiers rather than
names in free form text. However, cross-border payments participants do not

have a harmonized information sharing system or template, which all financial

institutions, regardless of where they are, should use.

5. Conclusions and suggestion from the industry to address key

challenges
93. Responses received from participants seem to indicate that
divergent AML/CFT requirements could be contributing significantly to
challenges for cross-border payments. Key areas of these requirements relate
to identifying and verifying the identity of customers and beneficial owners,
receiving and sharing customer and transaction information, screening for
targeted financial sanctions and establishing and maintaining correspondent
banking relationships. The paper lists a number of key challenges highlighted
by respondents to the survey. Based on survey responses and the subsequent
discussion with industry participants, this section also provides initial
suggestions received from participants on how to address some of these
challenges.
94. Further consideration would need to be given to AML/CFT
measures implemented at national levels, which are not stemming from the
FATF standards. Responses received on the issue have highlighted a number of
issues, many of which are outside the remit of AML/CFT. As noted by
respondents, these include rules based filing expectation, including
requirements to report all cross-border transactions for exchange control
considerations, limited use of innovative services and new technologies and
inconsistent national application of or over compliance with requirements.
95. Information sharing remains a key challenge, both within and
across financial institutions and jurisdictions. This impacts appropriate risk
monitoring, transaction processing and sanctions screening. Data localisation
and inconsistent interpretation or application of data protection and privacy
laws and their interaction with AML/CFT laws are key points of concern.
96. Some respondents noted that jurisdictions should look to
harmonise and standardize the data points and/or fields that must be captured
to enable the one-time collection of identity information from clients.
Additionally, there needs to be a broader global understanding of FATF
requirements, including of risk-based approach, as discrepancy exists in the
level of understanding across various regions. Greater harmonisation in CDD
rules and high risk Jurisdiction rules and increased collaboration among the
FIUs were other suggestions received in this regard. Respondents noted that
while the perception of risk might differ from country to country on a given
sector, thematic work on RBA and what it entails would help jurisdictions in
general.
97. National registry of KYC and beneficial ownership information and
proper infrastructure to ensure maintenance/accuracy of it were also cited by
a number of respondents. Respondents noted that development of a
comprehensive digital population identification infrastructure could also
support expansion of financial services, including international remittances to
whole populations. In this regard, respondents also noted the importance of
guidelines from jurisdictions for the banking sector with clear rules on how to
provide access to the non-bank payment service providers.
98. As noted by a number of respondents, greater clarity and
consistency in the implementation of R.16 would be helpful. This would include

consistent expectations on the information required for originator and

beneficiary across jurisdictions, including minimum standards for ‘address’
and its components, consistency in expectations from intermediary
institutions pertaining to reaching out to the originating institution to obtain
missing information in payment messages and application of these
requirements on new payment companies using emerging technology.
Respondents noted that the transition to ISO 20022 standards for payment
messaging should help, though a standardised approach to what data are
mandatory and for which parties would still be needed.
99. Respondents noted that a possible way to address the information
sharing challenges stemming from data protection and privacy concerns could
be to create a framework that ensures that financial institutions are able to
process personal data to achieve the AML/CFT objectives in line with the
applicable data privacy rules. For example, a legal basis possibly covering the
AML/CFT activities and clarifying that these activities are covered by
‘legitimate interests’ of financial institutions and that those financial
institutions can choose the most adequate mechanisms to be compliant with
the Regulation. Alignment of privacy laws in all jurisdictions was cited as a key
challenge.
100. Some respondent noted that lack of intra-group reliance wastes
significant amounts of internal resources, and impedes financial institutions
and their clients from providing access to financial services within their group
effectively and efficiently. They also noted that the level of duplication caused
by the lack of regulatory equivalence and the inability to rely on compliance
processes performed by other institutions in a cross-border context creates a
significant burden. They highlighted the importance of following a risk-based
approach for implementing the FATF Recommendations in national legislation
by requiring legislation to be more principles-focussed and less prescriptive
where this is possible. This could help alleviate the regulatory top-up exercises
by allowing financial institutions more flexibility in terms of demonstrating
that they know their customers and reduce the need for collecting additional
documentation from clients with little value to financial crime risk
management.
101. On the challenge of sanctions screening identified previously, some
respondents suggested development of best practices at a global level to
ensure more consistent application of sanctions screening requirements
across jurisdictions. This could include best practices on issues such as
complying with list-based sanctions and comprehensive sanctions, importance
of a principles-based focus, screening of aliases, whitelisting of false positive
and use of emerging technologies (e.g. machine learning) to reduce false
positives.
102. In this context, many respondents supported increased cooperation
between regimes to standardise sanction list formats, interpretation of
contents, expected response associated with listings and list distribution
approaches. According to them, increasing uniformity in the list entries and
greater use of structured identifiers such as Legal Entity Identifiers (LEIs),
Business Identifier Codes (BICs) and digital identities and linkage of list entries
between UN and country lists would simplify the screening process and
improve detection performance. They also indicated that wider adoption of the

LEI for entity client identification and identifying beneficiary and originator in
payment messages would support widespread interoperability between
systems and reduce costs and increase precision and transparency.
103. Participants noted that it would also be useful for the industry to get
a better understanding of the purpose, use and effectiveness of the information
it currently provides. Feedback from FIUs as to what information is helpful to
them was highlighted as a key success factor. They supported public private
partnerships and information sharing groups, including development of
recommendations on the type of information that can be shared and the
circumstances under which such sharing is appropriate. Respondents also
highlighted that there should be an ongoing dialogue between the public and
private sectors regarding the creation and implementation of financial sector
requirements in order to avoid unintended consequences that may lead to less
effective risk management or potential de-risking.

Faster, cheaper, more transparent, and more inclusive cross-border payment

services, that are safe and secure can facilitate economic growth, international
trade, global development and financial inclusion. Enhancing cross-border
payments is a key priority of the G20. In October 2020, G20 Finance Ministers
and Central Bank Governors endorsed the Roadmap for Enhancing Cross-border
Payments, which comprises 19 Building Blocks. The FATF initiated an industry
survey in consultation with the Basel Committee on Banking Supervision (BCBS)
to identify areas where divergent AML/CFT rules or their implementation
cause friction for cross-border payments. The survey results highlight, among
others, that lack of risk-based approach and inconsistent implementation of
the AML/CFT requirements increases cost, reduces speed, limits access and
reduces transparency. Inconsistent national approaches also create obstacles in
identifying and verifying customer and beneficial owners, effective screening for
targeted financial sanctions, sharing of customer and transaction information
where needed, and establishing and maintaining correspondent banking
relationships.

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