Publication of the updated Wolfsberg Group Payment Transparency Standards
Payment transparency can seem a very dry subject, but it is essential to the smooth functioning of the commercial world. Transparency is necessary, for example, to allow recipients to be able to apply incoming funds appropriately. Transparency is equally as important to managing financial crime risk, as it allows the screening of payments against sanctions lists and makes possible the process of transaction monitoring to identify unusual or suspicious activity, as required by law. If information about the transacting parties and the purpose of the payment are absent or incomplete, financial crime compliance processes will be made less effective and result in more friction, increased delays, and higher costs for all in processing payments.
Ensuring minimum levels of transparency and providing clarity about where these responsibilities lie is thus of great importance to all payment service providers. This challenge has grown greater as payment innovation has resulted in new ways of moving funds. There is more widespread use of bundling of payments (the aggregation of more than one payment into a single transfer that may also be referred to as batch, bulk, or netting), as well as an increase in the number of and types of payment service providers (e.g. banks, MSBs, third party payment processors or TPPPs, fintechs, etc.). Moreover, value and the information about that value (i.e. details of underlying bundled payments) may not move in the same message or through the same channels. This subject has become more complex and nuanced since 2017, when the Wolfsberg Group published its Payment Transparency Standards. Therefore, today we are pleased to be publishing updated Payment Transparency Standards that:
· Broaden coverage from financial institutions to all types of payment service providers and use the ISO 20022 terms. · Expand the list of stakeholders to include payment market infrastructures and competent authorities, who we believe should be involved in defining how their systems should (and should not) be used. · Affirm that all payments should be treated equally regardless of the type of entity processing them, and that the entity initiating the payment flow should have the primary obligation to ensure transparency. · Address the fact that certain intermediaries in the payment flow, by nature of the limited information they see in the normal course of business, should not be held accountable for the transparency and compliance obligations of the entity initiating the flow. · Provide illustrated examples of real-world payment chains highlighting their inherent transparency challenges.
We hope these updated Standards serve to enhance the understanding of this subject, provide practical guidance to payment service providers, and help inform the dialogue on the roles and responsibilities of all relevant stakeholders.