The Wolfsberg Group (the Group) has prepared this guidance to supplement, and be read in conjunction with, the Wolfsberg Group Payment Transparency Standards published in October 2023. Payments can flow in a variety of ways and involve many types of payment service providers (PSPs)¹, messaging systems and payment market infrastructures (PMIs). The purpose of this document is to provide an overview of the roles played by key actors in a payment chain. It also sets out their respective responsibilities to adhere to payment transparency standards across a sample of commonly observed payment flows and serves as a reference guide that can be used by all PSPs, regulators and standard setters. The Group acknowledges that there are wider responsibilities of PSPs not described in this document and that all PSPs are required to comply with applicable laws and regulations so as to maintain effective Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) programme controls. References in this document to monitoring refer to real-time or ex-post monitoring as may be required by applicable laws and regulations. The roles and responsibilities of actors in the payment flow apply to all actors regardless of the entity type or their corporate affiliation. Note: this document is not intended to:

• • Describe all the possible permutations of how a payment can be made
• • Set out the detail of controls that are part of a PSP’s wider financial crime risk management programme including, but not limited to, Know Your Customer (KYC)/Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), sanctions compliance (which depends on payment messages being transparent), transaction monitoring and record keeping
• • Cover every role and every actor that could be involved in a payment flow
• • Cover every responsibility of every actor in the payment chain
• • Cover the nature and timing of the flows of information arising from a request for information (RFI) process.

Overview of content:

Table 1. Simplified payment flow – roles and responsibilities matrix

Example of a cross-border payment between two countries (country A and B), two parties and with no intermediaries (and not a direct debit transaction). The parties outlined in Table 1 are present in all cross-border payments irrespective of the number of intermediary PSPs involved.

Table 2. Intermediary agent PSPs – varying roles and responsibilities

This table gives examples of three different ways in which an intermediary agent PSP can be involved in a payment to draw attention to what information is available to each actor from the payment message and what responsibilities they have in relation to payment transparency requirements. As set out in the Introduction, it does not consider what additional information might be available from the RFI process. All intermediary agent PSPs have an obligation to monitor for manifestly meaningless or incomplete information in payment messages as may be required under applicable local laws, regulations and taking into consideration relevant guidance and to adhere to Basel Committee on Banking Supervision guidance as appropriate. Not all payment flows will include intermediary agent PSPs and not all types of intermediary agent PSPs depicted below will necessarily be present.

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Footnotes

1. In this document, PSP is used to capture the full spectrum of payment service institutions that provide fund transfers, to include credit transfers, direct debit, money remittances whether domestic or cross-border, and transfers carried out using a payment card, an electronic money instrument, mobile phone, or any other digital or IT prepaid or postpaid device with similar characteristics. This includes traditional banks and money service businesses (MSBs), as well as entities commonly referred to as third party payment processors and electronic money institutions, among other PSP types. ↩