Cross-border regulatory and compliance advisory

The obstacle to cross-border retail payment is rarely technical. It is that two institutions, supervised by two different authorities, must each satisfy themselves about the other before a single transaction moves. Done bilaterally, that negotiation is repeated for every pair of banks and every corridor.

What the work covers

• Mapping the regulatory perimeter in each jurisdiction, including exchange control, data residency and consumer protection.
• Preparing the position taken to each supervisor, and supporting member banks in their engagement with the central bank.
• Harmonising customer due diligence, sanctions screening and transaction monitoring between institutions.
• Drafting the framework agreements the two banks sign with each other, and the membership agreement with HAEMPCS.
• Advising on alignment with FATF recommendations on wire transfers and beneficial ownership.

What it does not cover

Advisory work is advice and arrangement. HAEMPCS does not obtain, hold or share a financial services licence, does not act for a bank before its regulator, and does not assume any part of a member bank’s regulatory obligation.