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, and its cost is what makes small transactions uneconomic.

Advisory work replaces bilateral negotiation with a shared framework, tested once against both supervisory regimes.

What the work covers

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

What it does not cover

Advisory work is advice and arrangement. The local program provider 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.