The Clearing House Payments Company L.L.C. (TCH) submitted comments to the Financial Stability Board (FSB) regarding progress on the G20 Roadmap for Enhancing Cross-Border Payments. TCH urged the FSB, working with other public-sector stakeholders, including the Financial Action Task Force (FATF) and the Basel Committee on Banking Supervision, to prioritize progress in overcoming compliance-related friction in cross-border payments, as economic sanctions and anti-money-laundering and countering the financing of terrorism (AML/CFT) measures remain a challenge to faster, cheaper, and more transparent cross-border payments.

In its comments, TCH suggested three ways to reduce this friction:

1. Permitting cross-border payments to be screened at fewer points;
2. Shifting toward endpoint-based customer due diligence rather than individual payment-based compliance; and
3. Establishing a value threshold below which some degree of compliance relief is provided. 

TCH believes such steps would further the G20’s goals while maintaining an appropriate risk-focused approach to compliance.

To read the full comment letter, click here.