The Clearing House Association, L.L.C. (TCH) provided recommendations to the Financial Stability Board (FSB) for reducing compliance related frictions for cross-border payments. The recommendations are intended to assist the FSB as it advances work that focuses on the legal, regulatory, and supervisory frameworks for cross-border payments. TCH emphasized the need to balance supervisory expectations for sanctions screening with the public policy interest for faster, cheaper cross-border payments. In particular, TCH explained how supervisory expectations for edge-case, fuzzy logic sanctions screening and extensive documentation for alert handling have significant impact on the cost and speed of cross-border payments. TCH’s recommendations include both public sector and private sector solutions to sanctions screening frictions.
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