The imperative of building and fostering a strong compliance culture in the evolving cross-border payments space

Abstract

It is a period of substantial change for the ever-growing cross-border payments space, with numerous new trends emerging, along with new technologies, new market entrants and participants, and unprecedented regulatory collaboration around the G20 Roadmap for Enhancing Cross-border Payments. This paper discusses the drivers for the changes underway, explains the continued context of elevated compliance risks in the cross-border payments space, and calls for the entire ecosystem, including banks, service providers, new entrants and regulators, to focus on building and fostering a strong culture of compliance. This imperative is even more critical for new entrants who may not be subject to the same level of stringency within their current applicable regulatory regime and who may believe that this gives them more flexibility than other service providers. Building and fostering such a culture of compliance will have numerous benefits, including the reduction of crime. This paper argues that the universal commitment to such a culture of compliance among all parties involved in the ecosystem must begin with the adoption of an inquisitive compliance mindset, that is, a mindset that acknowledges the critical importance of compliance requirements, the rationale for their adoption and a willingness to ask questions and get detailed responses on an ongoing basis. Such a dynamic understanding would facilitate any future changes required by evolving regulations.