Steps 10-11: Sanctions screening
The sanctions screening requirement
All cross-border payments through Nexus will need to be screened by the PSPs involved in a payment against the sanctions lists that apply in their jurisdiction (‘sanctions screening’).
In most cases, sanctions screening software used by the PSP will first compare the name of the Sender or Recipient and look for similar names on the sanctions lists. If a positive ‘hit’ is found, the software can use additional data, such as address, date and place of birth, or national identity number, to confirm whether the Sender or Recipient is actually the person on the sanctions list or just a similar name (a “false positive”).
FATF’s Recommendation 16 requires the following information to be included in cross-border payments:
| SENDER | RECIPIENT |
|---|---|
|
|
Additional requirements may apply in each jurisdiction. For example, a particular country might define the Debtor > Postal Address element to be mandatory.
Each IPS can define this required information in Nexus so that it can be shared with PSPs in the response to GET /countries.
The PSP should therefore ensure that all pacs.008 payment instructions to Nexus include the Recipient’s name and account number as a minimum. Adding further information in addition to the name will reduce the likelihood of the payment triggering a false positive alert and being delayed.
Step 10: Review the data available for sanctions screening; ask the Sender for Recipient data if necessary
The PSP should now review the acmt.024 response to confirm whether:
Name is present
Account number is present
If the Name element is blank, the PSP must display a form asking the Sender for the Recipient’s full name. (The Recipient’s name is required as a minimum, in line with FATF Recommendation 16.)
Failure to include the Recipient's name is likely to result in the payment failing the sanctions screening of PSPs and and the payment being rejected.
The Source PSP can display fields for them to enter the Recipient’s address. The Source PSP should check the information it received from GET /countries/{countryCode}/ to establish if these additional fields are mandatory in the Destination IPS.
Although the Source PSP could also ask for Date and Place of Birth and National Identity number, Recipients may be uncomfortable with sharing this information directly with the Sender. (In contrast, when the Destination PSP shares the information in response to an acmt.023 account resolution request, the information is shared securely through Nexus and not shown to the Sender, except for the display name).
Step 11: Screen the payment against applicable sanctions lists
Before the PSP send the payment instruction the Source PSP will need to screen the Recipient against the sanctions lists applicable in the PSP’s jurisdiction. (It is assumed that the Source PSP has already screened the Sender as part of the PSP’s regular KYC, AML and screening processes.)
This step can be done later if the PSP's screening software requires a complete pacs.008 payment instruction.
If the Destination PSP supports the acmt.023/acmt.024 account resolution process, Nexus will already have issued a acmt.023 request to the Destination PSP during the proxy and account resolution process.
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