Obligations on the SAP

The Nexus Scheme Rulebook provides detailed obligations for Settlement Access Providers. At a high level, these obligations include:

Account management

• The SAP must provide the FXP with an account denominated in the domestic currency, and the tooling to manage the balance on the account. This may be the same tooling as supplied by the SAP to other (corporate) clients.

Due diligence on FXPs

• The SAP needs to onboard the FXP and comply with local laws and regulations, including (but not limited to) due diligence on the FXP. Depending on the local legislation, this process may be different than onboarding other corporate clients.

• The SAP should accept the Wolfsberg Correspondent Banking Due Diligence Questionnaire (CBDDQ) template from FXPs, and not require FXPs to use a non-standard process for collecting due diligence information.

Compliance & sanctions screening

• SAPs must comply with all applicable regulations in the jurisdiction they are based in. The SAP must ensure that any applicable compliance checks are completed before approving the payment. Depending on local regulations, this typically includes screening against the sanctions lists applicable in the SAP’s jurisdiction. If there are no local requirements for screening for the SAP in the local jurisdiction, this is not required by Nexus.

• If local regulations do not permit the SAP to rely on screening done by the Source or Destination PSP, then the SAP must have real-time sanctions screening ability.

• The SAP must ensure that its internal systems can handle and process the Nexus payment messages, which may be more data-rich than the domestic format.

Testing

• The SAP must undertake a robust testing process with the IPS Operator and FXP to ensure that all systems are working as expected before go-live and before any significant change.

Minimum commitment

• SAPs must commit to providing services to an FXP and must give a period of notice if they wish to stop providing those services. This is to avoid unexpected disruption to Nexus payments, which could occur if an SAP withdrew its services at short notice.

Pricing

• The SAP has total discretion over whether it offers services to a specific FXP or not, and on what terms. The terms of service between the SAP and FXP will be agreed bilaterally, outside of the Nexus Scheme.

Fees

• The SAP is not allowed to deduct fees from the value of the payment transferred; it must pass on the funds in full.

• Any fees charged by the SAP to the FXP must therefore be charged separately and paid by the FXP to the SAP outside of the Nexus scheme.

Allowing payment reversals

• When a Nexus Payment fails to complete correctly in the Destination IPS:

  • the Destination SAP has the obligation to return the funds already debited from an FX Provider to that same FX Provider.

  • the Source SAP has the obligation to allow the Source IPS to return funds that were credited to the Source SAP back to the Source PSP

The following obligations will be taken care of by Nexus:

• After each successfully completed Nexus payment, Nexus will notify the FX Provider of the amount and currencies of the payment.