TCH submitted comments in response to recommendations by the Financial Stability Board (FSB) to promote alignment and interoperability across data frameworks related to cross-border payments. In addition to supporting the proposed establishment of a new forum focused on data framework issues, TCH emphasized the need to (1) better balance U.S. supervisory expectations for sanctions screening with the public policy objectives of the G20 cross-border payments initiative; (2) harmonize the meaning and use of ISO 20022 elements for financial crimes purposes; and (3) explore ways to prevent fraud in cross-border payments that will not have the very significant negative impacts on payment processing as FATF’s proposed requirement for beneficiary banks to check the alignment of beneficiary information. 
 
A copy of the letter may be found here.