An International Initiative to Address Frictions in the Flow of Data Relating to Cross-border Payments

– Balancing Conflicting Obligations, Alignment and Interoperability: Publication of the FSB Final Report –

On December 12, 2024, the Financial Stability Board (“FSB”) published the “Recommendations to Promote Alignment and Interoperability Across Data Frameworks Related to Cross-border Payments: Final Report” (“Final Report”). Thereafter, on March 27, 2025, the FSB announced the establishment of the Forum on Cross-border Payments Data (“Forum”), a platform for dialogue, information exchange, and research on issues pointed out in the Final Report. The Final Report is a compilation of recommendations intended to mitigate unintended frictions impacting cross-border payments without compromising on the underlying objectives of data frameworks (as defined in section 3 below), such as the security of transactions, anti-money laundering/countering the financing of terrorism (“AML/CFT”), sanctions, and data protection and privacy rules; however, some of the approaches taken in the Final Report...To read the full article, please see the PDF file

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Authors

Chika IGARASHI

Partner
Tokyo

Chika Igarashi is a partner at Nishimura & Asahi specializing in the fields of (i) Banking and Financial Regulations. Chika also has extensive experience in advising a wide range of corporations on (ii) the countermeasures for AML/CFT (anti-money laundering/countering financing of terrorism) and foreign economic sanctions, including OFAC regulations; (iii) data privacy; (iv) global compliance and governance, including the establishment and implementation of whistleblowing and internal control systems; and (v) dispute resolution and crisis management involving cross-border aspects for corporate clients. She also advises corporations doing business in (vi) Africa and the Middle East.

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