Wire Transfer Regulations (WTR2)

Introduction

The new Wire Transfer Regulations (WTR2) came into effect on June 26, 2017. The regulations require that accurate payer and beneficiary information accompanies the transfer of funds in order to further combat financial crimes and money laundering.

From October 11, 2017, payer detail fields will be mandatory on the Currencycloud platform to ensure WTR2 compliance.

What does this mean for Currencycloud clients?

The following information on Payers will be mandatory regardless of the type/origin/destination of the payment.

Payer (Individual)

  • First Name
  • Last Name
  • Full Address
  • Date of Birth

Payer (Company)

  • Company Name
  • Full Address

Note: The above is the minimum set of information required for all payments. Some payment types/currencies may have additional requirements.

How this affects the way you instruct payments

We have made several updates to our API and Currencycloud Direct to ensure clients can provide the required information while creating a payment and conform to regulation.


WTR2 changes to the API

Payer Required Details API

Similar to the existing Beneficiary Required Details API, a new API call (Payer Required Details API) is now available to let you get the required payer details and their basic validation formats.

get /v2/reference/payer_required_details

Key Type Value Required
payer_country string GB required
payment_type string “priority” or “regular” required
payer_entity_type string “company” or “individual” required

Below is an example of a call and response:

Call:

/reference/payer_required_details?&payer_country=GB& payment_type=priority

Response:

<br /> {<br /> "details": [<br /> {<br /> "payer_entity_type": "company",<br /> "payment_type": "priority",<br /> "required_fields": [<br /> {<br /> "name": "payer_country",<br /> "validation_rule": "^[A-z]{2}$"<br /> },<br /> {<br /> "name": "payer_city",<br /> "validation_rule": "^.{1,255}"<br /> },<br /> {<br /> "name": "payer_address",<br /> "validation_rule": "^.{1,255}"<br /> },<br /> {<br /> "name": "payer_postcode",<br /> "validation_rule": "^.{1,255}"<br /> },<br /> {<br /> "name": "payer_company_name",<br /> "validation_rule": "^.{1,255}"<br /> }<br /> ]<br /> },<br /> {<br /> "payer_entity_type": "individual",<br /> "payment_type": "priority",<br /> "required_fields": [<br /> {<br /> "name": "payer_country",<br /> "validation_rule": "^[A-z]{2}$"<br /> },<br /> {<br /> "name": "payer_city",<br /> "validation_rule": "^.{1,255}"<br /> },<br /> {<br /> "name": "payer_address",<br /> "validation_rule": "^.{1,255}"<br /> },<br /> {<br /> "name": "payer_postcode",<br /> "validation_rule": "^.{1,255}"<br /> },<br /> {<br /> "name": "payer_first_name",<br /> "validation_rule": "^.{1,255}"<br /> },<br /> {<br /> "name": "payer_last_name",<br /> "validation_rule": "^.{1,255}"<br /> },<br /> {<br /> "name": "payer_date_of_birth",<br /> "validation_rule": "/A([+-]?d{4}(?!d{2}\b))((-?)((0[1-9]|1[0-2])(\u0003([12]d|0[1-9]|3[01]))?|W([0-4]d|5[0-2])(-?[1-7])?|(00[1-9]|0[1-9]d|[12]d{2}|3([0-5]d|6[1-6])))([T ]((([01]d|2[0-3])((:?)[0-5]d)?|24:?00)([.,]d+(?!:))?)?(\u000f[0-5]d([.,]d+)?)?([zZ]|([+-])([01]d|2[0-3]):?([0-5]d)?)?)?)?Z/"<br /> }<br /> ]<br /> }<br /> ]<br /> }<br /> 

Create/Update a Payment API

Until now Payer details have been mandatory only for priority (SWIFT) and certain regular (Local) payments. However, payer details will now be mandatory for all payments regardless of the type/origin/destination of the payment. If any of these details are missing you will not be able to instruct payments.

The “Payer” is considered to be the individual or entity from where a particular payment originates. Depending on the payment model you operate, the payer will either be you or your client on whose behalf you are instructing the payment.

The exact information required can be determined by calling the Payer Required Details API. All relevant fields enabling you to submit payer details are already available on the Create/Update Payment API.

1. Making payments where you are the payer

When you send funds to Currencycloud for conversion on your own behalf and instruct a payout to the ultimate beneficiary, you are considered the payer.

Flow of funds Currencycloud Client as Payer

Typically, you will fall under this operating model if you are a:

  • Marketplace paying out to corporates/individuals
  • Corporate/Individual making payments on your own behalf
  • Prepaid card firm sending funds to issuers
  • PSP acquiring card payments and paying out to merchants

There is no requirement to explicitly provide payer details in each payment. This information will be taken automatically from the details on your account. Please ensure that the Name, Address and Date of Birth (if applicable) on your account are provided and up to date. If any of these details are missing, you will not be able to instruct payments starting October 11, 2017, once payer details become mandatory.

2. Making payments where your client is the payer

Your customer is considered the payer when you collect funds from your customers and send to Currencycloud for conversion and payout to the ultimate beneficiary.

Flow of funds Currenycloud Client’s Customer as Payer

Typically, you will fall under this operating model if you are a:

  • FX Broker making payments on behalf of your customers
  • Remittance/International Payments firm providing payments functionality to your customers via Currencycloud

You must provide the details of your customer in the Payer fields at the time of creating a payment using the “Create a Payment” API. Please ensure that the Name and Address on your account are also provided and up to date. If any of these details are missing you will not be able to instruct payments starting October 11, 2017, once payer details become mandatory.

Create/Update Account API

In order to ensure that all new accounts have the required WTR2 information, the following fields which were optional on the create and the update account APIs are now required. As a result, you will not be able to create or update an account without providing these details:

  • street
  • city
  • country
  • state_or_province – required only for US, Mexico and Canada

Create/Update Contact API

In order to ensure that all new accounts have the required WTR2 information, the Date of Birth field on the Create and the Update Contact APIs is now required. As a result, you will not be able to create or update a Contact without providing the Date of Birth.

Note: This only applies when the Contact belongs to an “individual” type of account.


WTR2 changes to Currencycloud Direct

Create a payment

Until now, Payer details have been mandatory only for priority (SWIFT) and certain regular (Local) payments. However, payer details will now become mandatory for all payments regardless of the type/origin/destination of the payment. If any of these details are missing you will not be able to instruct payments.

The “Payer” is considered to be the individual or entity from where a particular payment originates. Depending on the payment model you operate, the payer will either be you or your client on whose behalf you are instructing the payment.

1. Making payments where you are the payer

When you send funds to Currencycloud for conversion on your own behalf and instruct a payout to the ultimate beneficiary, you are considered as the payer.

Flow of funds Currencycloud Client as Payer

Typically, you will fall under this operating model if you are a:

  • Marketplace paying out to corporates/individuals
  • Corporate/Individual making payments on your own behalf
  • Prepaid firm sending funds to issuers
  • PSP acquiring card payments and paying out to merchants

There is no requirement to explicitly provide payer details in each payment. At the time of creating a payment, select “Yes” under the “I am the Payer” field.

 

Payer information will be taken automatically from the details on your account. Please ensure that the Name, Address and Date of Birth (if applicable) on your account are provided and up to date.If any of these details are missing you will not be able to instruct payments starting October 11, 2017, once payer details become mandatory.

2. Making payments where your client is the payer

Your customer is considered the payer when you collect funds from your customers and send to Currencycloud for conversion and payout to the ultimate beneficiary.

Flow of funds Currencycloud Client’s Customer as Payer

Typically, you will fall under this operating model if you are a:

  • FX Broker making payments on behalf of your customers
  • Remittance/International Payments firm providing payments functionality to your customers via Currencycloud

You must provide the details of your client in the Payer fields at the time of creating a payment by selecting “No” under the “I am the Payer” field.

Flow of funds Currencycloud Client as Payer View

You will then be shown the required fields that need to be completed for the payer depending on the Payer Type.

Please ensure that the Name and Address on your account are also provided and up to date. If any of these details are missing you will not be able to instruct payments starting October 11, 2017, once payer details become mandatory.

Create/update account

In order to ensure that all new accounts have the required WTR2 information, the following fields which were optional to create and update an account are now required. As a result, you will not be able to create or update an account without providing these details.

  • Street
  • City
  • Country
  • State or Province – required only for US, Mexico and Canada

Create/update contact

In order to ensure that all new accounts have the required WTR2 information, the Date of Birth field is now required when you create or update a Contact. As a result, you will not be able to create or update a Contact without providing the Date of Birth.

Note: This only applies when the Contact belongs to an “individual” type of account.

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