Some indicators suggest that overall bank payment volumes are falling. However, the big banks have continued to see their volumes increase. Some of course have seen massive growth as a result of the mega mergers over the last twelve months. This increase in volumes isn’t going to make it easier to comply with sanctions regulations and some UK banks have already fallen foul of the US regulator and been subject to fines of hundreds of millions of dollars.

It also shouldn’t have gone unnoticed that earlier this year, the Financial Services Authority issued a report and guidance for firms because banks were failing to see the difference between suspicious activity detection and sanctions filtering. Many banks thought that their suspicious activity detection systems were also scanning all payments against the HM Treasury list but this wasn’t the case. Firstly, most suspicious activity systems operate overnight and would not stop a payment in real-time and secondly, these systems apply minimum amount thresholds and look at a composite risk score. This means that payments that should have been checked, were getting through.

The regulations and banks’ own attitudes to risk are changing. SEPA in Europe and NACHA in US require new types of payment to be scanned, not just the traditional cross border SWIFT messages.  In the current climate, banks must look beyond the short-term, quick fix solutions and think of the long-term gains of cost-effectiveness and efficiency. The opportunity lies in scaleable filtering that is truly able to scan millions of messages per day across multiple systems and taking advantage of new advances in filtering technology to massively decrease the number of false positives.

With regulatory requirements for increased levels of filtering only becoming more stringent and the financial landscape becoming increasingly risk-averse, this is a relatively simple measure to put in place and will go a long way to protecting the integrity and reputation of firms.