“The Australian banking industry is in the process of developing a service to enable large payers, such as corporate or government entities, to send an electronic payment that includes a secure hyperlink to a PDF document,” it said. “The provision of this functionality is part of a growing trend globally to improve efficiency and lower the costs of payment services by improving the amount and quality of data that are able to be transferred together with a payment.” The remarks were made in a submission [PDF] the RBA presented to a Senate committee probing the adequacy and efficacy of Australia’s anti-money laundering and counter-terrorism financing (AML/CTF) regime. It raised the payment feature while discussing the potential to whitelist some trusted payer entities.  “Some of these initiatives, such as the adoption of the ISO 20022 standard for payment message formats, provide for structured remittance data that make it easier and faster for systems to screen for financial crimes compliance,” the RBA said. Explaining how the feature works, the RBA said organisational payers that sign up to the “payment with document” service could optionally include a link to a document when sending a payment. A payee recipient would view the payment in their online banking channel and be able to click on that link, which RBA argued would provide secure, authenticated access to the PDF document associated with that particular payment. It said the documents would be held by accredited document host providers. “For example, if an Australian government agency utilised this service, myGov could store the documents and an authenticated link would provide direct access to the document on myGov,” the RBA said. According to the RBA, the payment with document service would provide benefits to both payers and payees. “It would be of particular value to a payer that sends a high volume of correspondence to recipients detailing information about their payments. There is often a lag between payment receipt and receipt of the related correspondence – this generates a high number of calls to customer call centres, which is expensive and inefficient to manage,” the RBA said. “A ‘payment with document’ service would also be valuable to payees, who could quickly and easily access correspondence directly from their banking app or online banking service to understand what the payment was for.” The Reserve Bank said providing detailed information with the financial transaction through electronic banking channels makes this information available for consideration by financial institutions in meeting their AML/CTF regulatory obligations. But, they will need to be able to screen any documents linked to a payment in order to meet these obligations, and the RBA said this solution does not appeal to all players. A possible solution, it said, would be to maintain a whitelist of trusted payer entities that provides relief to financial institutions from the requirement to screen documents linked to payments from those trusted entities. “Our understanding is financial institutions would welcome such a whitelist, as the cost and effort involved in screening all linked payment documents would be challenging,” the RBA wrote. This would mean correspondence sent with a payment by trusted entities, such as an Australian government agency, would remain private to the payment recipient, and banks would be permitted to access the document only in order to provide technical support services to the account-holder and only with the accountholder’s consent. A formal governance framework would need to be developed for this to occur, and the RBA proposed Austrac could be the authority over the scheme. The Legal and Constitutional Affairs References Committee kicked off the inquiry in June, which, among other things, seeks to determine the effectiveness of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 to prevent money laundering outside the banking sector, the attractiveness of Australia as a destination for proceeds of foreign crime and corruption, and Austrac’s role in policing such activity.

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