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How the LEI Can Help Financial Institutions ‘Address’ a Growing Challenge in ISO 20022

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The vast complexity and inconsistency of address formats globally presents significant challenges for financial institutions. In this blog, GLEIF’s Head of Business Operations, Clare Rowley, explores why the ability to map relevant address fields from Legal Entity Identifier (LEI) reference data into the ISO 20022 messaging format is a powerful means of improving data quality, helping to bolster the global fight against financial crime and promote faster, cheaper, and more transparent and inclusive cross-border transactions.

Addresses are foundational to the global economy. As noted by the Universal Postal Union, “addresses form an important part of the basic information needed to ensure communication (both digital and physical) between individuals, governments, and organizations.”

Given the fundamental role in enabling legitimate access to global commerce, incorrect, incomplete, or incongruous address information is often seen as a ‘red flag’ signaling nefarious activity within cross-border payments. The Financial Action Task Force (FATF) Recommendations, which set out a comprehensive and consistent framework of measures to combat money laundering, terrorist financing, and the financing of the proliferation of weapons of mass destruction, make this clear. Specifically, FATF Recommendation 16 aims to ensure that basic information (including address) on the originator and beneficiary of wire transfers is immediately available and included within the payment message.

Address formats and payment messages

Yet the inclusion of address information within a payment message, where every extra byte increases costs and reduces speed, presents particular and unique challenges. Address structures are wildly inconsistent across countries and jurisdictions and can be unfathomably complex, given the vast array of potential combinations. Cross-border payments compound this complexity. These transactions often involve organizations with addresses in different languages, formats, and colloquial styles.

In a bid to accommodate, payment messaging standards have favored character-limited free text lines or open fields for address information. While this approach offers a degree of flexibility (to account for the inherent variability), it also resists automation and thus inhibits straight-through processing (STP) because manual intervention is often required.

The ISO 20022 messaging standard aims to solve this problem through the introduction of highly structured, discrete, character-limited elements for specific address information, reflecting a broader drive for more consistent and structured data in payment processing to promote greater interoperability in cross-border payments and beyond.

As of today, the following address fields have been defined within ISO 20022:

  • Address Type
  • Address Line
  • Department
  • Sub Department
  • Street Name
  • Building Number
  • Building Name
  • Floor
  • Post Box
  • Room
  • Postcode
  • Town Name
  • Town Location Name
  • District Name
  • Country Sub Division
  • Country

While such highly specified address structures are undoubtedly useful in some domestic use cases where, for example, entities share the same address formats and language, cross-border payments reveal limitations.

This is hardly surprising; it would be practically impossible to provide standardized fields for every conceivable variation in physical address structures globally. To take one real-world example, an entity whose address is listed as the third floor of a building, within a golf course, close to a business park, near a ring road. Similarly, what is the practical, scalable solution for jurisdictions where street names are uncommon and addresses must be described in terms of proximity to local landmarks (i.e. 75 meters north and 50 meters east of a Church)? Add in the need to parse different languages and writing systems, and it is apparent that different organizations are not going to interpret addresses the same way.

Mapping the LEI to ISO 20022

Rather than add further structured fields in response to outliers (which stand to only contribute to further complexity), overcoming this problem requires a common, globally consistent starting point. This is especially true for the creditor address data information in cross-border payment transactions. While debtor address information can be sourced from the debtor agent’s KYC master records, the debtor interpretation of the creditor address into the ISO 20022 format is recognized as being ‘problematic’.

Happily, such a common, globally consistent starting point for address information already exists within the Legal Entity Identifier (LEI). The LEI is a 20-character, alpha-numeric code that connects to key reference data, including address information, that enables clear and unique identification of all entities participating in a financial transaction.

In comparison to the highly structured ISO 20022 address format, the LEI is more streamlined and minimally structured to account for the significant variability and flexibility. This is particularly important in the context of cross-border payments, where differences in address format are guaranteed. While this means that the format of the structured address within the LEI does not match exactly the format of the structured address within an ISO 20022 payment message, the LEI Index can be used to map LEI address data into the ISO 20022 format.

Put simply, the LEI address information should be considered compliant with ISO 20022, and relevant address fields can be retrieved from the LEI reference data in an automated manner to reduce ambiguity and enable STP.

GLEIF provides this mapping here and highlights the opportunity for financial institutions to reduce the complexity of structuring beneficiary customer information by leveraging the LEI as the organizational identifier for the beneficiary. This will “reduce the touch points and impact on clients, optimize resources and investments while enabling the bank to provide significant improvement in client experience.”

GLEIF has also received direct industry feedback from financial institutions flagging that it would be helpful and logical to leverage the LEI reference data to meet ISO 20022 requirements on customer’s address since the LEI is mandatory for most of these messages.

Supporting the global fight against financial crime

The ability to map LEI address data into the ISO 20022 format has important implications. The challenges of address validation are emblematic of an increasingly pressing need to improve data quality to bolster the global fight against financial crime. Project Aurora – an analysis by the Bank of International Settlements (BIS) Innovation Hub – identified ‘data quality and standardization of the data identifiers and fields’ contained within payment messages as key factors. This echoes the findings of the FATF, which has flagged data-sharing, data standardization, and advanced analytics as underpinning effective anti-money laundering (AML) and counter-terrorist financing (CTF) initiatives across borders.

Given this directional trend, leveraging the LEI to overcome challenges in interpreting address information stands to become a powerful way to align with emerging regulation. Looking more broadly, the LEI offers unique benefits to support globally standardized, lightweight, efficient payment messages that can be fully automated, helping to realize the promise of faster, cheaper, and more transparent and inclusive cross-border transactions.

For this reason, GLEIF has engaged extensively with various stakeholder groups across the industry on the Bank for International Settlements’ Committee on Payments and Market Infrastructures (CPMI) consultation on ISO 20022 harmonization requirements, advocating that the LEI be introduced as the identifier of the debtor/creditor in payment messages and be allocated the same status as the Business Identifier Code (BIC) regarding the substitution of name and postal address.

GLEIF has also highlighted an unmissable opportunity to consider the use of the LEI in the planned review of FATF Recommendation 16. GLEIF posits that where the originator or beneficiary is a legal entity, a trust, or any other organization that has legal capacity under national law, the LEI should be included within the information accompanying the qualifying wire transfer.

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Unified ticketing: how can transport stakeholders ensure interoperability?

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Arnaud Depaigne, Product Manager – Smart Mobility, and Taoufik Sakhi, VP Deputy – Technical Advisory at Fime

 

Public Transport Operators and Authorities (PTOs / PTAs) are under constant pressure to deliver a reliable service. And with different passenger groups to consider, each with unique demands, operators must develop smarter and more innovative ticketing experiences to keep up with the rapidly evolving smart mobility landscape.

PTOs and PTAs must work with other stakeholders in the transit ecosystem to create solutions while navigating incumbent systems, funding concerns and ever-changing political challenges. All of this must be considered while ensuring that ticketing systems meet the needs and expectations of passengers. In the second blog in our series on unified and interoperable ticketing, we will explore the factors that transport stakeholders must consider when implementing a unified ticketing approach.

Political and administrative considerations

Public transport is by its very name public. Be it operated by governmental organizations (at either the local or national level) or by private enterprise, it remains at its heart a public service. This means that it is subject to the scrutiny and regulation of local and regional decision makers and is often at the center of legislative discussions.

Political representatives frequently champion policies that directly impact transit networks. A common example of this is promoting free or concessionary fares for youth, students and seniors. Others may endorse large-scale infrastructure projects or network overhauls as part of their campaigning. However, this can also go the other way, with certain candidates advocating defunding or eliminating transit projects entirely.

This creates an even greater challenge when a network extends across two or more administrative boundaries. Two neighboring areas may have administrations which prioritize public transport differently. This can mean a network must deal with discrepancies between investment in modern infrastructure, funding and fare concessions. By adopting a unified ticketing model, transport stakeholders can work together to develop an interoperable regional network while remaining compliant with legislated priorities, as well as encouraging a modal shift away from private vehicle usage.

Funding to cost saving

The budget a network must work within is another major differentiator between networks. As mentioned above, the local government often has a large role in dictating this, but other factors such as ridership and ticket sales can have a significant impact too. Funding can also be obtained through Public-Private Partnerships (PPPs), which may require the operator to work within a framework dictated by a third party to achieve certain profitability targets.

Another concern is legacy debt and the available cash flow of a network. The timelines for implementing a new ticketing system are typically quite long, as specifications and deployment plans need validation from multiple stakeholders. These can include the national and local authorities, employee unions and passenger unions in addition to PTA, PTOs and suppliers. Engaging these stakeholders at the build stage can be crucial to reducing costs later on. In doing so, a system can be designed to meet user needs without unnecessary complexity, helping reduce potential project expenditures and the technical risks of integration. During the run phase, it enables more flexible equipment procurement and operational efficiency while also improving maintenance and staff skill management between operators.

Working within a fragmented market

Unlike the telecommunications or payments ecosystems, there is no globally recognized initiative for the standardization of ticketing. Initiatives such as ISO 14443 (contactless proximity cards), ISO 24192 (communication between contactless readers and fare media in public transport), CSN EN 12896 (Reference data model – Transmodel), CEN/TS 16614 (Public transport network topology exchange format- NeTEx), General Transit Feed Specification (GTFS) and others, have attempted to create consistency. However, each of these allows for an element of interpretation to account for local needs and requirements.

Furthermore, incumbent ticketing solutions have most likely been developed by market leaders in each region over a number of decades. These solutions each have their own design choices, with decisions driven by industrial optimization. Upgrades to stay in line with contemporary norms are often expensive. Additionally, meeting new operational requirements while keeping incumbent systems up and running can drastically lengthen the migration process.

While migrating to unified ticketing may require a significant effort to begin with, the long-term benefits make it worth it, as PTOs and PTAs are prepared for potentially the next decades of operations and upgrades. It places PTAs and PTOs in a strong position to protect their sovereignty, supported by industry leaders championing open standards. Unified ticketing development can pool the resources of operators and authorities, accompanied by partners that will manage integration and implementation with minimal disruption to the existing ticketing systems.

Finding the right solution

PTOs, PTAs and transit solution providers undoubtedly have a complex task designing and implementing flexible, scalable ticketing solutions. They must meet the evolving demands of customers while navigating numerous legislative and regulatory requirements dictated to them by local authorities. Unified ticketing is a way that resources can be combined and optimized to help provide a quality service and achieve operational efficiencies while keeping on track for their profitability targets.

Fime can work alongside multiple operators to guide them through the process of pooling their resources to create a unified ticketing system that works. This ensures that they meet the technical and quality standards they pride themselves on, while also complying with their transit policy and budget constraints.

Learn more about how Fime can help you accelerate your ticketing offer to create frictionless unified ticketing for passengers.

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Provenir and Trustfull Agree Global Partnership

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Trustfull and Provenir to deliver innovative risk decisioning using digital footprints via new global partnership.

Trustfull, the digital risk decisioning platform and Provenir, a global leader in credit and fraud risk decisioning technology have announced a global partnership that sees Trustfull joining Provenir’s Data Marketplace.

Trustfull enables companies to leverage the power of alternative data and digital footprint analytics to enhance their identity screening, prevent fraud, and improve digital onboarding experiences through advanced trust and risk signals coming from email, phone number, IP address, device, and browser data.

Provenir is a global leader in credit and fraud decisioning solutions that enable financial services organisations to redefine customer decisioning by optimising any decision across the customer journey. With a low-code UI,  dynamic data orchestration, and flexible analytics deployment, Provenir’s AI-powered decisioning platform powers enhanced decisioning accuracy, speed and agility.

Provenir’s Global Data Marketplace brings together offerings from data partners around the globe and creates an ecosystem for organisations that are seeking an easy-to-use cloud solution for data consumption across their decisioning processes. With fully maintained API connections to both traditional and alternative data providers, organisations can easily add and test new data sources in minutes.

The synergy created from this partnership will provide clients access to a vast array of data sources, including new alternatives from social and web apps, telco data, among others — all seamlessly integrated with the Provenir decisioning engine, enabling clients to make smarter risk decisions faster. Most importantly, Trustfull clients will benefit from a data source that is truly global, allowing integration with any international market.

“We’re excited to welcome Trustfull to the Provenir Marketplace as we see increasing demand from clients on new sources of digital signals to further verify identity and prevent fraud,” said Carol Hamilton, Chief Product Officer at Provenir. “Trustfull’s solution brings a unique blend of data sources, accuracy, and risk scoring that is perfectly aligned with the Provenir decisioning technology.”

Alex Tonello, Chief Revenue Officer at Trustfull said about the partnership: “This strategic collaboration with Provenir is perfectly aligned with Trustfull’s ambition to become the preferred destination for enterprise clients seeking technology to support more accurate risk decisions, especially during a pre-KYC screening phase. Most importantly, the partnership offers clients an easier, single point of integration for organisations looking for comprehensive risk orchestration.”

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