Changes to international payments
Important announcement for clients who make international
payments
In response to the attack on the United States
in September 2001 the Financial Action Task Force issued Special
Recommendation VII (FATF SR VII) with the objective of enhancing
the transparency of electronic payment transfers of all types,
domestic and international. The European Union (EU) has
adopted its version of FATF SR VII in a regulation passed in
November 2006 and the Isle of Man and Jersey have introduced their
regulation earlier this year in line with that EU legislation.
From 15 December 2007 it was made mandatory to
attach information about the payer on all international (ie,
cross-border) payments, subject to certain technical limitations.
We will be including your name, address and account number with any
international payments. This is to ensure we comply with the above
standards and reduce the potential delay or rejection of your
payment.
If you do not want your address to be included
with your international payments, then please contact us, in
writing, explaining why. Please write to our customer service
centre at St Mary’s Court, 20 Hill Street, Douglas, Isle of Man,
IM1 1EU. In this event, a Customer Identification Number (CIN) will
be substituted, as allowed by the regulation. The CIN will be
generated by us and be unique to you. Your CIN will be used
between us and the receiving bank for your international
payments only. Until a written request is received from you, we
will include your address on any of your international
payments.
The Data Protection Supervisors on the Isle of Man and Jersey
have commented that bank customers should be made aware that as a
result of these changes such personal information may be
transferred to countries which do not provide the same level of
protection for your personal information as we do and could be made
available to other legal or regulatory authorities.
Payments between the UK and its Crown
Dependencies (ie, Isle of Man, Jersey and Guernsey) are treated as
domestic payments and the regulations allow for reduced payer
information to accompany such payments, consisting of the payer’s
account number only, although by convention the payers name is
usually provided. We will attempt to provide reduced payer
information with domestic payments on a best endeavours basis.
It is possible that some receiving banks will
require details of the payer’s address, if it is not attached, and
the regulations allow for the transmission of such
information. In such an event, we retain the right to supply
your address to the receiving bank, in order to avoid your payment
being delayed or rejected.
We shall not be responsible for any losses,
costs, charges or other liabilities of any kind, if payments are
delayed or refused as a result of us acting on these new
standards.
Incorporated entities, trading names
and partnerships should note that the full entity names and the
normal correspondence address will be included with the payment to
fulfil the above standards.
If you have any queries, please do not
hesitate to call our client services centre on +44 (0) 1624
645000.