Key challenges for complying with SCT Instant regulations
Payments must be processed and funds made available to the beneficiary within 10 seconds end-to-end, from the initiating financial institution to the receipt of the approval or rejection by the payer.
The initiating entity needs to notify the originating party that the funds have been successfully delivered to the beneficiary within the 10-second processing window.
VoP will be required on all SCT payments, including SCT Instant, even if the payer is sending a payment to a pre-registered, whitelisted payee. This requires the ability to query payee information from the scheme or a third-party vendor solution to perform the verification before the customer initiates the transfer.
Although sanctions screening is not required in real-time for incoming and outgoing SCT Instant, entities will be required to screen their customers on a daily basis.
This ensures that the originating party of an SCT Instant will have been screened within the past 24 hours, limiting the likelihood of SCT Instant payments being sent by individuals on sanction lists. Sanctions screening is typically done using a fraud and compliance solution.
A daily, 365-day-a-year process will be needed to ensure that the originating party reference information is updated as soon as the sanction screening has been performed, blocking the possibility of initiating an SCT Instant payment in case of a screening match.