Regulations and Compliance in Treasury

KYC, AML, and sanctions compliance form a critical part of treasury’s interaction with banks and financial institutions.

They are not optional, not occasional, and definitely not quick.

These frameworks exist to prevent financial crime, ensure transparency, and protect the integrity of the financial system. For treasury, they translate into ongoing obligations that affect daily operations.

What KYC, AML, and Sanctions Mean

• KYC (Know Your Customer)
  Banks need to understand who they are dealing with. This includes ownership structures, business activities, and key stakeholders. 
• AML (Anti-Money Laundering)
  Ensures that financial systems are not used to move illicit funds. 
• Sanctions compliance
  Prevents transactions with restricted countries, entities, or individuals. 

Together, they create a framework of checks that companies must comply with when working with financial institutions.

Why This Matters for Treasury

Treasury sits at the centre of:

• Bank account management 
• Payments and collections 
• Counterparty interactions 

Which means it is directly impacted by KYC, AML, and sanctions requirements.

Without proper compliance:

• Bank accounts cannot be opened or maintained 
• Payments may be delayed or blocked 
• Relationships with banks can deteriorate 

In extreme cases, access to banking services can be restricted.

KYC: The Ongoing Process

KYC is not a one-time onboarding exercise.

Banks require:

• Corporate structure documentation 
• Ownership details (often up to ultimate beneficial owners) 
• Identification documents 
• Business activity descriptions 

And they require updates:

• Periodically 
• When company structures change 
• When new entities are added 

Treasury often manages this process, coordinating with legal and compliance teams.

It’s time-consuming, repetitive, and unavoidable.

AML Controls and Monitoring

AML frameworks focus on detecting suspicious activity.

Banks monitor:

• Transaction patterns 
• Unusual payment flows 
• Counterparty behaviour 

Treasury needs to ensure:

• Transactions are consistent with business activity 
• Documentation supports payments 
• Processes are transparent 

Unexpected or unclear transactions can trigger:

• Payment delays 
• Requests for additional information 
• Increased scrutiny 

Which slows down operations.

Sanctions Screening

Sanctions compliance involves checking:

• Payment beneficiaries 
• Counterparties 
• Countries involved in transactions 

Against official sanctions lists.

This is often automated by banks and systems, but treasury still needs to:

• Ensure accurate data 
• Validate counterparties 
• Manage exceptions 

A flagged transaction can:

• Be delayed 
• Be rejected 
• Require manual review 

Timing becomes unpredictable when sanctions checks are triggered.

Impact on Payments and Operations

KYC, AML, and sanctions directly impact:

• Payment execution times 
• Onboarding of new suppliers or customers 
• Opening new bank accounts 
• Expanding into new markets 

What looks like a simple operational step can become a multi-week process due to compliance checks.

This is where treasury needs to plan ahead.

Data and Documentation

Compliance relies heavily on documentation.

Treasury needs to maintain:

• Up-to-date corporate records 
• Ownership structures 
• Counterparty information 
• Supporting documents for transactions 

Incomplete or outdated data leads to:

• Delays 
• Repeated requests 
• Increased friction with banks 

Where It Goes Wrong

Some common issues:

• Underestimating the time required for KYC processes 
• Incomplete or inconsistent documentation 
• Poor coordination between departments 
• Lack of central ownership 
• Treating compliance as a one-off task 

These issues create delays and frustration. Usually at the worst possible moment.

Treasury’s Role

Treasury acts as the coordinator.

It ensures:

• Required documentation is available and maintained 
• Banks receive timely and accurate information 
• Transactions comply with AML and sanctions requirements 

It works closely with:

• Legal 
• Compliance 
• Operations 

Because while KYC, AML, and sanctions may not add visible value, they enable everything else to function.

Without them, treasury doesn’t have access to the financial system.

Which makes the rest of the job somewhat difficult.

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Payments used to be straightforward. You had money, you sent it, done.

Now there are layers of regulation shaping how payments are initiated, authenticated, processed, and reported. Treasury sits right in the middle of this.

These frameworks are designed to make payments safer, more transparent, and more competitive. They also make them more complex.

Why Payments Are Regulated

Regulators focus on payments because they are:

• High volume 
• Cross-border 
• Prone to fraud and misuse 

The objectives are to:

• Increase security 
• Prevent fraud and financial crime 
• Improve transparency 
• Encourage competition and innovation 

For treasury, this means adapting processes to comply with evolving rules.

Key Payment Regulations

In Europe and beyond, treasury is impacted by frameworks such as:

• PSD2 and PSD3 (Payment Services Directive)
  Introducing stronger authentication, open banking, and increased transparency 
• SEPA regulations
  Standardising euro payments across participating countries 
• ISO20022 standards
  Defining structured payment data formats 
• Local payment regulations
  Country-specific rules on processing, reporting, and data 

Each of these influences how payments are executed and managed.

Strong Customer Authentication (SCA)

One of the most visible impacts of regulation is Strong Customer Authentication.

This requires:

• Multi-factor authentication 
• Additional verification steps for payment approval 

For treasury, this affects:

• Payment workflows 
• Approval processes 
• System configurations 

While it improves security, it can also:

• Slow down execution 
• Increase operational complexity 

Balancing security and efficiency becomes key.

Open Banking and APIs

Regulation has also driven innovation.

Open banking frameworks require banks to:

• Provide access to account data 
• Enable payment initiation via APIs 

This creates opportunities for treasury:

• Real-time data access 
• Improved integration 
• New payment solutions 

But it also introduces:

• New dependencies 
• Additional security considerations 

Because more connectivity means more potential points of failure.

Data Requirements and Standardisation

Payment regulations increasingly require:

• Structured data 
• Detailed payment information 
• Consistent formats 

ISO20022 is a key driver here.

It enables:

• Richer payment data 
• Better reconciliation 
• Improved transparency 

But it also requires:

• System updates 
• Data standardisation 
• Process adjustments 

Which, unsurprisingly, takes time.

Cross-Border Payments

Cross-border payments are subject to:

• Additional regulations 
• Reporting requirements 
• Compliance checks 

Treasury needs to consider:

• Local restrictions 
• Currency controls 
• Reporting obligations 

What looks like a simple international payment can involve multiple regulatory layers.

Fraud Prevention and Controls

Regulation pushes for stronger fraud prevention.

This includes:

• Verification of payee 
• Enhanced monitoring of transactions 
• Stricter approval processes 

Treasury integrates these into:

• Payment workflows 
• Supplier onboarding processes 
• Control frameworks 

Security improves. Friction increases. That’s the trade-off.

Impact on Treasury Operations

Payments regulation affects:

• System design 
• Process flows 
• Approval structures 
• Bank connectivity 

Treasury needs to:

• Stay informed on regulatory changes 
• Update processes accordingly 
• Ensure systems remain compliant 

Ignoring updates is not an option. Banks will enforce them anyway.

Where It Goes Wrong

Some common issues:

• Underestimating implementation effort 
• Poor data quality affecting compliance 
• Outdated systems unable to support new standards 
• Lack of coordination between IT, treasury, and compliance 
• Treating regulation as a one-time project 

Payment regulation evolves continuously. So do the requirements.

Treasury’s Role

Treasury ensures that payment processes:

• Comply with regulatory frameworks 
• Remain secure and efficient 
• Support business operations 

It translates regulation into practical processes.

Because in treasury, sending money is no longer just operational.

It’s regulated, structured, and continuously evolving.

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Using derivatives to manage risk sounds straightforward. You identify exposure, execute a hedge, and move on.

Regulators had a different idea.

After the financial crisis, derivatives became heavily regulated. Not because corporates were the main problem, but because the system as a whole needed more transparency and control.

Now, if treasury uses derivatives, it also deals with reporting, documentation, and compliance requirements that sit alongside the financial decision.

Why Derivatives Are Regulated

Derivatives can:

• Create large exposures 
• Be complex and opaque 
• Connect multiple financial institutions 

Regulators introduced frameworks to:

• Increase transparency 
• Reduce systemic risk 
• Improve oversight of trading activity 

For treasury, this means that hedging is no longer just about economics. It’s also about compliance.

Key Regulatory Frameworks

Treasury is typically impacted by regulations such as:

• EMIR (European Market Infrastructure Regulation)
  Governs reporting, clearing, and risk mitigation for derivatives in Europe 
• Dodd-Frank (US)
  Similar objectives in the United States 
• Other local regulations
  Depending on where the company operates 

Even if a company is not a financial institution, it can still fall under these frameworks when using derivatives.

Trade Reporting Requirements

One of the main obligations is trade reporting.

Treasury must:

• Report derivative transactions to trade repositories 
• Include detailed information on each trade 
• Ensure accuracy and timeliness 

This applies to:

• New trades 
• Modifications 
• Terminations 

Reporting is not optional. And errors can lead to regulatory scrutiny.

Clearing and Thresholds

Some derivatives may need to be centrally cleared, depending on:

• Type of instrument 
• Volume of activity 
• Regulatory thresholds 

Treasury needs to monitor:

• Whether thresholds are approached or exceeded 
• Whether clearing obligations apply 

For many corporates, exemptions exist. But they still need to be assessed and documented.

Risk Mitigation Requirements

Even when clearing is not required, regulators impose:

• Timely confirmation of trades 
• Portfolio reconciliation with counterparties 
• Dispute resolution processes 
• Valuation and margining requirements 

These add operational steps to what would otherwise be a straightforward hedging activity.

Documentation and Legal Agreements

Derivatives require:

• ISDA agreements 
• Credit Support Annexes (CSA) 
• Internal documentation for policies and approvals 

Regulation increases the importance of:

• Proper documentation 
• Consistent processes 
• Audit trails 

Missing or incomplete documentation can create both compliance and operational risks.

Impact on Treasury Processes

Derivatives regulation affects:

• Trade execution workflows 
• Data management and reporting 
• Counterparty interactions 
• Internal controls and governance 

Treasury needs to ensure that:

• Systems can capture required data 
• Processes support reporting timelines 
• Controls are in place 

This turns hedging into a more structured, process-driven activity.

Data and System Requirements

Reporting requires:

• Accurate trade data 
• Consistent identifiers 
• Integration between systems 

Challenges include:

• Data reconciliation between internal systems and trade repositories 
• Managing updates and lifecycle events 
• Ensuring data completeness 

Again, data quality becomes critical.

Where It Goes Wrong

Some familiar issues:

• Incomplete or inaccurate reporting 
• Lack of clarity on regulatory obligations 
• Poor coordination between treasury, legal, and compliance 
• Manual processes increasing error risk 
• Underestimating ongoing effort 

Most problems are not about understanding the regulation. They’re about implementing it consistently.

Treasury’s Role

Treasury ensures that:

• Derivative activities comply with regulations 
• Reporting obligations are met 
• Processes are structured and controlled 

It works with:

• Legal teams 
• Compliance functions 
• External advisors 

Because in treasury, hedging is no longer just about managing risk.

It’s also about proving that you did it properly.

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