In 2007, EU Regulation 1781 on payer information accompanying funds transfers became effective as the European manifestation of the Financial Action Task Force on Money Laundering (FATF) Special Recommendation VII (SR VII). Different countries, regions, and banks have interpreted compliance with the payer information obligations in various ways and started to adopt different follow-up procedures.

To address the regulatory changes and avoid any impact to your payments, the following procedures must be followed.

Effective Immediately

For all payments that you initiate on your own behalf, the originator information should be left completely blank, as J.P. Morgan will automatically insert this information on your behalf, using the account data we have on file.

For all payments made on behalf of your client or a third party, in accordance with the new rules, you must include all the originator information in the following order.

Line 1: / Account Number
Line 2: Full Name
Line 3: Street Address (Not a PO Box)
Line 4: City, Country (and State and Postal code if applicable)

A slash (/) which is the SWIFT standard indicator for account number should precede the account number.

If you are working with a version of any initiation software where a slash is not an acceptable character, J.P. Morgan will insert the slash on your behalf for all numeric account numbers.

If you are initiating a multi-currency or euro wire payment, only the first text line of the "By Order" Field should be included with the payment, and J.P. Morgan will insert the complete payer information of the account being debited based on the data we have on file.

If originator information is not provided in the format described above, your payments may be stopped, delayed, inquired upon or returned by banks in the payment chain. Also, banks may levy additional charges when handling such payments.

This action is required for all payment initiation channels, whether you are initiating payments via phone, facsimile, workstation, Internet or directly via a Host to Host utility. If you are a Host to Host user, you will need to ensure that your payment origination systems (e.g., ERP) are not automatically filling in the originator (By Order Party) field with information that is not compliant with the format outlined above.

Additionally, you may need to review your local and/or bank-maintained repetitive payments to ensure they comply with the format outlined above.

Additional Information

Commission of the European Communities: http://ec.europa.eu/internal_market/payments/docs/transfers/proposal_en.pdf
British Bankers Paper: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2006:345:0001:0009:EN:PDF
The Financial Action Task Force (FATF): http://www.fatf-gafi.org/dataoecd/16/34/40268416.pdf