Further to the letter of 6 September 2017 from the Chief Financial Officer, FSS, of the United Nations Joint Staff Pension Fund (UNJSPF) concerning the mailing addresses of UNJSPF beneficiaries, we would like to provide the following additional information and clarification.
The notification was a disclosure letter for information purposes only. It was sent to all beneficiaries of the Fund, irrespective of whether or not they currently receive a payment from the Fund. There is no need for any action or response to UNJSPF or a need to resubmit the address on file for this purpose.
The Fund uses international banks, J. P. Morgan Chase, UBS, and Standard Chartered Bank (UNJSPF banks) to execute its payroll. UNJSPF banks have adopted the Financial Action Task Force (FATF) recommendation, incorporated in the ISO 20022 standard, which sets forth a comprehensive and internationally endorsed framework for measures and global standards for financial business transactions. This industry standard requires additional disclosures in order to ensure successful transmission of the bank file containing financial remittances. Due to this requirement, all financial remittances must now include the information of the recipient’s mailing address for international wire transfers. As all UN entities, including the Fund, use the international banking system to transmit their payments, there is no option to bypass this requirement. October 2017 was the deadline for the Fund to provide UNJSPF banks the updated payment file with information on the addresses of beneficiaries to banks in order to ensure that payment of the monthly benefit is made.
Yes, the United Nations System entities, including United Nations Secretariat (Treasury), have also implemented this requirement in respect of reporting the addresses of beneficiaries of payments for international wire transfers.
All account holders were required to provide their address to their bank upon opening an account. Therefore all receiving banks have the beneficiaries address on file. Following the Financial Action Task Force (FATF) recommendation, ISO 20022 introduces a requirement for the Fund’s banks, as the originating banks, to obtain the address of beneficiaries for international wire transfers.
Without the address information, the UNJSPF banks (J. P. Morgan Chase, UBS, and Standard Chartered Bank) will not be able to transfer benefits payable to an overseas bank account. In order to avoid any rejection or delays of payments, UNJSPF will ensure that all the requirements are met.
Depending on the receiving bank the following could occur:
The payment could be rejected.
The beneficiary’s financial institution may request for the information.
The correspondent bank may request for the information.
All of these will result in delay, rejection or return of the payment(s).
No, as part of international banking standards, the Financial Action Task Force (FATF) and ISO 20022 require the addresses of beneficiaries for international wire transfers (cross-border wire transfers) only. UNJSPF is not required, and it will not, share the beneficiaries’ addresses for so called domestic wire transfers. These are transfers originating and received in the jurisdiction of UNJSPF’s banks, i.e., within the U.S. and within the Single Euro Payments Area (SEPA).
FATF is Financial Action Task Force, which is a global standard setting body for combating money laundering and the financing of terrorism and proliferation. You can find more information on the following website: http://www.fatf-gafi.org.
The Financial Action Task Force (FATF) and ISO 20022 are international standards and are adopted by national jurisdictions through their respective local laws. The U.S. is one of the national jurisdictions having adopted the recommendations.
In implementing the Financial Action Task Force (FATF) recommendation, the UNJSPF banks (J. P. Morgan Chase, UBS, and Standard Chartered Bank) must comply with the agreed methodology used by the financial industry to create consistent message standards across all the financial business transactions. This is called ISO 20022. The international implementation of ISO 20022 is progressing. Information regarding the status of the implementation can be found at: www.iso20022.org/adoption.page
The Financial Action Task Force (FATF) recommendation on combatting money laundering and the financial terrorism and proliferation and ISO 20022 regulate the standard and protocol used by international banks; there are no exceptions for international wire transfers for international organizations.
The regulations do not allow the Fund’s banks to utilize the information provided by the Fund for any other purposes than meeting the requirements stipulated by Financial Action Task Force (FATF) in transmitting payment via wire transfer. At the same time, the local banks are bound by national legislation and by their own industry and national standards to safeguard the privacy of information. It is noted that the Fund’s banks and/or the intermediary banks, as well as the receiving banks, may be required, in specific circumstances, to share these addresses with the authorities in their respective jurisdictions under national law in accordance with FATF requirements.
Under Administrative Rule J.2, the UNJSPF participant specifies in writing the method, currency and the banking institution to which his/her payment should be made. All UNJSPF beneficiaries have already provided their addresses in their official initial Payment Instructions (E6, E7, E2, etc.) of the Pension Fund. The beneficiaries sign that form and it is used for banking purposes to remit the benefit payment. Furthermore, in subsequent forms – Change in Payment Instruction (PF23) or Change in Address (PF23M, E10, and E11) – they submit the address in original format to the Fund. All these UNJSPF forms are used for the purpose of communicating with the Fund and enabling the Fund to remit the payments due – including (international) wire transfers. Therefore, the provision of address information in accordance with Financial Action Task Force (FATF) and ISO 20022 to facilitate banking operations falls outside the restriction under Administrative Rule B.4. The information is provided to ensure that the benefit entitlement is paid to the right account and the right recipient.