ARIFAC Working Groups

This workstream focuses on information-sharing challenges and response frameworks between cross-border payment aggregators and AD Category-I banks when handling Red Flag Indicators (RFIs). Key issues may include documentation standards, turnaround expectations, transaction context, merchant visibility, source-of-funds indicators, and escalation triggers for unusual cross-border activity.

This workstream can examine how banks and payment aggregators identify suspected mule accounts, share red flags, and respond to RFIs linked to suspicious transaction patterns. It can also cover practical indicators such as account behaviour inconsistent with customer profile, rapid fund movement, layering through intermediated channels, and the use of shared alerting or case-escalation mechanisms.

This workstream can develop practical approaches to Enhanced Due Diligence for customers presenting elevated risk because of business model, geography, ownership structure, transaction profile, or adverse intelligence. ARIFAC's July 2024 discussions already emphasized the need for CDD/EDD before STR filing, deeper customer analysis, open-source validation, and risk upgrading after suspicious reporting, making EDD a natural pillar for the page.

This workstream can address how digital onboarding, remote servicing, velocity of transactions, and ecosystem connectivity affect mule account exposure in digital banking environments. Topics may include onboarding controls, behavioural monitoring, trigger-based review, AI/ML-assisted alerting, and the use of external signals such as fraud alerts and network-based indicators in risk assessment.

This workstream can focus on sanctions screening design, watchlist governance, name-matching quality, false-positive reduction, and escalation standards across customer onboarding and ongoing monitoring. The objective should be to help members improve consistency, timeliness, and auditability of screening controls while reducing operational friction in higher-volume environments.

This workstream can provide a dedicated forum for AML/CFT issues affecting VDA service providers, including customer due diligence, transaction monitoring, sanctions compliance, reporting expectations, and cooperation with competent authorities. ARIFAC's own description lists VDA-SPs among the sectors within its intended chapters, and recent India-focused compliance guidance for VDASPs highlights written AML/CFT frameworks, sanctions screening, and stronger supervisory expectations as core areas of attention.