Identity assurance at the last mile: A disbursement-time verification framework for cross-border compliance in the G20 payment reform era

Abstract

Global cross-border payments reached approximately US$179tn in 2024, with business- to-business flows comprising the majority of that value. Despite this scale, a significant proportion of cross-border payments fail or are delayed by compliance issues, trapping substantial liquidity annually in the correspondent banking system. The root cause is architectural rather than regulatory: identity verification in most disbursement platforms is anchored at onboarding, producing a static customer due diligence record applied to all subsequent payment decisions regardless of elapsed time, jurisdictional change or counterparty evolution. Four structural failure modes follow from this mismatch, namely identity staleness, jurisdictional drift, counterparty opacity and velocity blindness. The disbursement-time identity assurance (DTIA) framework proposed in this paper provides a structured response, comprising three layers: continuous identity signal ingestion, a regulatory destination mapping engine and an identity-gated payment authorisation layer. The framework is evaluated against the three most consequential regulatory deadlines of 2026: the EU Digital Identity Wallet under eIDAS 2.0, ISO 20022 mandatory structured data compliance and high-risk enforcement under the EU AI Act 2024. Policy recommendations for the Financial Action Task Force, the Financial Crimes Enforcement Network and the European Banking Authority are developed in the final section. This article is also included in the Business & Management Collection which can be accessed at http://hstalks.com/business.