Swift RMA Guidance
Introduction
The Wolfsberg Group (the Group) has prepared this guidance document on the Swift Relationship Management Application (RMA) to supplement the Wolfsberg Financial Crime Principles for Correspondent Banking issued in 2022. This document is intended to provide broader guidance to financial institutions (FIs) for managing non-customer RMAs. This document is an update to the 2016 Wolfsberg Group SWIFT RMA Due Diligence Guidance, which has been retired.
Relationship Management is a service on SwiftNet1 that allows Swift users to control the messages they want to accept from counterparties. The overall objective of Relationship Management is to stop unwanted messages before they leave the sender's messaging interface. Swift users benefit from this by not receiving unwanted traffic which saves them time and effort in reviewing this traffic and eliminates the exposure from processing such unwanted traffic. The Swift user can control the following types of information:
- which other Swift users can send them traffic;
- which messages the Swift user can send; and
- the validity period of the RMA relationships.
A traditional customer relationship which involves cross-border transactional or liability accounts requires an RMA. RMAs are also established with third parties (i.e. non-customers) to facilitate transactions for existing customers; these RMAs may be referred to as non-customer RMAs.
The possible use of an RMA arrangement for purposes not intended, or agreed to, at the time of establishment is predominantly an operational risk, not a financial crime risk. RMA arrangements, if poorly controlled, may, however, allow Swift counterparties with inadequate systems and controls access to international banking systems. For example, through the exchange of an RMA authorisation with a non-customer, an FI may receive, and act upon, payment instructions from a non-customer. This guidance outlines minimum due diligence standards required for non-customer RMAs to help mitigate the impact of possible misuse of an RMA. It is also noted that Swift requires and validates membership documentation on all prospective members.
In preparation for migration to new MX2 messages as part of the ISO20022 changes, RMA will be required for all FINplus messages. The migration became available in 2023 and must be implemented by November 2025.3 Swift has defined Business Profiles to assign RMA in a logical grouping of message types. FIs can assign RMA authorisation at different levels within the business profiles.
1. Principles
FIs should incorporate RMA due diligence standards into their risk management programmes where the following concepts or principles should be considered (more detail on the different types of relationships is set out in the sections below):
- Due to the potential risks that may be associated with the establishment of an RMA, approval of such requests needs to be controlled appropriately;
- RMA requests may be segregated between customer relationships and non-customer relationships, with distinct due diligence criteria for each;
- Within the set of non-customer relationships maintained by an FI, those relationships that are limited to a purely reporting-related exchange of messages, with no transactional activity involved, should be considered lower risk. FIs may therefore determine that there is no, or a reduced, requirement for due diligence on those relationships;
- Where an RMA holder has a customer relationship subject to due diligence, the requirements under that due diligence programme will apply;
- Due diligence on the RMA holder should consider the message types used by the RMA holder and the risk associated with the activity conducted;
- FIs should consider designating an accountable person for related procedures. The aim is to ensure accountability of a responsible person to mitigate the potential risk outlined above.
2. Definition of a Non-Customer RMA Relationship
A non-customer RMA is generally created when there is a request that the FI sends or receives Swift messages to/from a third party (i.e. the non-customer) in support of a customer’s business and where the FI has no other relationship with that third party.4 This can include both transactional and non-transactional messages. Within the scope of non-customer RMA relationships, reporting-only relationships are those non-customer RMA relationships in which exchanged messages do not lead to the initiation of any transactions; transactional relationships are all other non-customer RMA relationships.
FIs should assess the types of messages they send and receive and perform their own assessment of the appropriate classification of each as either transactional or reporting. Some examples include, but are not limited to:
| Transactional | Reporting |
|---|---|
|
|
It is noted that the definition of a customer may vary according to applicable local laws and regulations, which may also have an impact on the designation of non-customer RMAs. For example, in certain jurisdictions, the establishment of an RMA is considered a form of customer relationship and therefore subject to risk-based due diligence. It is important for FIs to assess and understand any local requirements that apply in the jurisdictions in which they operate and be guided accordingly.
3. Minimum Due-Diligence Procedures for Non-Customer RMAs
For non-customer RMA relationships that are reporting-only, there are no minimum recommended identification and due diligence requirements from a financial crime perspective, however sanctions obligations should always be considered in relation to information available to the FI.
For non-customer RMA relationships that are transactional, the minimum recommended identification and due diligence financial crime requirements are as follows:
- Collect name and address information;
- Evaluate risks of the potential RMA based on the above information to identify whether the RMA-holder FI may require further review based on the FI’s risk appetite; and
- Conduct a review against watchlists, which could include screening against:
- Sanctions lists and other relevant lists maintained by competent authorities; and
- Internal lists that the FI may maintain to manage or monitor transactions/relationships.
4. Suggested Procedures for Ongoing Management of RMAs
The potential risks associated with the establishment of a non-customer RMA need to be managed throughout the lifecycle of that RMA. Below are suggested procedures for managing the potential risks associated with non-customer RMAs, as well as the transactions the FI undertakes with such entities:
- Consider a review of relationships to identify those that warrant cancellation due to non-usage; and
- Conduct watchlist screening periodically in accordance with internal screening standards.
For relationships not previously subject to the FI’s non-customer RMA due diligence programme, but now in scope, appropriate RMA due diligence should be conducted within a reasonable period.
5. Conclusion
Important changes to industry messaging standards mean that FIs should revisit their approach to Swift RMA due diligence. FIs should review and, as appropriate, update their policies and procedures relating to risk assessment and due diligence for such relationships.
Appendix A: List of Swift MT messages which do not require an RMA authorisation
| MT 300 | Foreign exchange confirmation: Confirms information agreed to in the buying/selling of two currencies |
| MT 305 | Foreign currency option confirmation: Confirms information agreed to in the buying and selling of vanilla options on currencies |
| MT 306 | Foreign currency option confirmation: Confirms information agreed to in the buying and selling of exotic options on currencies |
| MT 320 | Fixed loan/deposit confirmation: Confirms the terms of a contract relative to a fixed loan/deposit transaction |
| MT 330 | Call/notice loan/deposit confirmation: Confirms the terms of a contract relative to a call/notice loan/deposit transaction |
| MT 340 | Forward rate agreement confirmation: Confirms the details of a forward rate agreement |
| MT 341 | Forward rate agreement settlement confirmation: Confirms the settlement details of a forward rate agreement |
| MT 350 | Advice of loan/deposit interest payment: Advises of a loan/deposit interest payment |
| MT 360 | Single currency interest rate derivative confirmation: Confirms the details of a single currency interest rate derivative swap, cap, collar or floor |
| MT 361 | Cross currency interest rate swap confirmation: Confirms the details of a cross currency interest rate swap transaction |
| MT 362 | Interest rate reset/advice of payment: Confirms or advises the reset rates of the floating interest rate(s) in a single or cross-currency interest rate derivative transaction and/or the payment of interest at the end of an interest period |
| MT 364 | Single currency interest rate derivative termination/re-couponing confirmation: Confirms the details of the partial or full termination or re-couponing of a cross currency interest rate swap |
| MT 365 | Cross Currency Interest Rate Swap Termination/Recouponing Confirmation: Confirms the details of the partial or full termination or recouponing of a cross currency interest rate swap. |
| MT 370 | Netting position advice: Advises the netting position of a currency |
| MT 390 | Advice of charges, interest and other adjustments: Advises an account owner of charges interest or other adjustments |
| MT 391 | Request for payment of charges, interest and other expenses: Requests payment of charges, interest or other expenses |
| MT 392 | Request for cancellation: Requests the receiver to consider cancellation of the message identified in the request |
| MT 395 | Queries: Requests information relating to a previous message or amendment to a previous message |
| MT 396 | Answers: Responds to an MT 395 Queries or an MT 392 Request for cancellation or other message where no specific message type has been provided for a response |
| MT 398 | Proprietary message: Contains formats defined and agreed to between users and for those messages not yet live |
| MT 399 | Free format message: Contains information for which no other message type has been defined |
| MT 600 | Commodity trade confirmation: Confirms the details of a commodity trade and its settlement |
| MT 601 | Commodity option confirmation: Confirms the details of a commodity option contract |
| MT 605 | Commodity notice to receiver: Notifies the receiver of an impending book-entry transfer or physical delivery of a specified type and quantity of commodity |
| MT 606 | Commodity debit advice: Advises the receiver of a debit entry to a specified commodity account |
| MT 607 | Commodity credit advice: Advises the receiver of a credit entry to a specified commodity account |
| MT 608 | Statement of a commodity account: Provides the details of all bookings to a commodity account |
| MT 620 | Commodity fixed loan/deposit confirmation: Confirms a commodity fixed term loan/deposit contract |
| MT 670 | Standing settlement instruction update notification request: Requests SWIFT to create the MT 671 from the MT 670 and send it financial institutions |
| MT 671 | Standing settlement instruction update notification: Specifies standing settlement instructions for one or more currencies |
| MT 900 | Confirmation of debit: Advises an account owner of a debit to its account |
| MT 910 | Confirmation of credit: Advises an account owner of a credit to its account |
| MT 920 | Request message: Requests the account servicing institution to send an MT 940, 941, 942 or 950 |
| MT 935 | Rate change advice: Advises the receiver of general rate change(s) and or rate change(s) which applies to a specific account other than a call/notice loan/deposit account |
| MT 940 | Customer statement message: Provides balance and transaction details of an account to a financial institution on behalf of the account owner |
| MT 941 | Balance report: Provides balance information of an account to a financial institution on behalf of the account owner |
| MT 942 | Interim Transaction Report: Provides balance and transaction details of an account, for a specified period of time, to a financial institution on behalf of the account owner. |
| MT 950 | Statement message: Provides balance and transaction details of an account to the account owner |
| MT 970 | Netting statement: Provides balance and transaction details of a netting position as recorded by a netting system |
| MT 971 | Netting balance report: Provides balance information for specified netting position(s) |
| MT 972 | Netting interim statement: Advises interim balance and transaction details of a netting position as recorded by a netting system |
| MT 973 | Netting request message: Requests an MT 971 or 972 containing the latest available information |
| MT 985 | Status enquiry: Requests an MT 986 |
| MT 986 | Status report: Provides business-related information about a customer or institution |
| MT 990 | Advice of charges, interest and other adjustments: Advises an account owner of charges, interest or other adjustments to its account |
| MT 991 | Request for payment of charges, interest and other expenses: Requests payment of charges, interest or other expenses |
| MT 992 | Request for cancellation: Requests the receiver to consider cancellation of the message identified in the request |
| MT 995 | Queries: Requests information relating to a previous message or amendment to a previous message |
| MT 996 | Answers: Responds to an MT 995 Queries or an MT 992 Request for cancellation or other message where no specific message type has been provided for a response |
| MT 998 | Proprietary message: Contains formats defined and agreed to between users and for those messages not yet live |
| MT 999 | Free format message: Contains information for which no other message type has been defined |
Appendix B: Further reading
The following articles and documents are available to Swift members with swift.com access and related service access. Consult with your FI’s administrator for access:
| CBPR+ landing page | https://www2.swift.com/mystandards |
| RMA Evolution Update | https://www2.swift.com/knowledgecentre/kb_articles/5023348 |
| RMA Portal Getting Started Guide | https://www2.swift.com/go/book/book201334 |
| RMA Business Profiles Handbook | https://www2.swift.com/knowledgecentre/kb_articles/5024789 |
| RMA Landing/Support Page | https://www2.swift.com/knowledgecentre/subjects/rma/index.html |
Footnotes
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SwiftNet is Swift’s secure, global messaging platform. ↩
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“MX” messages refer to the message schema introduced by Swift as part of the migration to ISO 20022. These Swift messages require the use of FINplus and all FINplus messages are signed, which means they require an RMA. By contrast, the legacy “MT” message schema includes a small number of FIN messages that are not required to be signed, hence not all exchanges of MT messages necessitate an RMA relationship. ↩
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As of the date of this publication, 2025 is the scheduled date. ↩
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Examples of “other relationship” could include vendor relationships that FIs may subject to additional financial crime-related controls. These relationships are outside the scope of this paper. ↩
