In this timely episode of Payments on Fire®, Yvette Bohanan has gathered teammates at Glenbrook (Elizabeth McQuerry, Erin McCune, Cici Northup, and Joanna Wisniecka) to discuss the payment infrastructure supporting the foreign policy actions being taken as a result of the situation in Ukraine.

In the past week, the UK, EU, and Switzerland announce sanctions against Russia, – with
Switzerland setting aside a long-standing tradition of neutrality in participating in these actions and the US announcing sanctions against Russia’s central bank in a move that prohibits Americans from doing any business with the bank as well as freezes its assets within the United States. These measures are also targeting the National Wealth Fund of the Russian Federation and the Ministry of Finance of the Russian Federation. As markets opened February 28, the Russian Ruble had fallen 29% against the dollar to an all-time low, after the U.S., European Union and Canada agreed to disconnect some Russian banks from the SWIFT interbank messaging system.

We’re going to explore SWIFT and other payment infrastructure elements used to implement foreign policy on a routine basis, and why these recent announcements, in some respects, are taking this to a new level.

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Yvette Bohanan: Welcome to Payments on Fire, a podcast from Glenbrook Partners about the payments industry, how it works, and trends in its evolution. I’m Yvette Bohanan, a partner at Glenbrook and co-host of Payments on Fire, along with George Peabody.

 

Yvette Bohanan: Today we’re gathered with some of our teammates at Glenbrook to discuss the payments infrastructure supporting the foreign currency and policy actions being taken as a result of the situation in the Ukraine.

 

Yvette Bohanan: In the past week alone, we have observed the UK, EU, and Switzerland announce sanctions against Russia – with Switzerland notably setting aside a long-standing tradition of neutrality in participating in these actions and the US announcing sanctions against Russia’s central bank

 

Yvette Bohanan: in a move that prohibits Americans from doing any business with the bank, as well as freezing assets within the United States that are held by Russia. These measures are also targeting the national wealth fund of the Russian Federation and the Ministry of Finance of the Russian Federation.

 

As markets open on February 28 the Russian ruble had fallen 29% against the dollar in an all-time new low after the US, European Union, and Canada agreed to disconnect some Russian banks from something called the SWIFT interbank messaging system.

 

Yvette Bohanan: Now we’re going to explore SWIFT and other payment infrastructure used to implement foreign policy on a routine basis and why these recent announcements, in some respects, are taking this to a new level.

 

Yvette Bohanan: Let me take a moment first to introduce the team members from Glenbrook who we have assembled for this conversation. I feel very fortunate that we have assembled you all as a dream team, if you will, to dive into this important and timely topic. First of all, Elizabeth McQuerry

 

Elizabeth is one of our partners at Glenbrook and heads up our global practice. Throughout her career, she has held leadership roles at the Federal Reserve retail payments office and as CEO of the International Payments Framework Association.

 

She has worked with organizations and governments around the globe on strategic payments infrastructure, governance, and product definition for cross-border payment systems. Elizabeth, welcome, we’re so glad you’re here.

 

Yvette Bohanan: Next on our panel is Erin McCune.

Erin is another partner here at Glenbrook who leads practice work focused on increasingly complex payments initiatives for our corporate clients and advises financial institutions and payment technologists on the development of their payment capabilities, with a special emphasis on cross-border payments that enable global trade between buyers and suppliers.

Erin, we’re delighted you’re here with us today.

 

Erin McCune: The pleasure’s all mine.

 

Yvette Bohanan: And with us today, we also have Cici Northup.

 

Cici is one of our Associate Partners and has worked for nearly a decade with central banks, industry bodies, and global NGOs working to increase financial inclusion and build inclusive low cost interoperable digital financial service systems.

 

The thrust of her work has been in creating rule books, governance frameworks, and business models to aid in the launch of instant payment systems around the globe. Cici, welcome, and thanks for joining us.

 

Cici Northup: Happy to be here.

 

Yvette Bohanan: And then, last but not least, we have Joanna Wisniecka.

 

Joanna has held a variety of positions within the Federal Reserve Bank of New York, including its banking supervision group overseeing large financial institutions’ payments processing activities, the payments policy group coordinating a central bank lead industry Task Force, and the Fed Wire securities and funds service leading strategy product management and participant engagement.

 

Yvette Bohanan: Her vast experience provides Glenbrook clients with a broad perspective in regulatory oversight, payments infrastructure management, and product roadmap development. Joanna, welcome.

 

Joanna Wisniecka: Thank you, Yvette.

 

Yvette Bohanan: I’m going to kick it off with you and just want to sort of take a step back. We’re hearing a lot of words right now, all over the newspapers, podcasts, Twitter, you name it. Words like sanctions and OFAC and SWIFT.

 

Yvette Bohanan: Can we ask you to start this discussion by helping us look at the tools that governments are using to implement foreign policy in general?

 

Joanna Wisniecka: That’s a great question to start with, Yvette. You already started to highlight some of the financial tools that are already being used in actioning the foreign policy actions against Russia.  Really the focus on the use of these tools in the last just few days is quite striking.

 

The US, EU and UK governments, at a minimum, and central banks are using a number of these mechanisms to deliberately cut off Russia from the global financial system.

 

Joanna Wisniecka: I’ll highlight a couple of the key ones here all being used to prevent Russia from easily making payments and using a payments infrastructure to get money in and out of the country and then I’ll turn it over to Erin to talk about SWIFT specifically.

So the US announced just in the last couple of days a number of sanctions on Russia’s financial institutions, some of the state-owned enterprises, as well as specific individuals that are tied in one way or another to benefit from the government. You may have heard the term oligarchs and really some of the elite families in Russia. So what does that mean from a payments perspective? So once an individual or company is sanctioned, it’s added to an OFAC list.

 

Joanna Wisniecka: OFAC is the Office of Foreign Assets Control and is part of the US Treasury Department. The list identifies those individuals and companies owned or controlled by, or acting for or on behalf of the targeted countries, so the sanctioned countries.

Financial institutions then implement those lists in their daily activities, in their daily payment processing activities to determine where they can essentially process payments that are in and out of the bank accounts held by those sanctioned individuals or companies. And if a company or individual is on the list, their transactions are blocked and they’re also reported up to the US Treasury.

 

Now, this can have a significant impact on the ability of the individuals and companies to conduct their normal activities. In the case of companies, for example, they may not be able to pay their bills in foreign currencies, or they may not be able to bring revenues due to them from other countries.

 

Joanna Wisniecka: And Elizabeth will talk a bit more about the impact on trade from Russian banks specifically being cut off from the SWIFT global financial messaging system. The impact is somewhat the same. The US and EU also announced the freezing of Russia Central Bank reserves held at the Federal Reserve and the European Central Bank.

 

One of the services that those central banks provide to other central banks is to be like a custodian of their assets. This allows central banks, including Russia’s, to hold assets abroad. So, for example, Russia’s central bank holds US dollars and accounts at the Federal Reserve or may hold euros at the European Central Bank.

They may also hold other assets and, in fact, they do, like securities. So, for example, US Treasury securities or physical assets like gold. And indeed actual blocks of gold that belong to other countries’ central banks are held in the basement of the Federal Reserve Bank of New York. And I know that Die Hard fans listening to this may have already known that.

 

Joanna Wisniecka: And in the case of currency, that’s held in electronic accounts. So a foreign central bank that owns the funds may request movement of the money, of the funds, in and out of their accounts when they want access to it. With actions being taken by the US Government, Russia’s central banks will essentially not be able to access those funds.

 

So why could this be a problem? Well, Russia has significant financial reserves, over 600 billion.

 

In case of emergency need, in case of a crisis, the reserves can be used to provide funds to banks, to provide cash to banks, to continue to support them in smoothly operating.

So smooth functioning of the banking system by ensuring that if individuals and companies need access to extra cash, in case of a crisis or emergency, they can have it.

However, without the central banks actually being able to get those assets, or in the case of securities and gold to actually convert them to cash, the system can collapse. And this is admittedly a bit of a simplification and there are a number of factors at play here, but for the purpose of the podcast, I think I’ll stop here in terms of the likely or the potential impact here.

 

Yvette Bohanan: I am just going to stop you there for a second and just ask – this seems extraordinary at the moment and it is. Is it unusual, have you seen examples of this happen in other places, other countries, for example?

 

Joanna Wisniecka: That’s a great question, Yvette. And going back to really my first point, these actions are really striking. The seriousness of the actions to cut off a country’s Central Bank from a global financial system or global payments infrastructure shouldn’t be underestimated and the decisions to put them in that place or to put the actions in place are quite rare.

 

We do have a recent example of a central bank being sanctioned and it being blocked from accessing its funds at the Federal Reserve, and that was Myanmar.

You might have followed in the news that almost exactly a year ago, on February 1st, Myanmar’s military staged a coup in the country and overturned the democratically elected government there and the central bank, which had then been taken over by the Myanmar military was trying to redraw a billion dollars from its reserve account at the Federal Reserve.

And the decision to block those funds had to go all the way up to the President to make the call to freeze the funds and not let them go. But it’s quite rare and it really does take in an event that’s extraordinary.

 

Yvette Bohanan: So what we’re saying here is, you have OFAC lists and sanctions being imposed, we have mechanisms in place that do that on individuals or businesses.

We’ve kind of taken it to the next step in imposing these same types of mechanisms on the central bank itself and so that’s the big step-change, if you will, here taking it up to the next level is this notion that it’s being imposed on the central bank.

Now that’s very, very helpful context. So it’s unusual but not unique because we’ve seen it happen before in extraordinary cases like Myanmar.

 

Yvette Bohanan: Now I’m going to shift over to Erin because you teed up Erin really nicely here. What are we talking about with this thing called SWIFT, Erin, and why does that get into the mix? What is SWIFT’s role?

 

Erin McCune: So, in the last several days SWIFT has been all over the mainstream news and social media but there’s a lot of confusion and sometimes misleading descriptions of what SWIFT is and what it does so let’s unpack that a little bit here. What is a messaging system, if that’s what SWIFT is, and how is that different from a payment system?

 

So let’s be super crisp about what SWIFT is and what SWIFT is not. SWIFT is not a bank. SWIFT is not a central bank. It is not a payment system and it doesn’t actually move any money.

 

SWIFT is an association of international banks. And there are over 11,000  members of swift and they are in 200 countries. The 200 countries that it’s okay to move money in and out of. And actually now maybe we’re down to 199.

It provides a secure messaging system that those banks use in order to affect what we call “international wires” and I’m putting that in air quotes because there’s actually no such thing as an international wire, but that’s a subject for another day.

Swift defines the format and the content, what goes in those messages, and it also sets some SLAs or expectations between the banks and how quickly they respond to one another and it allows for the tracking of those transactions from bank to bank.

 

Erin McCune: It’s been around for decades, since like the late 70s, and when it was originally started its big claim to fame was replacing telexes and I  don’t think anyone listening to this podcast even knows what a telex is. But you can look it up on Wikipedia and

 

Yvette Bohanan: It’s electronic communication that’s evolved over decades and decades.

 

Erin McCune: Right right, and you know SWIFT has actually done an admirable job of responding to you, you know what, we won’t get into that.

 

Yvette Bohanan: So not a bank. Not a payment system. It’s an association and it’s a messaging format that this association uses to communicate with its members.

 

Erin McCune: No, it’s the global financial messaging system that its members use to communicate with one another.

 

Yvette Bohanan: With each other.

 

Erin McCune: That’s right, with each other.

 

Erin McCune: The participants of SWIFT are what we call correspondent banks and these are the international banks that affect international money movement.

They themselves, that correspondent banking network, is itself a misnomer. There is no network and there is no system. There’s just these messages. And what they do is they use SWIFT to send instructions to one another that create the illusion of a global money movement mechanism.

And the way that works is the banks hold accounts with one another and the instruction say, “please take this money from my account with you and credit it to the ultimate beneficiary of this account”. And that’s what these instructions allow the banks to do.

The banks themselves have partnerships, bilateral relationships, with correspondents in different geographies that they use, that are customers of one another in order to affect the debits and credits between the accounts that they hold with one another that ultimately allow the movement of the money to the destination in another geography.

And, the money gets delivered via the domestic payment system in that destination geography, whether it’s a real-time payment infrastructure that Elizabeth and Cici have been involved with developing, whether it is a domestic ACH system or the equivalent of our ACH system or a domestic wire system.

I think one of the things that is important and sort of ties back to what Joanna just described to us in terms of sanctions is the SWIFT messages include all the information necessary for the participant banks to do the compliance checks to make sure that this money isn’t going to a sanctioned individual, bank, or company.

 

Erin McCune: And this is why in the world of payments, this whole notion of “know your customer,” or KYC, is so important.

 

Yvette Bohanan: Right. Okay, so the picture that I’m getting in my brain just from what you’ve said, Joanna, and what Erin has.

The picture you’re painting together here is I’m picturing the world and I’m picturing like this web across it of interconnected relationships and this SWIFT messaging allowing these banks to communicate with each other, to tell each other moving assets out of these accounts or into these accounts is blocked and forbidden now.

 

Erin McCune: mm hmm.

 

Yvette Bohanan: And because it’s blocked and forbidden basically in a concerted and coordinated manner, that whether it’s a person, an entity, a company or now Russia itself, at the central bank level and its assets are being blocked from telling you to credit or debit and account anywhere Russia has these accounts in the world.

 

Erin McCune: Yeah.

 

Yvette Bohanan: Wow, we’ve just sort of thrown a giant web over the world to catch all of this communication and movement of funds, that’s incredible.

 

Erin McCune: It’s as though their email address got unplugged.

 

Erin McCune: Like, sorry.

 

Yvette Bohanan: Yeah.

 

Erin McCune: No messages for you.

 

Yvette Bohanan: We can’t do this, it’s just impossible. That brings us to the question, okay that’s the mechanics of it and how it fits together.

 

Yvette Bohanan: And Cici, I’m going to ask you to kind of help us out here. How do you coordinate, how do you govern something like this, how does this happen, so that everyone is coordinated together in taking this action? And who’s calling the shots really, is it the government, is it SWIFT, is it a combination, how does this work?

 

Cici Northup: Great question, Yvette, and I would start out by saying that the complexity that you just pointed to, that Erin just described, is somewhat mirrored in the governance structure of SWIFT. But let’s try and break it down.

So, as Erin described, SWIFT is a global messaging system that supports financial transactions.  It is not owned by any single nation, it’s actually a cooperative composed of 25 independent board of directors who are elected in by SWIFT shareholders. And SWIFT shareholders are made up of financial institutions, including central banks.

And the SWIFT shareholders elect the board members through a very complex representation process that’s intended such that the board composition represents and reflects the usage of the SWIFT message services, so you can imagine that the countries or the financial institutions who use SWIFT more often have a greater chance to elect a board member that represents their interests.

 

Cici Northup: From what I can gather from SWIFT’s bylaws in a recent review, there are multiple ways in which the 25 elected board of directors may suspend or expel a shareholder from the system.

The most relevant, there’s 4, the most relevant from my read for the current situation is related to regulation. Where the shareholder is subject to “regulations impacting its shareholding in the company”. So from my read and from recent press releases released by various regulatory bodies, there are regulations being implemented in the EU and in other countries to expel Russian institutions from SWIFT.

Because SWIFT is based in Belgium, they have to respond to that regulatory call to action. And, as a result, the SWIFT board will need to vote to acknowledge the removal of Russian banks in coordination with these regulations.

Interestingly, each Director has one vote and a simple majority rules. And the board of directors, in looking at their representation, 14 of the 25 represent the US, UK, and the EU.

So this suggests that when the SWIFT board does go to vote, we will see a majority agreement for the removal of Russian banks. And just one last comment here, which is to say that we’ve seen precedent for this with the expulsion of Iranian banks in 2012.

 

Yvette Bohanan: So it’s again, it’s not unheard of. But it’s a situation that you don’t see happen very often.

 

Cici Northup: And one last thing just to add is from what I’ve read, the Iranians experienced significant impacts as a result of that expulsion and there was a rejoining in 2016 to avoid further implication.

 

Yvette Bohanan: Yeah. So we see this connection between government policy and the bylaws if you will, or the governance model of SWIFT and the central bank participants to stay coordinated with what’s going on at the macro-level of geopolitics and the central bank infrastructure itself and the banking infrastructure. So it all kind of ticks and ties together.

 

Okay, so we have the mechanisms in place here, we’ve kind of unpacked what’s going on with the messaging, the communication, how things actually get implemented in the mechanics, how they’re able to do this from a governance perspective.

 

Yvette Bohanan: Let’s now turn our attention over to the “so what”. What actually happens when the penny drops, if you will, pun intended, and this actually goes into effect?

 

Yvette Bohanan: Elizabeth, can you help us go through some of the implications of this happening, like what’s going to unfold or what could possibly unfold next?

 

Elizabeth McQuerry: Yeah, absolutely Yvette.

This is happening in real-time. We’re almost seeing a textbook case in a tragic circumstance of whether or not the sort of system of checks and balances and whether sanctions can be effective in creating you know the desired outcomes and whether or not the financial system is key to really, if you will, making those making these sanctions play out quickly and efficiently.

And we’re going to see very soon how effective this really is because once you really put the banks at the center of everything, that’s connected to all of us in one way or the other.

Whether we’re a company or whether we’re an individual, we’re going to have an account somewhere with some bank and chances are, given the size of the sanctioned institutions, the commercial banks in Russia, many Russians and businesses, they’re going to have accounts at those banks. So they’re connected very directly with the sanctions.

So very quickly they’re going to have challenges moving money, they’re going to have challenges being paid, as well as, of course, access to capital outside of Russia. So we’re going to have very quick effects that are going to translate very quickly into their commercial balance sheets and to trade.

 

Elizabeth McQuerry: From the scope of this, it’s not just trade with the United States. It’s pretty much trade with the entire world. So you’re not going to be able to go very far or trade for many things, because, I believe some are some exclusions like energy, but it’s going to be hard to buy and sell things for sure and even worse it’s going to be even harder to pay for it.

Because with the ruble declining significantly in value, anything you want to do in hard currency is going to cost more money, right. So, inflation is going to increase and it will place a significant pressure ultimately on the government to try to stabilize this.

 

Elizabeth McQuerry: Businesses will probably act very directly to try to get the government to take stabilization measures. So what will they do if they’re not buying and selling things, they’re not making revenue, they’re not generating value-added taxes.

If it goes to individuals, also feeling the pain of inflation, they’re not going to buy as many goods and services themselves, so the pain really just sort of redoubles, right, it can be a very acute, tremendous effect. And I think that it’s not just these banks, right, it’s how they connect to all the rest of us, all the way back to the Russian Government.

 

Yvette Bohanan: You know, we often talk about the systemic nature of payments, the systemic nature of domestic systems, the systemic nature that…what you’re describing is payments at the heart of an economy and the systemic fallout, if you will, of actions at this scale and it’s putting them in a very grave situation, right.

 

Elizabeth McQuerry: Absolutely.

 

Yvette Bohanan: Yeah, so that’s a pretty heavy implication.

 

Erin McCune: And it’s remarkable to see it playing out in near real-time. The scope, and then I don’t want to say universality, but this is a widespread action. Not just our government, but many governments and so it’s profound. The order of magnitude is big and we’re just literally watching in real-time via Twitter and overnight, 24-hour news, what the implications are.

 

Yvette Bohanan: Right, absolutely. So when you think about those implications, which are pretty heavy as you’re saying, there’s going to be people who are trying to work around this, right. I mean given the impact to the Russian economy and so forth, can we talk for a moment here about how a country or a person would try to circumvent the actions that we’ve just described. How are they going to try to get around this?

 

Yvette Bohanan: Cici, do you have any thoughts here?

 

Cici Northup: Yeah, I think there’s a number of things that can be said related to that question. I want to point to two things that I find interesting. The first is that following 2014 threats of removal from SWIFT, Russia has been building its own alternative for some time now.

News reports note that it is operational, but there’s really little we know outside of Russia in terms of how extensive it is or how well it works. Our current understanding is that it’s domestic only and while agreements have been made to connect this SWIFT alternative to other countries, notably China, it’s unclear the extent to which this has come to fruition. And as a result, this Russian-born SWIFT alternative could support intro Russian transactions, but in its current form, it will not solve the challenge of connecting Russia to the economy, outside of its border.

Cici Northup: A second alternative that I think is top of mind for many, is the extent to which decentralized cryptocurrency-based systems like Bitcoin may be used in place of SWIFT and the transactions affected by SWIFT. Of course, any sanctions that prohibit treating or doing business with certain banks or certain entities in Russia apply regardless of the payment system, so those would hold. It may be easier to disguise the true identity or beneficial ownership of the transaction or assets in some cases when using these systems.

However, users that lean on a cryptocurrency-based payment system will eventually need to get funds into the digital currency and back out into the ruble. And when they do it’s going to be challenging in both instances, but particularly challenging for the exchange from digital currency back out to Fiat as long as the value of the ruble is falling.

 

Cici Northup: I guess the main point here is to say that there are alternatives, I mentioned two, but they’re certainly not yet a panacea for most people or businesses.

 

Yvette Bohanan: Got it. Yeah so we know in digital currency systems there’s the cryptocurrency, there’s some press around bitcoin being used to help people in this as well.

 

Yvette Bohanan: But we also have central bank digital currency systems, and China notably is leading in that initiative with 120 million people and 10 million businesses operating in their pilot so far in terms of a distributed ledger central bank digital currency. And you have to wonder what’s possible there, right, so and what might they do?

Of course, all of these distributed ledger technologies, whether crypto or stable coin or central bank digital currency, you know representations of Fiat currency, if you will, on these ledger technologies are not part of SWIFT. So it gives one pause as we go into this brave new world.

 

Yvette Bohanan: And Erin, as you said, it’s all happening in real-time, unfolding before us. So you know we always say we’re in an interesting moment in payments and it just keeps getting more interesting for one reason or another. Some of them are not happy reasons, but still it’s pretty interesting.

 

Yvette Bohanan: So with that I think we’re going to wrap up. Are there any final thoughts any of you would like to share on this topic that we haven’t covered already or anything you think our listeners should be keeping on their radar or staying apprised of through the coming days and weeks?

 

Elizabeth McQuerry: I have a thought, Yvette. I think it’s reasonable, and we often hear complaints that the banks are being used to make policy, right, they’re the arms of policy and the compliance obligations and extended “know your customer” obligations which have been placed on banks over the years. I mean, more and more regulation right. And a lot of it, focused on knowing the end user and, if it’s another bank, who their customers are, right.

 

How can you really know who all the customers are at an institution in another country? And that’s what’s being asked of banks and I think it is a significant challenge and burden for the financial institutions to really comply with all this.

Right now, what we’re seeing is what is really perhaps the intended effect when these sanctions and compliance mechanisms are put into place. They’re here for when we really need them right, and right now, most of the world is saying we really need to make this happen.

 

Elizabeth McQuerry: Because the alternative is not acceptable and this is the best opportunity, the best avenue that we have to sort of bring about the attention, possible policy change, which unfortunately goes with a lot of economic pain on, well, all ends, frankly.

Of course, mainly going to be felt in Russia, but you really see what some of the intended positive effects are meant to be with all of the fianncial regulation that we see. Thinking of a lot of our fintech clients and the work we do to get them ready to work with a bank and explain to them, yes, this seems really onerous.

 

Erin McCune: Now, the reason why the bank needs to know for sure who your customers are, that you are going to be enabling transactions on behalf of, here’s a very clear illustration of why that’s happening.

 

Erin McCune: I’ve been reflecting on the whole challenge around the processes that we have in place for “know your customer” and “know your business” and getting to the beneficial owners of various entities and that’s a real challenge.

And I think coming out of this we’re going to have a real spotlight on what works well, what doesn’t work well, and I think that technologists that are really focused on this whole question of validating whose account this is and who’s behind this account, those types of players are going to be in a lot of demand, because this is a very painful process today.

And if you thought it was difficult to get a bunch of customers setup and thought you were going to do it via API in just a few minutes, it’s going to take a whole lot longer with a lot more scrutiny.

 

Yvette Bohanan: Yeah digital identity and figuring out how to do this at scale is a big challenge and there’s more work to be done there for sure.

 

Erin McCune: A lot more work. And this really just exposes how hard that is – for everyone, not just the banks, for anyone that’s helping businesses and consumers transact and acting as an extension of the bank in order to ensure compliance happens and the data is available.

Yvette Bohanan: Well, on that note. I’m going to say thank you to you Elizabeth, Erin, Joanna and Cici. It’s always a pleasure to get together and geek out on payments with you.

I wish it was under different circumstances for this particular podcast but, hopefully, we’ve added some clarity to the conversation, helped people sort of have some guideposts to put together the pieces and to interpret what they’re seeing and hearing right now, on an I’d say daily but it’s more like minute by minute basis, and to help their thinking and their decision-making.

So thank you so much for taking the time and with that, I’ll say thank you to our listeners, we hope you stay safe and continue to do good work. Take care.