BAFT Response to ECB Consultation to Extend T2 Operating Hours

BAFT supports extending T2 operating hours in a measured, opt-in, and phased manner to enhance liquidity management, support instant and cross-border payments, and keep traditional payment rails competitive with new technologies. However, it emphasizes that full 24/7/365 operations would impose major costs, risks, and system changes, and should only proceed with clear demand, industry alignment, and long notice periods. BAFT urges careful consideration of operational resilience, liquidity sourcing, cybersecurity, and coordination with T2S, recommending feasibility studies, staggered implementation, and safeguards like circuit breakers and central liquidity bridges.

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BAFT submitted a comment letter to urge regulators to expand collaboration across banks, fintechs, telecom, social media, and law enforcement — both domestically and internationally — to effectively combat payments fraud. The association calls for real-time data sharing, clearer liability standards, and safe harbor protections so banks can pause suspicious transactions without fear of penalty. It also recommends updated regulations, industry-wide fraud standards, and consumer/business education campaigns to strengthen prevention, detection, and mitigation efforts.

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BAFT joined with numerous trade associations, including the Bank Policy Institute, UK Finance, the Loan Market Association, the Swiss Finance Council, and others, to urge European Union Member States to implement the branch requirements under CRD VI (Capital Requirements Directive) in a uniform and harmonized manner. This effort is part of BAFT’s overall advocacy on Basel III capital standards as they are implemented at the national level. CRD VI was, in part, the EU’s adoption of the final pieces of the Basel III Framework.

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WASHINGTON, D.C. (September 2, 2025) – It is with great excitement that BAFT (Bankers Association for Finance and Trade) formally announces its independence as a separate association from the American Bankers Association (ABA).

As the leading global industry association for international transaction banking, BAFT brings together financial institutions, service providers, and the regulatory community to promote sound financial practices that support innovation, efficiency, and commercial growth. Through its advocacy, thought leadership, best practice guidance, and professional development, BAFT helps members navigate a rapidly changing global environment in areas such as trade finance, payments, and compliance.

“Establishing BAFT as an independent association is a strategic step toward deepening our global impact and positions BAFT to represent our members’ interests with greater agility,” said Tod Burwell, BAFT president and CEO. “As the voice of the transaction banking community, we are committed to advancing best practices, innovation, resilience, and excellence on a truly global scale.”

At a time when policy and regulatory developments continue to evolve, BAFT’s independence enables the association to maintain geopolitical neutrality and better represent the diverse interests of its international membership. Independence also provides BAFT members with greater influence over the association’s long-term strategic direction and services.

“While organizational structures may have changed, BAFT’s mission remains resolute. We will continue to provide the high-impact advocacy, insight, and global engagement our members rely on. As an independent entity, we are better able to adapt to the shifting demands of international commerce and provide leadership with global impact,” said Burwell.

Founded in 1921 by 10 midwestern U.S. bankers, BAFT became a wholly owned subsidiary of the ABA in 2001 and later merged with the International Financial Services Association (IFSA) in 2010. Since then, BAFT has grown significantly in scope, reach, and impact—today, more than 70% of BAFT’s member banks are headquartered outside of the United States. With members in over 60 countries, BAFT operates five regional councils that support the global transaction banking community.

About BAFT
BAFT is the leading global industry association for international transaction banking. Bringing together financial institutions, service providers, and the regulatory community, BAFT provides thought leadership, advocacy, education, and a platform for collaboration to promote sound financial practices that foster innovation, efficiency, and commercial growth. The association engages in a broad range of issues affecting transaction banking, including trade finance, payments, and compliance, helping members navigate a rapidly evolving global landscape. For more information about BAFT, visit baft.org, or follow BAFT on X (Formally Twitter), LinkedIn, and YouTube.

Via Trade Finance Global by Glee Baniago

Navigating the trade finance landscape, with constant dodgeballs in the form of geopolitical tensions, regulatory requirements, and threatening technology, requires considerable agility. But this year’s BAFT Global Annual Meeting, in Washington, DC, revealed the considerable opportunity in times of turbulence.

These takeaways are drawn from the following sessions: 

  • ‘Beyond Buzzwords: Supporting a Fair and Inclusive Workplace’, featuring Shannon Manders, Editorial Director, GTR (moderator); Leigh Amaro, Head of North America, Swift; Priya Raghavan, Managing Director and Head, US & Canada Financial Institutions, BBVA; James Rausch, Managing Director, Head, Global Transaction Banking, Royal Bank of Canada; and Nick Smit, Head, Financial Institutions Americas, ING
  • ‘AI: Leading the Way in the Future of Finance’, featuring Manuela Veloso, Head of AI Research, JPMorgan; and Mike Katergaris, Head of North America Financial Institution Sales, JPMorgan
  • ‘Meaningful Collaboration for Enhancing the Client Experience in Supply Chain Finance (SCF)’, featuring Wouter Hazenberg, Managing Director – Head of VCF Supplier Finance North America, Rabobank; and Flav Pop, Director, Financial Partnerships, PrimeRevenue

1. Banks and fintechs are choosing collaboration over competition

The traditional rivalry between established banks and fintech disruptors is giving way to partnerships which leverage each other’s strengths; banks can typically provide deep client relationships and multi-currency funding capabilities, whilst fintechs handle complex supplier onboarding and electronic time drafts.

This shift reflects mounting client expectations for real-time analytics, automated payment execution, and comprehensive supply chain visibility, a demand so large it is impossible to solve alone. The approach is proving commercially successful: joint responses to client RFIs are becoming commonplace, with customers explicitly requesting collaborative solutions that neither party could deliver independently.

2. Geopolitical tensions are accelerating supply chain localisation

Samarium is a rare-earth metal used in military-grade magnets, and its supply is entirely controlled by China. This should serve as an emblem of the wider inefficiencies in the geopolitical ecosystem, where skyrocketing tariffs (from the US and in response) are forcing companies to rethink global dependencies.

The rhetoric around this is largely politicised. Returning to Samarium, the magnets which it produces are critical components in missiles, smart bombs, and fighter jets, making it clear that whoever controls such resources has a large stake in military capabilities and strategy. 

But rethinking has created new opportunities for trade finance providers. The renewable energy sector and the data centre supply chain particularly illustrate this shift. The rapid expansion of the data centre sector has led to streamlined procurement and modular construction, but has also exposed an over-reliance on a small pool of suppliers, contractors, and standardised components. As such, massive data centre projects exceeding two gigawatts require localised supply chains to ensure resilience. Tesla’s ‘Gigafactory Nevada’ battery facilities and in-house lithium refining operations represent the future that many corporates are moving towards.

3. Gender diversity in trade finance remains stubbornly poor despite business benefits

In GTR’s first comprehensive gender diversity survey, 47% of respondents reported women hold just 0-5% of C-suite positions in trade finance organisations; 45% of employees don’t know whether their organisation has gender pay parity policies, suggesting fundamental communication failures around diversity initiatives.

There’s a business case for inclusion which extends beyond the ethical one. McKinsey data shows that companies prioritising diversity achieve a 39% greater likelihood of outperforming peers on profitability. Yet the sector appears to have embraced technological partnerships more readily than workplace inclusion. As the industry transforms through artificial intelligence (AI) and embedded finance, diverse perspectives will become increasingly valuable.

4. Human-AI collaboration is essential, but scale demands AI-to-AI verification

The integration of AI across trade finance operations is moving beyond experimental phases into practical applications. Fintech providers are leading this adoption, using AI to optimise supplier onboarding programmes and enhance real-time analytics capabilities that clients increasingly demand.

Deep-tier supplier finance – extending credit down the supply chain to suppliers’ suppliers – exemplifies AI’s potential impact. While still in its infancy, this approach can unlock significant value by financing entities that might otherwise pay 6-7% interest rates. As AI capabilities mature and processes become increasingly automated, industry leaders predict this will enable financing of entire value chains more efficiently, making supply networks more resilient while reducing overall borrowing costs.

While banks have traditionally focused on data analysis and pattern recognition, AI agents can understand policies, execute rules, and take actions based on business knowledge, and could present a space to watch in the future. This could render the ‘human in the loop’ approach redundant when dealing with systems that can process hundreds of sources: ‘AI checking AI’ could be implemented, with humans performing random spot checks to build trust over time. 

This approach mirrors how we learned to trust GPS navigation systems like Waze. Banks need to develop systematic verification processes where different AI models cross-reference results, and humans validate randomly selected outputs to maintain quality control while leveraging AI’s scale advantages.

Whether agentic AI or otherwise, the competitive consequences of avoiding AI adoption could be fatal, all the while maintaining data security and regulatory compliance.

5. Accounting transparency requirements are unexpectedly boosting market adoption

The introduction of IFRS and FASB disclosure requirements for supplier finance programmes initially sparked industry concern about potential market contraction. Rating agencies like S&P began scrutinising programmes more closely, with blanket rules such as treating anything over 90 days as debt regardless of industry context.

However, the opposite effect has materialised. Increased transparency has actually attracted new corporates to consider supplier finance: the global supply chain finance market is projected to grow at a compound annual growth rate of 8.8% from 2022 (the year the new standards took effect) to 2031.

While some programmes with excessive payment terms or disproportionate balance sheet dependency have scaled back, the clearer regulatory framework has provided confidence for new entrants. Industry participants now argue for more nuanced rating agency approaches that consider sector-specific norms, recognising that 30-day terms suit perishable goods like dairy, whilst 360-day terms may be appropriate for capital equipment like wind turbines.

Washington, D.C. – BAFT, the leading global industry association for international transaction banking, has published a new white paper titled “ISO 20022 Migrations: Lessons Learned in Sanctions & Compliance.” This latest publication is part of BAFT’s ongoing efforts to support the financial industry in navigating the complex landscape of global payment modernization and regulatory compliance.

The white paper captures practical insights from early adopters of ISO 20022, specifically focusing on the challenges and strategies related to sanctions screening and financial crime compliance. As financial institutions transition to richer data formats and structured messaging, the paper highlights both the operational and regulatory implications, and provides actionable recommendations for compliance professionals and technology teams.

“ISO 20022 has introduced new dimensions to data quality, transparency, and risk management,” said Deepa Sinha, senior vice president of payments & financial crimes, BAFT. “This white paper addresses a critical area—how the migration impacts sanctions and compliance operations—and offers lessons that can benefit banks still undergoing or preparing for the transition.”

Key themes explored in the white paper include data truncation and translation issues, evolving regulatory expectations, technology enablement, and the need for cross-functional collaboration between compliance, operations, and IT. The white paper is available to BAFT members and the broader industry community on the BAFT website.

Click here to read BAFT’s ISO 20022 Migrations: Best Practices & Guidance. The white paper is also available within BAFT’s Library of Documents under the Guidance and Industry Practices section.

About BAFT

BAFT, the leading global financial services association for international transaction banking, helps bridge solutions across financial institutions, service providers and the regulatory community that promote sound financial practices enabling innovation, efficiency, and commercial growth. BAFT engages on a wide range of topics affecting transaction banking, including trade finance, payments, and compliance.

BAFT Media Contact:
Blair Bernstein
Senior Director, Public Relations
[email protected]
+1 (202) 663-5468

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