PVDC Sets Out Financial Crime Expectations for Future Payments Infrastructure

The Payments Vision Delivery Committee (PVDC) has published a policy paper clarifying how the United Kingdom's next-generation retail payments infrastructure should accommodate financial crime controls, providing supporting context to the design consultation opened by the Retail Payments Infrastructure Board (RPIB) on 25 June 2026. The RPIB consultation, chaired by the Bank of England, addresses the core clearing and messaging layer that will eventually replace the rails underpinning Faster Payments and Bacs, and closes on 11 September 2026.

The commercially and operationally significant point for compliance functions lies in how the PVDC has divided responsibility across the ecosystem. The paper distinguishes between the core infrastructure, envisaged as a shared national utility operated on a cost-recovery basis by a single operator, and the product-level arrangements that will sit above it, governing individual payment journeys, liability, dispute resolution and merchant acceptance. Financial crime controls are expected to function across both layers. The core is intended to provide a baseline of consumer protection and to support prevention, data sharing and reporting, while product-level arrangements may layer enhanced safeguards according to the risk profile of a given payment journey.

That architecture carries direct implications for firms. The document confirms that the wider ecosystem must incorporate robust measures against fraud, money laundering, sanctions evasion and terrorist financing, with the infrastructure itself positioned to support prevention and information sharing rather than to displace institutional obligations. The explicit reference to programmable and artificial intelligence (AI)-driven payments signals that scheme-level design is being shaped around transaction types that will complicate conventional monitoring, screening and attribution. Practitioners should anticipate that a risk-differentiated model, where baseline protections apply universally and stronger controls attach to higher-risk journeys, will require correspondingly granular risk assessment at the product layer.

The paper is expressly not a statement of policy or regulatory guidance and does not prejudge future work; its function is to inform responses to the RPIB consultation. That status is worth noting, but the direction of travel is instructive. The five outcomes set by the PVDC's November 2025 strategy include protection from fraud and financial crime alongside interoperability between forms of digital money, and the current update should be read against HM Treasury's 21 April 2026 package consolidating the Payment Systems Regulator (PSR) into the Financial Conduct Authority (FCA). Firms with a view on where financial crime accountability should sit, between operator, scheme and participant, have a defined window to shape it before the design hardens.