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And FMI compliance generally, notably no 1 Legal basis, "An FMI should have a well-founded, clear, transparent, and enforceable legal basis for each material aspect of its activities in all relevant jurisdictions."

Seem to have omitted need for wire transfer regs compliance: full ULTIMATE payor and bene information, shared end to end with all PSPs and VASPs in the chain, with pre-scrreing and seizure of funds in the event of a sanctions 'hit' until verified to be a false positive.

It just makes you wonder how it addresses the legal challenge of potentially being classified as cherry-picking, i.e. that a bank decided to PVP only some transactions, with some counterparties in the event of default.

Interesting optic to apply to the MasterCard take-over of VocaLink?  And PSR's role in this.