In 2020, the Group of Twenty (G20) launched its Roadmap for Enhancing Cross-Border Payments to “benefit citizens and economies worldwide, supporting economic growth, international trade, global development and financial inclusion.”
The roadmap aims to make payments “faster, cheaper, and more transparent and inclusive,” while “maintaining their safety and security.” For four of these five goals, the G20 has set global quantitative targets, covering wholesale, retail, and remittance payments, but the “safety and security” goal does not have targets.
Yet the roadmap process has lacked one critical element: a systematic assessment of whether its ambitious goals are mutually compatible, or whether progress toward one may come at the expense of another.
The ‘travel rule’ as a test case for competing goals
The revised “travel rule” offers a concrete example of the potential tradeoffs the Financial Stability Board (FSB), tasked with coordinating the roadmap’s implementation, may need to consider.
The original travel rule was adopted by the Financial Action Task Force (FATF) after the 9/11 terrorist attacks to ensure that basic information about the sender and beneficiary accompanied wire transfers, that is, “traveled” with the payment message. This information supports anti-money laundering and countering the financing of terrorism (AML/CFT) measures and law enforcement.
In 2025, as a means “to support the G20 roadmap of making cross-border payments faster, cheaper, more transparent and more inclusive”, the FATF broadened the travel rule in principle to all payments and value transfers, including purchases of goods and services. The task force also increased the personal information to travel with that payment to include an individual’s address and birth date. What was previously optional data has now become mandatory. The process followed by FATF relied heavily on member and stakeholder submissions rather than controlled pilots or empirical testing such as the Bank for International Settlements’ Project Mandala.
A tradeoff between safety and inclusion?
FATF was sensitive to the fact that enhanced information requirements could exclude people who lack the data, documents, or means to verify them, especially in low-resource contexts. Some people may not have a birth certificate because they were born in a rural area where births were not formally registered. Others, particularly women and girls, may face gaps in official registration.
The revised travel rule therefore provides some flexibility. For transactions below a threshold that countries may set at no more than $1,000 or €1,000, the so-called de minimis rule allows simplified information requirements.
The $1,000 or €1,000 threshold serves as an upper limit, and countries that have implemented the de minimis rule must set thresholds below that limit. This has created a patchwork that global banks have found difficult to navigate, leading them not to apply the exception for cross-border payments. FATF has been unable to reach agreement on either adjusting the threshold, which was set two decades ago, upwards, or on establishing a uniform limit. Its draft non-binding guidance on the updated travel rule encourages countries to voluntarily set it at the $1,000 or €1,000 mark. But given a lack of consensus among FATF members, a uniform approach remains highly unlikely. Where full information is unavailable, FATF also allows financial institutions to collect substitute information, such as an approximate date of birth verified locally or a village name where no formal residential address exists. The appropriate use of substitute information is vital, but it depends on judgment calls about whether a client genuinely lacks the required information or is attempting to conceal their identity. And experience has shown that institutions tend to err on the side of caution.
For the G20 roadmap, this illustrates a broader challenge: measures that are meant to strengthen the safety and security of cross-border payments can negatively affect the accessibility of cross-border payments. If financial institutions decide not to accept substitute information where permitted, or if the de minimis exception is applied inconsistently across a cross-border payments chain, people who lack formal identifying information may face greater barriers to accessing payment services. This risks creating a tension between the roadmap’s safety and security goal and its financial inclusion goal, even though financial inclusion and financial integrity are mutually reinforcing.
The G20’s inclusion target at the remittance level is to ensure that “more than 90% of individuals (including those without bank accounts) who wish to send or receive a remittance payment” can access cross-border electronic remittance services “by the end of 2027.” However, the World Bank’s Global Findex Database 2025 found that only 79 percent of adults globally and 75 percent in low- and middle-income economies have a financial account of some kind. Closing that gap will be even more challenging if stricter information requirements create additional barriers.
Faster, better, but still secure?
The G20 goals were formulated before the rise of AI-supported fraud and scams, which are increasingly exploiting the speed of payments.
The US G20 Presidency has made it clear that both “improving cross-border payments and addressing payments fraud and scams” are priorities. According to the Organization for Economic Co-operation and Development, 69 percent of reporting jurisdictions experienced an increase in fraud and scams between 2024 and 2025. At the FSB Cross-border Payment Summit in March 2026, Tim Adams, chief executive officer of the Institute of International Finance, similarly warned that “growing payments fraud requires security to retake a prominent place in the agenda.”
AI is adding to the challenge. Interpol just found that AI is linked to more than half of all cybercrime in Africa and that financial, data, and law enforcement authorities in lower-resource contexts often lack adequate capacity. Despite valuable progress against fraud, the combination of AI-enabled fraud and limited regulatory capacity poses an alarming mix.
The G20’s 2021 target in terms of transaction speed at the retail and remittance level is to have “75% of cross-border retail payments to provide availability of funds for the recipient within one hour from the time the payment is initiated and for the remainder of the market to be within one business day of payment initiation, by end-2027.” Progress toward that target has been rapid: the FSB reported in 2026 that “75% of payments reach beneficiary banks in just 10 minutes, with many arriving in seconds.”
Financial institutions generally screen and monitor transactions for sanctions- and crime-combating purposes. When a transaction is flagged, however, it requires further investigation. Real-time and instant payments can leave little time for these controls to operate before funds move. The FATF’s draft guidance acknowledges that sanctions screening and investigation of fast payments may therefore only be possible after the fact, for example through daily rather than real-time screening. And the revised travel rule could exacerbate the challenge, as it requires more personal information to accompany an increasing number of payments.
The UK recognized this tension in 2024, when it gave banks new powers to delay payments for up to seventy-two hours to allow time for crime controls and intervention where necessary.
As payments become faster, there may be fewer opportunities to detect and stop criminal transactions. The G20’s focus on speed could therefore make its goal of safe and secure payments harder to achieve, particularly as AI turbo-charges fraud schemes.
A call to action
The FSB has acknowledged that the G20 roadmap is not on track to meet its ambitious targets. In its latest assessment, it concluded that “more needs to be done at the regional and jurisdictional level to turn the international policy work into real-world gains for end-users and to support economic growth.” In March, Andrew Bailey, governor of the Bank of England and the current FSB Chair, similarly urged stakeholders to “intensify efforts” to implement existing recommendations. Bailey also noted that the process has not yet “reached the point where we have to consider trade-offs.”
But that conversation may be approaching soon. As the case of the revised travel rule demonstrates, improving one dimension of cross-border payments can make it harder to achieve another. It raises fundamental questions about whether, and to what extent, the roadmap’s five goals can all be achieved simultaneously in an environment that has changed dramatically since 2020. The tensions between inclusion and speed on the one hand, and safety and security on the other, are becoming increasingly difficult to ignore. And there are likely more tradeoffs to consider.
As the 2027 deadline for its roadmap targets approaches, the G20 needs to recognize the real tradeoffs in its goals. Rather than focusing solely on implementation, the G20 should task the FSB with identifying, assessing, and transparently communicating where the roadmap’s targets conflict. The G20 should also examine how those tradeoffs differ across markets and jurisdictions and determine which compromises are acceptable for the benefit of all—and which are not.
Ruth Goodwin-Groen is a nonresident senior fellow with the Atlantic Council’s GeoEconomics Center. She is a former adviser to the Australian G20 Finance Track, and as the founding managing director of the United Nations Better Than Cash Alliance was a member of the G20 Global Partnership for Financial lnclusion for ten years.
Louis de Koker is a professor of law at La Trobe University, Melbourne, Australia. He is an expert on financial crime policy and regulation, and a consultant to several national regulators and multilateral institutions.
At the intersection of economics, finance, and foreign policy, the GeoEconomics Center is a translation hub with the goal of helping shape a better global economic future.
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