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- In the current EU AML/CFT legislation, Member States are allowed to exempt obliged entities from carrying out certain customer due diligence (CDD) measures with respect to e-money products with a proven low risk (Article 12 AMLD).
- To be able to make use of the exemption, various requirements must be met. These include a low threshold of 150 Euro for offline transactions and 50 Euro in the case of remote/online transactions In addition, issuers are obliged to conduct sufficient monitoring of the transactions or business relationship to detect unusual or suspicious transactions.
- This exemption is no longer included in the latest EU Commission’s AML/CFT proposal, without any justification and without actually contributing to the fight against ML/FT.
- The important exemption, which is to the great benefit of customers, is currently being applied to offer numerous prepaid products, like e money gift cards and vouchers. It plays a very important role in order to maintain the attractiveness of these products and to provide customers with easy access to digital means of payment. These products are now at risk of disappearing from the market. This would also entail negative consequences for issuers, their customers, merchants and businesses distributing such products, as well as for the digital economy as a whole.
- The signatories of this position paper firmly advise and call on the co legislators to retain the exemption for low risk, low value e money products in the AML Regulation for the benefit of customers, proportionate data collection, financial inclusion and to support digitisation and innovative business models.