Response to consultation on Guidelines to prevent transfers of funds can be abused for ML and TF

Go back

Question 1: Do you agree with the general considerations in Chapter 1? In particular, do you agree that these are necessary to ensure an effective, risk-based and proportionate approach to complying with Regulation (EU) 2015/847? If you do not agree, clearly set out your rationale and provide supporting evidence where available. Please also set out what you consider to be the common principles that apply to both, the PSP of the payee and the intermediary PSP, and why.

We do agree

Question 2: Do you agree that the expectations on intermediary PSPs and PSPs of the payee in Chapter II are proportionate and necessary to both comply with Regulation (EU) 2015/847 and ensure a level playing field? In particular, do you agree with: • The steps PSPs should take to detect and manage transfers of funds with missing information of inadmissible characters or inputs? • The steps PSPs should take to detect and manage PSPs that are repeatedly failing to provide the required information? If you do not agree, clearly set out your rationale and provide supporting evidence where available. Please also set out at what you believe PSPs should do instead, and why.

We do agree

Question 3: Do you agree with the provisions for intermediary PSPs in Chapter III? If you do not agree, clearly set out your rationale and provide supporting evidence where available. Please also set out how you think intermediary PSPs can meet their obligations in Article 10 of Regulation (EU) 2015/847 instead.

We do agree

Question 4: Do you agree with the provisions for PSPs of the payee in Chapter IV? If you do not agree, clearly set out your rationale and provide supporting evidence where available. Please also set out how you think PSPs of the payee can meet their obligations instead.

We do agree

Name of organisation

Magic Compass Limited