Clarify Recital 34, Save PIS, EU AML Regulation’s Urgency

February 4, 2024
1 min read

TLDR: A group of paytech representatives, including the European Third Party Providers Association (ETPPA), the European Fintech Association (EFA), the Electronic Money Association (EMA), and the European Payment Institutions Federation (EPIF), have called on legislators to clarify Recital 34 of the EU anti-money laundering (AML) regulation. They are concerned that without further clarification, European payment initiation services (PIS) could be at risk. Recital 34 needs to be clarified in two crucial respects, according to the organizations. They argue that payers using PIS should only be subject to customer due diligence (CDD) obligations in relation to the merchant, not the payer. Additionally, they believe that the proposed last sentence of Recital 34 discriminates PIS against other payment types. The groups are urging European legislators to ensure that Recital 34 makes it clear that merchant-facing PISPs should only perform CDD on the payee.

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