EPIF recently submitted its response to the EBA’s public consultation on the draft Regulatory Technical Standards (RTS) on new AMLA mandates. With over 300 direct and indirect members representing the non-bank payments sector, we have provided constructive input on how to ensure proportional, risk-based, and practical anti-money laundering rules.

Here are a few key takeaways from our submission:

• Strong call for a risk-based approach
  EPIF urges the EBA to preserve flexibility by ensuring that AML requirements are applied based on demonstrated risk levels and actual transaction behaviour, rather than a one-size-fits-all model across low-, medium-, and high-risk categories.
• Support for digital identity and innovation
  EPIF calls for harmonisation of eIDAS data across the EU, and the promotion of API-based and digital-first onboarding solutions – stressing that non-face-to-face onboarding should not be automatically deemed riskier.
• Clarification needed on key definitions and procedures
  EPIF raises concerns about ambiguities around definitions and requirements for proof of place of birth or beneficial ownership, especially in jurisdictions lacking central registries or standardized documents.
• Concerns over proportionality in customer due diligence
  EPIF highlights the need to calibrate document requirements according to risk levels. Applying the same stringent rules to low-risk clients could hinder efficiency and innovation without improving AML controls. This also applies to low-value e-money products: clear, risk-based rules set by Level 1 legislation should not be constrained by overly prescriptive RTS criteria.
• Recommendations on sanctions and supervisory measures
  Before imposing pecuniary penalties, EPIF recommends that authorities allow entities time to submit an action plan and show remediation progress.