Joint Recommendations for the Trilogue Negotiations on AMLR

The Payments Innovation Forum has joined a coalition of associations from the retail, payments and gift card industry in calling on the European Parliament and Council to incorporate an e-money exemption in the final text of the Anti-Money Laundering Regulation (AMLR). 

While the European Parliament has considered the introduction of a provision to exclude certain types of e-money products from the Customer Due Diligence requirements in Article 15(3), we remain concerned that the proposed exemption is still too narrow and establishes further requirements which are difficult to meet in practice. We are therefore calling for a widening of the scope of the proposed exemption to cover e-money products that are currently in the market.

The current drafting is further strictly limited to the purchase of goods and services in a single Member State. This requirement contradicts the goal to strengthen the internal market, speaks against the idea of the European Union and jeopardises the concept of the European passport for e-money issuers. In practice, it also leads to a high degree of legal uncertainty as it remains unclear how that provision would apply in relation to the online use of e-money, which is a significant use case and growing in importance. The limitation to a single Member State should therefore be deleted. 

Read the joint recommendations in full: