Publications and events

Malta: a Leading European Payments and e-Money Destination

E-money seminar on Malta as a leading European payments and e-money destination, 8 November 2016 in London,

Dr Thaer Sabri joined a number of speakers, discussing the impact of Brexit on the industry UK

The seminar did also provide delegates with information on Malta as a jurisdiction and how one would go about setting up a PSP / EMI, covering also a debate on the opportunities and challenges in relation to: the industry; regulations such as PSD II; and financing such as raising capital, exit strategies, mergers and acquisitions.

Fine more information in this event here.

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EMA comments on 4MLD implementation in Latvia

EMA comments on 4MLD implementation in Latvia

We set out our position on the implementation of customer due diligence and local point of contact provisions in 4MLD in a letter sent to the Latvian Ministry of Finance on 27 September.

The letter made a number of comments similar to those set out in previous responses to other EEA member states. These included:

  • Article 12exemption from CDD for some e-money products: we set out a compelling argument for the retention of this provision. While the exemption does not create vulnerabilities, products issued under this Article benefit, for example, the financially excluded segment of the population;
  • Articles 15, 16 and Annex IIthat allow SDD for low-risk products; we emphasised the importance of these provisions for EMIs that rely on the risk-based approach under Article 15 to onboard new customers;
  • disproportionality of the local point of contact requirement under Article 45(9), highlighting that someone located at the central office (e.g. compliance officer or MLRO) would be more knowledgeable and better able to engage with the Latvian regulator.

Read full letter here.

 

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EMA response to Austrian consultation on 4MLD

EMA response to Austrian consultation on 4MLD

We submitted a letter to the Austrian Ministry of Finance on 27 September, welcoming their proposals to no longer include EMIs passporting into Austria on a cross-border basis within the scope of the AML laws.

Although the draft law included the SDD provisions set out in Article 15, it did include the Article 12 e-money exemption. In setting out our arguments, we urged the regulator to consider implementing the exemption.

Regarding the requirement for a local point of contact, we provided arguments similar to those in previous EMA responses to member states’ 4MLD consultations, highlighting that the exchange of information can be facilitated effectively without imposing such a requirement.

The full response can be found here.

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