The EMA welcomed an opportunity to provide input to the implementation of 4MLD in Luxembourg, and submitted a letter on 25 August.
The letter set out the EMA’s position on the customer due diligence and local point of contact provisions:
- providing rationale and support for applying the Article 12 e-money exemption from CDD;
- setting out the importance of implementing the Article 15 simplified due diligence provisions as only a limited type of product can benefit from the Article 12 exemption;
- emphasising that someone from an issuer’s home office e.g. MLRO, would be better placed to provide a convenient point of engagement in the context of the local point of contact requirement.
We also commented on the implementation of Fund Transfer Regulation Article 2(5)(b), in support of exercising the member state option to exempt national transactions under EUR 1000 for goods and services where the transaction has a unique identifier.
Full details of the EMA’s letter can be found here.