The European Digital Payments Industry Alliance (EDPIA) welcomes the opportunity to provide its members’ views to the EU Anti-Money Laundering Authority’s public consultation on the future EU Anti-Money Laundering rulebook.
We particularly welcome the opportunity to share our views on the rules covering customer due diligence processes – a theme that is of extreme importance from a business and operational standpoint for payment service providers.
In our response, we call on AMLA to preserve technological neutrality and avoid imposing primary solutions such as the EU Digital Identity Wallet. We believe that this is essential for avoiding disproportionate burdens for firms and allowing for a true risk-based approach to client management.
Similarly, we lay out our considerations to ensure the exemption for low-risk e-money instruments is enforceable and proportionate.
EDPIA will continue to work with policymakers to ensure that the future EU AML rulebook is proportionate and future-proof.
