The EACB appreciates the opportunity to comment on the EBA draft Guidelines on preventing the abuse of funds and certain crypto-assets transfers for money laundering and terrorist financing purposes under Regulation (EU) 2023/1113 (the ‘Travel Rule’ Guidelines).
The proposals made under these draft Guidelines are welcome, however, to ensure a logical and practical framework under the Transfer of Funds Regulation, we suggest taking into consideration the following points under the relevant Guidelines:
Guideline 2.1 on determining whether a card, instrument or device is used exclusively for the payment of goods or services.Guideline 2.2 on Linked transfers in relation to the 1000 EUR threshold
Guideline 3.2 on Multi-intermediation and cross-border transfers
Guideline 3.3 on Batch transfers: the newly introduced requirement of ‘alternative channel mechanism’ imposed on PSPs would imply unproportionate costs for PSPs
Guideline 4 on Information to be transmitted with the transfer
Guideline 4.1 on Providing the payment account number of the payer
Guideline 4.2. on Providing the name of the payer
On Guideline 5.3. monitoring of transfers
Please refer to the EACB asnwer for more details.