The sixteenth recommendation of the FATF establishes that financial entities carrying out bank transfers must require information about the sender as well as the recipient of the transfer. This information must remain linked to the transfer to prevent money laundering and terrorism financing. To shape this recommendation, the European Union adopted in 2015 Regulation 2015/847 on the information accompanying fund transfers.
Regulation 2015/847 sets out rules on the information that must accompany fund transfers, regardless of the currency used, in order to detect, prevent, and investigate possible money laundering or terrorism financing operations.
Scope of Application
Article 2 of the European regulation states that the Regulation applies to fund transfers made in any currency, “sent or received by a payment service provider or an intermediary payment service provider established in the Union.”
Services such as payment transactions carried out between payment service providers, their agents, or branches on their own behalf, and fund transfers to pay for goods or services using a card or another digital device, among other exclusions, are excluded from the scope of this Regulation.
Obligations of the Sender
The sender’s payment service provider must include the following information in the fund transfer related to the sender:
- Name of the sender;
- account number — if the transfer is not made from a payment account, it must include a unique transaction identifier —;
- address, official identity document number, customer identification number, or date and place of birth.
The Regulation requires verification of the accuracy of the sender’s information through documents, data, or information obtained from reliable sources. Regarding the information about the recipient, the sender’s payment service provider must obtain:
- the recipient’s name, and
- the recipient’s payment account number.
However, when all the payment service providers involved in the fund transfer are established within the Union, the transfer must at least contain the account number of both the sender and the recipient. The aforementioned information may be requested by the recipient’s service provider in cases where the transfer exceeds €1,000, whether in a single transaction or in several transactions considered linked.
Obligations of the Recipient
The obligations of the recipient’s payment service provider revolve around receiving the information linked to the fund transfer. The recipient’s payment service provider must implement effective systems and procedures to detect information about the sender and recipient that is linked to the fund transfer.
If the service provider detects that information is missing from the fund transfer, they may reject the transfer or accept it while requesting more information from the sender’s payment service provider. Consequently, effective, risk-based procedures must be in place to determine how to act in such a situation.
Furthermore, if a payment service provider frequently fails to provide the required information, the other party may take measures ranging from issuing warnings to restricting or terminating the business relationship with that payment service provider.
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