As Susanne already covered in her latest blogpost about Payment Initiation Services, Account Information Services and the AML regulations, there will be two new payment services under PSD2: Payment Initiation Services (PIS) and Account Information Services (AIS). But does it really make sense that they are subject to the relevant anti-money laundering (AML) laws? How is this question being dealt with in the transposition laws across different EU member states?
AIS, PIS and co. What do we have for the future?
And what’s going to happen if, in the future, we face EU member states that make these new payment services subject to strict AML requirements, e.g. face-to-face customer identification, while others grant exemptions? Will that mark the end of such services for certain regions? On the other hand – in times of terror attacks – it is difficult to argue in favour of less strict AML regimes.
So what is behind the law? How can, will and should it be interpreted? And what do industry insiders, such as Nadja van der Veer who touched upon this topic in one of her recent LinkedIn posts and others who commented on the blogpost think about this?
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