How does AMLD5 affect the E-Money thresholds for customer due diligence (CDD) in the UK?
Under MLR 2017, certain lower-risk e-money products were exempt from <a href="/glossarycollection/customer-due-diligence" style="color:#48277C;" target="_blank" title="Customer Due Diligence"><u>CDD </u></a> requirements. MLR 2019 reduces the thresholds so that an exemption is only available where all of the following conditions are met:<br/><br/>
- The maximum amount that can be stored electronically is reduced from EUR 250 to EUR 150;<br/><br/>
- The payment instrument used in connection with the electronic money is not reloadable or has a maximum limit on monthly payments of EUR 150, which can only be used in the UK (previously EUR 250);<br/><br/>
- The payment instrument is used exclusively to purchase goods and services;<br/><br/>
- Anonymous e-money is not used to fund the payment instrument; and any redemptions in cash, or remote payment transactions, do not exceed EUR 50 per transaction (previously EUR 100).<br/><br/>
MLR 2019 also prohibits financial institutions from accepting payments which are carried out using anonymous prepaid cards issued in non-EU countries unless those non-EU cards meet requirements that are equivalent to the EU's AML rules for those products. This requirement comes into force on 10 July 2020.