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">CDD </a> requirements. MLR 2019 reduces the thresholds so that an exemption is only available where all of the following conditions are met: 

- The maximum amount that can be stored electronically is reduced from EUR 250 to EUR 150; 

- 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); 

- The payment instrument is used exclusively to purchase goods and services; 

- 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). 

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.