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Threshold-based data
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EUR 1,000
Natural Person/Legal Entity
Domestic:
If additional information is requested, then:
- < EUR 1,000: a), b), d), e);
- > EUR 1,000: a), b), c), d), e).
Cross-border:
The following data should be transferred:
- < EUR 1,000: a), b), d), e);
- > EUR 1,000: a), b), c), d), e).
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Domestic vs cross-border transfers
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There is a difference.
Natural Person:
Domestic. The following data should be transferred: b) and e). However, within three working days of receiving a request for information from the beneficiary's CASP or ICASP, the following data should be made available:
- < EUR 1,000: a), b), d), e);
- > EUR 1,000: a), b), c), d), e).
Cross-border. The following data should be transferred:
- < EUR 1,000: a), b), d), e);
- > EUR 1,000: a), b), c), d), e).
Legal Entity:
Domestic. The following data should be transferred: g) and j). However, within three working days of receiving a request for information from the beneficiary's CASP or ICASP, the following data should be made available:
- < EUR 1,000: f), g), i), j);
- > EUR 1,000: f), g), h); i), j).
Cross-border. The following data should be transferred:
- < EUR 1,000: f), g), i), j);
- > EUR 1,000: f), g), h); i), j).
Sumsub has submitted a request to the Jersey Financial Services Commission for clarification on the application of the rules concerning the minimum threshold amount. This information will be updated upon receipt of the regulator's
response.
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Batch file transfer
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In the case of a batch file transfer from a single originator where the CASPs of the beneficiaries are established outside the EU, the obligation on the CASP of the originator to ensure that information on the originator accompanies transfers of funds shall not apply to the individual transfers bundled together therein, provided that the batch file contains the information on the originator and the beneficiary, that the information has been properly verified, and that the individual transfers carry the account number of the originator or, where the exception is applied, the unique transaction identifier.
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Time and way to share the Information
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The regulation do not explicitly specify the time frame for information sharing. In turn, according to the interpretive note to FATF Recommendation 15, originating CASPs should submit the information on the originator and beneficiary to the beneficiary CASP immediately and securely.
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