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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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