Circular NBB_2025_13 / EBA Guidelines on internal policies, procedures and controls to ensure implementation of national and Union restrictive measures under Regulation (EU) 2023/1113 (EBA/GL/2024/15 of 14 November 2024)

Public NBB_2025_13 – 15 October 2025 Circular – Page 1/2 14 Berlaimont Boulevard – 1000 Brussels Tel. +32 2 221 38 12 Company number: 0203.201.340 Brussels RPM www.bnb.be

Circular
Public
Brussels, 15 October 2025
Reference: NBB_2025_13
Your contact:
Anthony Mention tel. +32 2 221 48 55 anthony.mention@nbb.be

EBA Guidelines on internal policies, procedures and controls to ensure implementation of national and Union restrictive measures under Regulation (EU) 2023/1113 (EBA/GL/2024/15 of 14 November 2024)

Scope
This circular applies to the regulated entities referred to in:

1. Article 5, § 1, first paragraph, 1st subparagraph, 4°, 6° and 7° of the Law of 18 September 2017 1 which provide the fund transfer service referred to in Article 3, point 9) of Regulation (EU) 2023/1113 2 (the ‘PSPs’);
2. Article 5, § 1, first paragraph, 1st subparagraph, 4°, 6°, 7° and 10° of the Law of 18 September 2017 which provide the crypto-asset transfer service referred to in Article 3, point 10) of Regulation (EU) 2023/1113 (the ‘PSCAs’);
   hereinafter collectively referred to as the ‘PSPs and PSCAs’.

Summary/Objectives
The guidelines of the European Banking Authority of 14 November 2024 on internal policies, procedures and controls to ensure implementation of national and Union restrictive measures under Regulation (EU) 2023/1113 (EBA/GL/2024/15) are integrated by the National Bank of Belgium into the exercise of its supervisory mission regarding anti-money laundering and counter-terrorist financing obligations.

These guidelines apply from 30 December 2025. The PSPs and PSCAs shall make all efforts to comply with these guidelines in accordance with Article 16, paragraph 3 of Regulation (EU) No 1093/2010 3.

1 Law of 18 September 2017 on the prevention of money laundering and terrorist financing and the limitation of the use of cash.
2 Regulation (EU) 2023/1113 of the European Parliament and of the Council of 31 May 2023 on information accompanying transfers of funds and certain crypto-assets, and amending Directive (EU) 2015/849 (recast). 3 Regulation (EU) No 1093/2010 of the European Parliament and of the Council of 24 November 2010 establishing a European Supervisory Authority (European Banking Authority), amending Decision No 716/2009/EC and repealing Commission Decision 2009/78/EC.

National Bank of Belgium
Eurosystem

Public NBB_2025_13 – 15 October 2025 Circular – Page 2/2

Madam,
Sir,

By this circular, the National Bank of Belgium (the ‘Bank’) communicates that it integrates the guidelines of the European Banking Authority (‘EBA’) of 14 November 2024 on internal policies, procedures and controls to ensure implementation of national and Union restrictive measures under Regulation (EU) 2023/1113 (EBA/GL/2024/15; the ‘guidelines’) into the exercise of its supervisory mission regarding anti-money laundering and counter-terrorist financing obligations referred to in Article 36/2, § 2 of the Law of 22 February 1998 laying down the organic statute of the Bank.

The guidelines detail the requirements regarding screening systems and the policies and procedures that the PSPs and PSCAs must put in place under Regulation (EU) 2023/1113 in order to:
(1) reliably identify targets of restrictive measures (section 4.1 of the guidelines); (2) analyse alerts related to restrictive measures (section 4.2); (3) suspend the execution of fund transfers, freeze funds or crypto-assets, and make the required reports to the competent authority (section 4.3); (4) ensure the ongoing effectiveness of the aforementioned policies, procedures and screening systems (section 4.4).

The guidelines are published on the EBA website (eba.europa.eu) and are annexed to this circular.

They apply from 30 December 2025. The PSPs and PSCAs shall make all efforts to comply with these guidelines in accordance with Article 16, paragraph 3 of Regulation (EU) No 1093/2010.

A copy of this circular is sent to the commissioner(s), approved auditor(s) of your institution.

Please accept, Madam, Sir, the expression of my distinguished consideration.

Pierre Wunsch
Governor

Annex: 1
Guidelines on internal policies, procedures and controls to ensure implementation of national and Union restrictive measures under Regulation (EU) 2023/1113