Regulatory Alerts2023-12-12
Added · Updated
Good Practices for Sub-Merchants
De Nederlandsche Bank N.V. provides non-binding guidance for payment institutions and electronic money institutions on managing money laundering and terrorist financing risks associated with sub-merchants. The document requires institutions to incorporate sub-merchant risks into their systemic integrity risk analysis and adopt specific customer due diligence policies, including risk profiling and ongoing monitoring of sub-merchant activities. It further mandates adjustments to transaction monitoring systems, such as developing specific business rules and maintaining current transaction profiles based on aggregated sub-merchant data to detect unusual patterns effectively.