Regulatory Alerts2023-10-10 | NBB_2023_08Added · Updated
Horizontal analysis of transactions carried out through tied agents of payment institutions
The National Bank of Belgium requires money remitters to implement annual, risk-based agent review plans and ensure data quality by eliminating duplicate customer and beneficiary identifiers. Institutions must set justified transaction thresholds calculated over floating periods rather than calendar months, and apply enhanced due diligence measures that require corroborating evidence for high-risk transactions instead of relying solely on declarative information. Furthermore, payment institutions are expected to analyze atypical facts, such as rapid sequential transactions by different customers at the same agent, and conduct new risk assessments for customers previously subject to suspicious transaction reports.