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Yearly Archives: 2017

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THE ESA RISK FACTORS GUIDELINES: CONTRIBUTING TO OR HURTING A RISK-BASED APPROACH?

AMLBy Nadja van der VeerNovember 10, 2017Leave a comment

Under 4AMLD, ESA has been assigned the task to issue guidelines on risk factors to be taken into consideration and the measures to be taken in situations where both simplified CDD and enhanced CDD measures would be appropriate. A final version of these Guidelines were issued in June and is appropriately called “The Risk Factors…

PSD2: THE RISE OF CONSUMER COMPLAINTS?

PSD2By Nadja van der VeerJanuary 10, 2017Leave a comment

PSD2 Fact 5: The Rise of Consumer Complaints? One of the areas that PSD2 is enhancing is consumer protection. Customers of Payment Institutions have the right to bring their claims to court, however the European Commission offers an alternative dispute resolution (ADR) route under PSD2 for payment service users. Pursuant to consideration 98, Member States…

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