Article 26 Risk factors


This is a draft act

This text has been parsed from the AMLA final report draft as published on 30 September 2026. While we run a suite of validations, the automated parsing can result in errors. Also, before it is finally adopted by the Commission, its wording, numbering and references may change, and entire articles might be removed or added.

Earlier drafts: AMLA consultation paper draft (9 February 2026)

  1. Where supervisors decide to allow for an exemption specified under Article 19(7) of Regulation (EU) 2024/1624, supervisors shall consider one or more of the following risk factors to determine the extent of that exemption:

    1. the extent to which the payment instrument has low transaction limits or thresholds to limit transaction values;

    2. the nature of the goods or services that can be acquired, including the level of risks associated with these goods and services;

    3. the extent to which the transactions through the electronic money instrument are executed by an obliged entity that applies customer due diligence measures and record-keeping requirements laid down in Regulation (EU) 2024/1624;

    4. the extent to which the payment instrument has a specific and limited duration in which it can be used;

    5. the extent to which the payment instrument is available through direct channels, which may include the issuer or a network of service providers;

    6. the extent to which the payment instrument has a limited geographical distribution;

    7. the extent to which the issuer applies adequate safeguards, including geofencing, monitoring, IP tracking and other technological measures to detect and prevent unauthorised activity and to restrict access to the payment instrument from third counties;

    8. the extent to which the issuer has measures in place to monitor the merchants that accept payments through the payment instrument in order to prevent and detect suspicious activities;

    9. the measures implemented by the issuer to detect and prevent suspicious bulk purchasing of the payment instrument by or for the benefit of the same person.

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