Article 13 Assessment and reporting

This brief article sits alongside Article 9, which imposes the same obligation on the payment service provider of the payee.

Article 13 extends that same principle to intermediary payment service providers, requiring them to treat missing payer or payee information as a red flag when evaluating whether a transfer of funds, or any related transaction, is suspicious and warrants reporting to the Financial Intelligence Unit (FIU).

Important points:

• Intermediary payment service providers must factor in missing payer or payee information when assessing whether a transfer is suspicious.
• This suspicion assessment is directly linked to the potential obligation to report to the FIU under Directive (EU) 2015/849.
• The obligation covers not just the transfer itself but any related transaction.