Article 9 Assessment and reporting

This brief but important article connects the information requirements established in earlier articles to the broader anti-money laundering framework.

It places an obligation on the payee's payment service provider to factor in missing or incomplete payer and payee information when conducting suspicion assessments, and links that assessment directly to the reporting obligations under Directive (EU) 2015/849, which governs AML/CFT compliance more broadly.

Important points:

• As the payee's payment service provider, treat missing or incomplete information on the payer or payee as a factor in your suspicion assessment for any transfer of funds or related transaction.
• This obligation connects to your reporting duties — if a transaction is deemed suspicious, it must be reported to the Financial Intelligence Unit (FIU).
• The article reinforces the purpose of the information requirements in preceding articles by ensuring gaps in that information carry real compliance consequences.