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Transaction monitoring requirements for account information services (service 8)

Published: 14 May 2018

Question:

Must account information services (service 8) meet the transaction monitoring requirements?

Answer:

The AMLD4 provides that account service providers are not exempted from the transaction monitoring requirements. They must report unusual transactions to FIU-NL. However, an AISP that provides no other payment service does not effect or initiate any transaction under the Wwft and does not form part of the payment chain, but merely provides an overview. DNB will consider how this statutory requirement can be put into practice.