The following factors may contribute to increasing risk:

a) Online and non-face-to-face distribution without adequate safeguards, such as electronic signatures, electronic identification means meeting the criteria set out in Regulation (EU) No 910/2014 and anti-impersonation fraud measures.

b) Distribution through intermediaries that are not themselves obliged entities under Directive (EU) 2015/849 or national legislation where applicable, where the e-money issuer:

i. relies on the intermediary to carry out some of the AML/CFT obligations of the e-money issuer;

ii. has not satisfied itself that the intermediary has in place adequate AML/CFT systems and controls; and

iii. segmentation of services, that is, the provision of e-money services by several operationally independent service providers without due oversight and coordination.