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AI Summary of 11.13

Version date: 1 March 2021 - onwards

11.13

Firms should in any case put in place:

a) systems to identify linked transactions, including those that might amount to a business relationship according to their policies and procedures, such as systems to identify series of transactions bellow EUR 1 000 which have the same payer and payee and an element of duration;

b) systems to identify whether transactions from different customers are destined for the same payee;

c) systems to permit as far as possible the establishment of the source of funds and the destination of funds;

d) systems that allow the full traceability of both transactions and the number of operators included in the payment chain;

e) systems that identify whether a transfer is made to, or received from, a high risk third country; and

f) systems to ensure that throughout the payment chain only those duly authorised to provide money remittance services can intervene.