Money remitters using agents to provide payment services should know who their agents as set out in Article 19 of Directive (EU) 2366/2015 are. As part of this, money remitters should establish and maintain appropriate and risk-sensitive policies and procedures to counter the risk that their agents may engage in, or be used for, ML/TF, including by:

a) Identifying the person who owns or controls the agent where the agent is a legal person, to be satisfied that the ML/TF risk to which the money remitter is exposed as a result of its use of the agent is not increased.

b) Obtaining evidence, in line with the requirements of Article 19(1)(c) of Directive (EU) 2015/2366, that the directors and other persons responsible for the management of the agent are fit and proper persons, including by considering their honesty, integrity and reputation. Any enquiry the money remitter makes should be proportionate to the nature, complexity and scale of the ML/TF risk inherent in the payment services provided by the agent and could be based on the money remitter’s CDD procedures.