Author: aplatero
Branch vs Freedom of Services: when each is the right EU passporting model
Side-by-side of the two cross-border models: physical presence, supervisory architecture, local AML rep, host-state reporting, tax footprint and timing. When FoS fits,…
DORA Article 30: the mandatory clauses for ICT contracts
Every clause Article 30 of DORA requires in ICT contracts, with the additional requirements for services supporting critical or important functions: audit…
UIF Italy and the Archivio Unico Antiriciclaggio
Italy's daily AML archive and SOS reporting to UIF: D.Lgs 231/2007 obligations, the Archivio Unico Antiriciclaggio's daily-update rule, INFOSTAT-UIF intake, the OAM-agent…
MiCA Travel Rule: the Funds Transfer Regulation for crypto
Regulation (EU) 2023/1113 in practice: what data must travel with every crypto-asset transfer, the EUR 1,000 self-hosted-wallet attestation rule, the receiver-side checks…
PSD3 and the Payment Services Regulation: a tracker
Living tracker on PSD3 and the PSR: the open-banking redesign, fraud-loss allocation, non-bank access to settlement systems, the merger of EMI and…
CRS for EMIs: when an EMI is a Reportable Financial Institution
How CRS / DAC2 catches EMIs holding named customer accounts: the Reporting Financial Institution test, due diligence, what data must be filed…
§43 GwG — filing SARs in Germany via goAML
German SAR reporting under §43 of the Geldwäschegesetz: the 'Tatsachen' (facts) threshold, the goAML Germany portal, the §46 three-day freeze, and how…
FIU-Nederland — UTR reporting through goAML
Dutch unusual-transaction reporting under the Wwft: the broader 'unusual' standard versus 'suspicious', objective and subjective indicators, the goAML portal, and the link…
TRACFIN — filing a déclaration de soupçon in France
Filing French suspicious-activity reports through TRACFIN: the soupçon threshold, the ERMES portal, the named déclarant and correspondant roles, the without-delay timing rule,…
Sanctions screening at instant-payment speed
How the IPR shifts sanctions screening from per-transaction to customer-level — at-least-daily refresh, the 10-second SCT Inst envelope, false-positive tooling, and the…