Following the joint EU fintech industry statement on the EU's proposed AML Regulation, issued on May 17, 2023, ETPPA, together with EMA, EPIF, EFA and OFA, are calling on the co-legislators and the European Commission to clarify the compromise text reached on recital 34 of the AML Regulation in the technical trilogues, in order to ensure that the text does not kill European payment initiation services (PIS).

In summary:
● Inequitable treatment of PISPs compared to card acquirers
● Homegrown EU fintechs to be left at serious and unwarranted competitive disadvantage
●EU legislators urged to clarify Recital 34 so that PISPs’ CDD obligation relate only to
merchants

It is our view that the current draft compromise text for recital 34 needs to be further clarified in two crucial respects, and as we explain in the joint statement. We are confident this can be done within the realm of the already existing political agreement. Otherwise, it will be impossible for European PISPs to compete with other payment solutions such as card acquirers (Visa/Mastercard), ApplePay and Ideal/EPI, all of whom have to perform due diligence only on the merchant to whom they provide services.