EPIFis deligted to be hosting a panel on Blockchain on 15th March in Brussels
The European Payment Institutions Federation has written a letter to express its views on the draft text of the Payment Services Directive 2 to coincide with the beginning of the trilogue negotiations amongst policy makers.
The European Payment Institutions Federation has collaborated with the European Digital Media Association, the Electronic Money Association, the Computer and Communications Industry Association and Ecommerce Europe, to jointly promote their concerns on the direction taken in the review of the Payment Services Directive(“PSD2”) in the EU Council’s proposals, addressed to the PSD2 Rapporteur, European Parliament Vice Presiden Antonio Tajani.
The European Payment Institutions Federation is pleased to share its Position Paper on Access to Bank Services. This position paper identifies the various issues and concens of PIs in terms of accessing bank services.
The European Payment Institutions Federation representing the voice of Payment Insitutions accross Europe participated at the first Euro Retail Payments Board (ERPB) meeting held on 16th May 2014. EPIF enaged to an active participation in the various Working Groups who would be formed.
The European Payment Institutions Federation is pleased to share its views on the draft Interchange Fees Regulation. In its paper, EPIF articulates how a number of the central proposals in the draft Regulation would impact small market players and what this would mean for competition and consumer choice in the payments sector.
EPIF welcomes the publication of the proposal for a Payment Services Directive 2 (PSD 2). EPIF is hereby identifying some key issues that need to be addressed in order to improve the current proposal. This includes, amongst other topics, the passporting regime, the use of agents, the access to bank services for payment institutions, safeguarding of merchant funds and surcharging.
EPIF is glad to share its views on two main issues currently discussed at Council level with regards to the review of the 3rd Anti-Money Laundering Directive: i) the introduction of CDD requirements for transfer of funds exceeding 1,000 EUR and ii) the possible re-introduction of an optional exemption for electronic money products from CDD requirements if certain thresholds are observed.
EPIF is glad to share its views on the topic of third parties accessing payment accounts to effect payments on behalf of European consumers (also called Payment Initiation Services) as well as to make four recommendations in respect of Payment Initiation Services (“PIS”).
Thanks to their safety, convenience and economic efficiency, we expect PIS to bring significant benefits to European consumers and contribute to the integration of the European payments market. In order for this to happen, consumer interests need to be safe-guarded and it needs to be ensured that third-party providers and bank-sponsored providers of PIS compete on a level playing field.
On 21st March 2013, EPIF (European Payment Institutions Federation) starred a panel on Payment Institutions at the EPCA (European Payments Consulting Association) Payment Summit, which is a key conference for the European payments industry. This event provides plenty of opportunities to catch up on the latest ideas from payment experts and leaders, to exchange ideas, to attend innovative and educational presentations, and to brainstorm on what the future will look like.
EPIF welcomes the European Commission’s proposal for greater harmonisation of the EU data protection regime within the internal market with regard to the processing of EU personal data. With this position paper, EPIF seeks to address the concerns it has identified in the draft Regulation.
A number of provisions lead in their current form to legal uncertainty as they seem to be in conflict with the requirements under applicable Anti-Money Laundering and Counter-Terrorism Financing rules (AML/CFT). Also, some provisions significantly increase of costs and bureaucracy for companies
EPIF is glad to share its high-level views on the review of the PSD and the follow-up to the Green Paper on payment innovation. EPIF is addressing below several issues of concern resulting from both instruments.
EPIF welcomes the publication of proposals for the 4 th Anti-Money Laundering Directive (4AMLD). AML rules need to be calibrated to reflect the reality of PI’s operating models.
EPIF would like to take the opportunity to identify some key areas that EPIF believes the 4AMLD should seek to address but currently does not. This includes, amongst other things, the legislative method applied (minimum harmonisation as opposed to maximum harmonization), risk based approach, customer due diligence measures, approach towards non face to face (online) transactions and data protection issues.
EPIF welcomes that the European Supervisory Authorities (ESA) have recently started to provide specific guidance to the financial industry regarding the supervisory, passporting and reporting regime applicable to Payment Institutions (PI) and their agent network. The new supervisory protocol (the ‘Protocol’) provides helpful clarifications, in particular from an Anti-Money Laundering and Counter-Terrorism Financing (AML/CFT) perspective. On the other hand, the Protocol contains various proposals which are a matter of concern to EPIF due to their unnecessary restrictive nature and potential severe impact on the business models of non-bank remittance service providers in Europe.
Towards an integrated European market for card, internet and mobile payments to be held on 4th May in Brussels.
On the 11th of April, the Commission published its anticipated Application Report on the 3rd AML Directive, which provides feedback on the Commission’s review process and considers possible needs for changes.
EPIF published a position on the Commission Staff Working Paper on AML Supervision Of, and Reporting By, Payment Institutions in Various Cross-Border Situations.
The European Payment Institutions Federation (EPIF) welcomes and encourages the private stakeholder consultation that is currently taking place concerning a review of the 3rd Anti-Money Laundering (AML) Directive.
Payment Institutions' (PI) compliance with anti-money laundering and counter terrorist financing obligations is a prerequisite for their authorisation under the Payment Services Directive (PSD). The current anti-money laundering framework was, however, established prior to the opening of the payment institutions market and subsequently is arguably not catered to the needs of their various business models.