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6.4.5 Requirements for Money or Value Transfer Services

Effective from 13/7/2023

(AML-CFT Decision Articles 26, 30)

As part of a risk-based AML/CFT approach, FIs that enter into or maintain Business Relationships with Money or Value Transfer Services (MVTSs) should take adequate CDD measures that are commensurate with the risks involved (see Sections 6.3, Customer Due Diligence (CDD) Measures and 6.4, Enhanced Due Diligence (EDD) Measures). Examples of measures that FIs should consider in this regard include, but are not limited to:

Ensuring that the MVTS is properly licensed or registered; in particular, when opening any accounts for Hawala Providers, FIs licensed by the Central Bank must physically check the original Hawala Provider registration certificate issued by the Central Bank and keep a copy thereof;
 
Obtaining information about and assessing the adequacy of the MVTS’s AML/CFT policies, procedures and controls, including those related to Wire Transfers as stipulated in the relevant provisions of the AML-CFT Decision;
 
Obtaining the MVTS’s list of agents, and identifying and assessing the associated ML/FT risks, especially with regard to high-risk countries or other identified high-risk factors;
 
Obtaining sufficient information about the MVTS’s ownership and management structure (including taking into consideration the possibility of PEP involvement), the nature and scope of its business, the nature of its customer base, and the geographic areas in which it operates, so as to be in a position to identify, assess, and manage or mitigate the associated ML/FT risks.
 

FIs that enter into or maintain relationships with MTVSs should also use a risk-based approach to determine the appropriate internal AML/CFT policies, procedures and controls FIs implement in relation to the risk assessment, risk classification, and the type and extent of CDD they perform on the MVTSs. The policies and procedures that FIs apply should be reasonable and proportionate to the risks involved, and should be adequately documented, senior management approved, and communicated to the relevant employees of the organisation.