Criminal finance rules tightened for PSPs

New measures from the European Union to boostthe effectiveness, harmonisation, supervision, enforcement and co-ordination ofits anti-money laundering and counter-terrorist finance regime will have asignificant impact upon payment service providers in the United Kingdom. Charlotte Hill and Julia Steinhardt set out the requirements.

Charlotte Hill is a partner and head of the financial services regulatory group,while Julia Steinhardt is an associate, at Taylor Wessing in London.Contact them on c.hill@taylorwessing.com and j.steinhardt@taylorwessing.com.

1 Overview

Since 26 June 2017, the Revised Wire Transfer Regulation(the ‘WTR’ [1]) has applieddirectly to most transfers of funds in any currency involving at least one paymentservice provider (PSP) that isestablished in the European Union. Related supervision, penalty and enforcementmeasures in the United Kingdom are set out in the Money Laundering Regulations(the ‘MLRs’ [2]). The Financial Conduct Authority is the relevant ‘transfer offunds’ supervisory authority for PSPs that are authorised under the FinancialServices and Markets Act 2000 or authorised or registered under the PaymentServices Regulations 2009 or the Electronic Money Regulations 2011; HM Revenueand Customs is the supervisory authority for any other PSP. Additional guidanceis provided by the FCA, [3]the Joint Money Laundering Steering Group, [4] and UK Finance. [5]