Supervision release 17 April 2018 – 26/2018

European Supervisory Authorities have published guidelines on prevention of abuse of fund transfers in money laundering and terrorist financing

EU Regulation 2015/847 on information accompanying transfers of funds (so-called Funds Transfer Regulation) entered into force on 26 June 2015. On 22 September 2017, the European Supervisory Authorities (ESAs) published joint guidelines under Article 25 of EU Regulation 2015/847 on the measures payment service providers should take in accordance with the Regulation. A Finnish-language translation of the guidelines release was published on 16 January 2018.

The ESA guidelines contain more detailed instructions on how payment service providers and intermediary payment service providers should act in order to fulfil the requirements of Regulation 2015/847. Payment service providers should have effective procedures based on comprehensive risk assessments to detect missing or incomplete information on the payer or the payee. The procedures should include both real-time and ex-post monitoring. Payment service providers should also define risk indicators detect high-risk fund transfers. In addition, payment service providers should put in place effective risk-based procedures to determine whether to execute, reject or suspend a transfer of fund. Payment service providers should identify service providers repeatedly failing to provide required information on the payer or the payee. The assessment of repeated failure should be based on a combination of quantitative and qualitative criteria.

The ESA guidelines are available on the ESA website.

The ESA guidelines will be implemented nationally by FIN-FSA regulations and guidelines 5/2018. The regulations and guidelines will enter into force on 1 May 2018.

Payment service providers should prepare a risk assessment and internal instructions based on the ESA guidelines, in which they assess for example the implementation of real-time and ex-post monitoring and define criteria for the assessment of the significance of failures by counterparties.

The Payment Transfers Regulation requires institutions to notify any shortcomings detected in payment information to the FIN-FSA. In accordance with the ESA guidelines, the notifications should be made without undue delay, and no later than three months after identifying repeated shortcomings in payment information. The notification should specify:

  • name of the payment service provider whose payments repeatedly involve deficient information
  • country in which the payment service provider was authorised or registered
  • details of the shortcomings: how often have there been shortcomings, period when shortcomings occurred, reasons for the shortcomings as told by the payment service provider and any measures implemented by the reporting payment service provider.

The notification is made using the template accessible through this link.

The notifications shall be sent to the FIN-FSA by email at maksuntiedot(at)

For further information please contact:

  • Ms. Erja Pullinen, Risk Specialist, tel 09 183 5358, erja.pullinen(at)
  • Ms. Anne Nisén, Senior Risk Specialist, 09 183 5211, anne.nisen(at)