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4th Money Laundering Directive for Prepaid Cards

Dear Valued Clients:

As you are probably aware, on the 20th May 2015 the European Union approved the Proposal to Amend Regulation 648/2012. This has become commonly known as the 4th Money Laundering Directive (4MLD).

As stipulated by the EU, the 4MLD will be finally adopted by all member states on the 26th June 2017. Gibraltar, being a member of the EU, will be adopting this Directive and it has already been transposed into local legislation.

The 4MLD brings along several important changes to the way that PAA CAPITAL can do business. It also makes important changes to the way our products can be sold and used.

Although our ability to continue issuing prepaid cards has not been affected, the initial load limits under which we can issue cards without cardholder verification, which you already know as KYC 1 (Know Your Customer Level 1), has significantly changed.

What are the main changes?

As of the 26th June 2017, the maximum load limit for KYC 1 cards will be reduced from . 2,500 to .250.

KYC 1 cardholders with less than .250, will have limited spend up to .100 through ATM or point of sale transactions.

To summarize, to load more than .250 or to exceed spend of .100, the cardholder must be verified.

What does this mean?

Prior to 4MLD, a KYC 1 cardholder could load .2,500 onto his prepaid plastic or virtual card before his identity and address information required verification. With 4MLD in place, a cardholder.s identity and address information must be verified to allow any loads above the new limit of .250.

A verified cardholder becomes KYC 2 and the full range of services of your Program would be available under the corresponding KYC 2 limits.

What will happen to KYC 1 cardholders on 26th June 2017?

As of 12:00 AM BST, on the 26th June, KYC 1 plastic and virtual cardholders, with a card balance that exceeds .250, will be unable to use their card(s) for any transaction. KYC 1 cardholders would need to have their identity verified to be able to spend their funds.

4MLD allows KYC 1 cardholders with less than .250 to spend up to .100 through ATM or point of sale transactions. To exceed spend of .100, the cardholder must be verified.

What does PAA CAPITAL recommend for Cardholders?

We recommend that KYC 1 cardholders verify their identity prior to the 26th June 2017.

Do these limits also apply to residents of France and Overseas Territories of France?

No. These new limits do not apply to residents of France or Overseas Territories of France as they are covered by the limits which have already been released and provided prior to this 4th Money Laundering Directive for Prepaid Cards.

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Anti Money Laundering and Counter Terrorism Financing (AML/CTF) & PEP & Sanction Screening Implemented

PAA Capital Group has successfully implemented and subscribed to Dow Jones Risk and Compliance through the Membercheck Platform to meet its obligations against Anti Money Laundering and Counter Terrorism Financing (AML/CTF) & PEP & Sanction Screening.