Etihad Law

AML & KYC Obligations for Electronic Payment Providers

Electronic Payment Service Providers (EPSPs) handle transactions that can be exposed to money laundering, terrorist financing, fraud, and sanctions risks. For this reason, CBI imposes mandatory Anti-Money Laundering (AML) and Know-Your-Customer (KYC) obligations on EPSPs similar to those applied to banks, with additional expectations for digital onboarding and transaction monitoring. Compliance is essential for maintaining regulatory approval and protecting the digital payment ecosystem.

AML/KYC Requirements

  • Customer identification and verification procedures
  • Enhanced Due Diligence (EDD) for high-risk users
  • Continuous monitoring of transactions and behavior
  • Sanctions and PEP list screening
  • Suspicious transaction reporting
  • Record-keeping and audit trails

Operational Requirements for Digital KYC

  • Secure digital onboarding channels
  • Document verification tools or manual controls
  • Data retention and privacy protections

CBI compliance

  • Maintain written AML/KYC policies and manuals
  • Establish an AML Compliance Officer and team
  • Integrate technology for real-time monitoring
  • Report suspicious activities in prescribed formats
  • Submit periodic AML compliance reports
  • Cooperate with supervisory inspections

How Etihad Can Assist

Etihad provides legal and regulatory advisory services to banks, financial institutions, and businesses, supporting compliance with applicable laws, regulations, and regulatory guidance issued by any competent authorities.