Assessment: Mittenda Limited IE · Regulation: EU 2023/1113 · Roles: PSP, Intermediary PSP, CASP, Intermediary CASP
Originator information verification not validly performed before transfer
R-ORIGINATOR-INFO-VERIFICATION-FAILEDRisk that the originator's PSP or originator's CASP dispatches a transfer without having validly established the accuracy of the Article 4(1) / 14(1) (and, where applicable, Article 4(3) / 14(3)) originator information before transfer, on the basis of documents, data or information obtained from a reliable and independent source. This may arise by omission, partial scope, non-reliable / non-independent source, stale evidence, late timing, wrong-record matching, failed-treated-as-passed gating inversion, missing audit trail, wrong-actor allocation (direct debit).
Linked objectivePreventing, detecting and investigating money laundering and terrorist financing. This is achieved by ensuring that the originator information accompanying a transfer is accurate and verified against reliable independent evidence before dispatch.
Observable defectOutbound transfer dispatched without a recorded, pre-transfer, reliable-and-independent-source verification of the originator's Article 4(1) / 14(1) (and where applicable 4(3)) information.
Defined terms EU 2023/1113 Article 3 4
- Payer
- A person that holds a payment account and allows a transfer of funds from that payment account or, where there is no payment account, that gives a transfer of funds order.
- Payment service provider
- The categories of payment service provider referred to in Article 1(1) of Directive (EU) 2015/2366, natural or legal persons benefiting from a waiver pursuant to Article 32 thereof and legal persons benefiting from a waiver pursuant to Article 9 of Directive 2009/110/EC, providing transfer of funds services.
- Payment service provider of the payer
- The payment service provider that acts on behalf of the payer in a transfer of funds, responsible for ensuring that transfers are accompanied by required payer and payee information.
- Funds
- Funds as defined in Article 4, point (25), of Directive (EU) 2015/2366.
What the key-risk tier means
- T1
- — Key-risk tier 1 (strict) — a key risk no firm tolerance absorbs — any failure must be treated, whatever the firm's appetite.
What the category chips mean
- Verification & scope assurance
- — Level 1 taxonomy category (CC-ASSURANCE)
- Verification performance & gating
- — Level 2 taxonomy category (CC-ASSURANCE-VERIFICATION)
Examined against the registered documents: documented, not evidenced. What the documents show
This risk is assessed in more than one way — you're deciding Funds · PSP here. The register counts it identified once all are decided.
This risk is assessed in 2 ways. One relevance decision covers them all, so one analysis and one evaluation do too. Decide relevance one at a time (step 1) to work them separately.
Assess understand the risk and what's already in place
The rating bands (Low / Medium / High / Critical) and the reduction applied to them are this product's own method, not a calculation any standard prescribes.