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make the service enabling customers to be notified when a mismatch is detected between the payee’s name and IBAN mandatory and without specific fee;

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ensure that when a mismatch is detected during the IBAN check processing by the receiving bank, this bank informs the sending bank of the situation;

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ensure that when a mismatch is detected and the consumer decides nevertheless to confirm the IP, the sending bank is no longer responsible if the beneficiary is not the right one;

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propose targeted measures to improve the fight against fraud as IBAN will only affect the authorised push payments (APP).

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how PSPs operating in several countries should assess such situations and what steps PSPs should take;

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how such information will be shared within the EU;

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how the issue of compensation for damages will be dealt with in such cases;

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to refer to just one list of persons or entities subject to EU sanctions that is adopted by way of Council Regulations under Article 215 TFEU and that should be made available to PSPs immediately. This information should constitute the official list of persons or entities subject to EU sanctions (restrictive measures).

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establishing internal monitoring lists, which would normally include entities involved in sanctions violations or sanctions risks, dual-use items, etc.;

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using the list provided by the national competent authority (NCA) in accordance with the EU anti-money laundering (AML) legislation.

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1 in 3 EU PSPs do not offer IPs in euro;

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in the Euro Zone, 70 million payment accounts do not allow their holders to send money and receive IPs in euro;

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up to 9,4 % of cross-border euro IPs are rejected by payment providers because of inefficient sanction screening.

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a requirement for PSPs providing a regular euro credit transfer service to offer sending and receiving of IPs in euro;

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a requirement for sanctions screening in the form of very frequent checking of clients against EU sanctions lists (as is already done in certain Member States for domestic payments), rather than for each individual transaction;

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a requirement for PSPs to provide a service enabling customers to be notified when a mismatch is detected between the payee’s name and the payment account identifier, which is usually the IBAN, as supplied by the payer.

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The EESC has also doubted whether the IBAN check is a purely optional service to which the consumer has to opt-in for each transaction or for all its transactions. In some situations (e.g. a mobile payment) it can be very complicated to manage and can also worsen the service convenience for the payer — he or she would be compelled to make a decision each time when the credit transfer is initiated and unnecessarily click more times than needed.

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The EESC would like the IBAN check not to be limited to IPs but also extended to classic credit transfers until they are provided by PSPs.

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EMIs and PIs are for the time being excluded from the scope of this regulation. This exemption should be withdrawn once these institutions are granted access to payment systems, after the modification of the Settlement Finality Directive. Non-bank PSPs should be covered by the regulation as long as their offer of payment services includes operating a payment account and execution of credit transfers. Until that date, it is necessary to clarify how IBAN check and liability rules are applied when these third parties are used to initiate IPs.

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enable customers to be notified by instant electronic notification, when a mismatch is detected between the payee’s name and IBAN or any other identifier used, as supplied by the payer. This service must be mandatory and without specific fee;

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ensure that when a mismatch is detected during the IBAN check processing by the receiving bank, then this bank informs the sending bank of the situation. Thus, the sending bank informs its consumer of this mismatch and the payment transaction is suspended;

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ensure that when a mismatch is detected and the consumer decides nevertheless to confirm the IP, it is completely clear to the consumer that if they have not indicated the right beneficiary the sending bank is no longer responsible if the beneficiary is not the right one;

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propose targeted measures to improve the fight against fraud as IBAN will only affect the authorized push payments (APP). This can be done in coordination with the development of the Request to Pay Scheme set up by the European Payment Council which is also the manager of the SCT Instant Payment scheme.

a)

include and explain in the regulation provisions to ensure the uniform application of EU law:

b)

set out the explanatory part of the regulation in detail so that it covers the general EU position and provides an interpretation of the sanctions applicable to goods and services, such as use by the EU in the case of goods and services. Sanctions that apply to the import, export, transport, prohibition, etc. of certain goods.

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establishing internal monitoring lists, which would normally include entities involved in sanctions violations or sanctions risks, dual-use items, etc.;

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using the list provided by the national competent authority (NCA) in accordance with the EU anti-money laundering (AML) legislation.