Instant euro transfers settle in under ten seconds, so there’s no time to hold a payment while someone reviews a possible sanctions match. The Instant Payments Regulation responds by moving the EU sanctions check out of the payment and onto the customer. Instead of screening each transfer, you must screen your entire customer base against EU targeted financial restrictive measures at least once a day, and again whenever a measure is added or amended.
The obligation applies to every PSP offering instant credit transfers from the day it starts offering them. You need to be able to receive instant euro transfers by 9 April 2027 and send them by 9 July 2027.
This checklist helps you find out where you stand. Answer six yes-or-no questions, see what a gap could cost, and see how each obligation maps to a practical screening setup.
What’s inside
- The two deadlines to plan around, and what each one requires
- Six questions to test your readiness, from daily customer-level screening to annual reporting on rejected payments
- The minimum penalties for breaching Article 5d, for companies and for individuals in senior management
- How Sumsub AML Screening supports each obligation, one by one
Who it’s for
Compliance, financial crime and product teams at PSPs, e-money institutions and payment institutions that offer, or plan to offer, instant euro credit transfers, including firms outside the euro area.
