Transparency in transfers of funds and crypto-assets is crucial for managing financial crime risk, as the 2023 Wolfsberg Group Payment Transparency Standards outline in detail. We are grateful for the opportunity to provide feedback on the “Travel Rule Guidelines” drafted by the European Banking Authority (EBA) to support the implementation of Regulation (EU) 2023/1113 and promote a common understanding of the requirements across all participants in transfer chains and competent authorities.

Focusing primarily on Payment Service Providers (PSPs) and Intermediary Payment Service Providers (IPSPs), the Group offers detailed suggestions on how the Guidelines may be further improved in the following areas:

• Acknowledging the various roles played by PSPs in a transfer chain and the different level of information available to each. This is particularly relevant for IPSPs facilitating payments for parties who are not their customers.
• Addressing the potential unintended consequences of the new requirements around batch payments.
• Requiring additional information on the payer to be included only when account number, name and address are insufficient to identify the person.
• Stressing the importance of ex-post monitoring including the fact that it does not delay the processing of payments.
• Clarifying terminology.