Understand CCP Requirement

Why payment institutions operating cross-border must comply with host-country AML rules.

The European Union has strengthened its AML/CFT framework to ensure that payment service providers (PSPs) and electronic money institutions (EMIs) operating across borders are subject to effective supervision. Under Delegated Regulation (EU) 2018/1108, a PSP or EMI based in one Member State may be considered established in another Member State even without a physical branch, whenever its activity in the host country meets certain thresholds.

In these cases, the institution must comply with the host country’s local AML laws and may be required to appoint a Central Contact Point (CCP). The CCP acts as a liaison between the institution and the national supervisor, ensuring proper customer due diligence, AML reporting and information exchange.

For institutions expanding into the Italian market through agents or affiliated distributors, understanding the CCP obligation is essential to avoid regulatory breaches and ensure smooth operations.

CTA: Need guidance on whether your institution must appoint a CCP in Italy? Contact us for an assessment.