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AMLD5, the 5th anti-money laundering directive, was published in June 2018. Workforces then had until 10th January 2020 to fully implement any required changes to their products.
Following terrorist attacks in Paris and Brussels, which were primarily funded via virtual currencies and ‘anonymous’ prepaid cards, it was decided that more control was required over these types of payments. It is hoped that the limitations in place will help prevent future attacks.
AMLD5 is a new version of the anti-money laundering directive that sees a number of provisions made to the previous version, AMLD4.
The focus is to regulate virtual currencies and anonymous pre-paid cards, whilst improving the safeguards for financial transactions to and from high risk countries. The second focus is to ensure centralised national bank and payment account registers are accessible in all member states of the EU.
To greater regulate anonymous prepaid cards, new limits have been introduced meaning they can only be loaded with a maximum of £120 and are limited to a maximum of £40 per transaction when used online.
This means that as a business, you can continue to buy regulated products in bulk (providing you’ve passed our business regulation and compliance checks), but you’re restricted to the new maximum load value limit per card.
For an individual user - i.e. your customers or employees who have access to these products via you, or via our consumer sites - the purchase of anonymous prepaid cards, such as our Choice Range, or One4All is limited to a maximum of £500 per order and affected by the load limit and online restriction.
To enable these limits to be implemented by the schemes and acquirers, prepaid issuers such as Blackhawk Network need to be able to distinguish between anonymous and non-anonymous cards.
Anonymous cards are those where we have not verified the identity of the cardholder or recipient and are the cards most impacted by AMLD5 through the increased restrictions which enforce lower load values and online spend restrictions.
This can be combatted in some cases by introducing KYC checks – a simple process that identifies and verifies who the end user is - meaning we can classify the product as non-anonymous. This removes all restrictions allowing you to load greater values and spend over £40 online. Our KYC checks are undertaken by Experian using the individual’s name, address and date of birth. When the information cannot be matched automatically, the individual will be asked to provide a snapshot of their ID documents such as a passport or drivers licence.
To comply with this regulation, there are new maximum load limits across our Choice family and One4all cards. These are the multi retailer gift cards that you can purchase online and in supermarkets, or that can be used as customer incentives, rewards or gestures. This is accompanied by a restriction on how much can be spent in one transaction when redeeming online. Users won’t lose the balance of their cards when only spending a proportion of the value online, but trying to spend over the limit will decline the transaction.
Pure Card can support a range of options, including the lower value cards with no real change, but can also easily KYC end users at the point they activate their cards enabling customers to still hand out higher value rewards, or rewards with limitation to online spend.
So, what does this really mean for our customers?
All Choice cards are classed as anonymous, but AMLD5 will only affect our regulated products: Kids Choice, Teen Choice, Student Choice and Fashion Choice.
Restaurant Choice, Cycle Choice and Spa Choice are exempt because they are only able to be spent on a specific retail category or service. Whereas the rest of our Choice Family can be used to purchase almost anything from the stores listed on each card.
Maximum load value has been reduced to £100.00
Online transactions over £40 will be declined
Businesses can continue to buy in bulk providing you’ve passed our due diligence checks
Your customers or employees who have access to Choice cards via a programme you run, or via our consumer sites are limited to a total product order of £500.00
One4all is classed as a regulated product due to the number of retailers who are on the network. As we currently don't offer KYC checks on One4all, this means that the card counts as anonymous.
Maximum load value has been reduced to £120.00
Businesses can continue to buy in bulk providing you’ve passed our business regulation and compliance checks
Your customers or employees who have access to One4all via a programme you run are limited to a total product order of £500.00
Our flexible prepaid card solutions can suit any of your requirements. We can support magstripe, Chip & PIN and contactless cards, across both anonymous and non-anonymous programmes as required.
Some cards will be classed as anonymous
Maximum load value on non-KYC checked cards has been reduced to £120.00
Online transactions over £40 will be declined for non-KYC checked cards
Our higher value rewards, that can be either single load, or reloadable will require KYC checks. This will then means that users will have no online spend limit.
The same restrictions do apply to any sale of our regulated products. You’ll be free to continue your usual purchase or redemption for any restaurant choice, cycle choice, spa choice or single retailer cards.
If you’re registered as buying on behalf of a business, you may continue buying in bulk providing your company has passed a due diligence check.
Businesses using our Pure Benefit or Pure Flex programmes will need to make sure that all cardholders are ‘Know Your Customer’ checked.
This is generally done by businesses as part of their employee onboarding, so the good news is that if your business is regulated to the same standard that we require, then we may be able to use and trust that data in order to issue a Pure Card. If not, don’t worry, we can complete the KYC checks for each cardholder as required in a simple customer journey.
This directive took effect ahead of the UK leaving the EU on 31st January, so AMLD5 still stands. During the transition period, the UK will continue to work with the EU on the enforcement of AMLD5 and begin work towards the next expected AMLD6. It is hoped that the UK and the member states of the EU will continue to work together on these kind of regulations in the future.
The biggest adjustment for your customers or employees to make following AMLD5 is the way in which they can spend online. Attempting transactions over the £40 limit will be declined – larger sums will need to paid for via multiple payment methods. You’ll have to split a £120 One4all card into three separate £40 online transactions, or a number of smaller divisions. In store, you can continue to spend the full total in one transaction.
The alternative is to look at one of our other solutions. Our Select platform is a viable option where your recipients can swap a digital code of any value for the gift card of their choice. Additionally, our prepaid reward cards where we can implement ‘Know Your Customer’ checks provide a simple way to reward your customers and employees.
If our prepaid reward card isn’t appropriate for your business, then we can offer you a large selection of discounted single store gift cards. As key UK distributors for multiple retailers, we are able to provide great rates on gift cards from Curry’s PC World, John Lewis, Microsoft and Argos, to name but a few.
If you’re concerned about how your business will continue to reward and incentivise your staff or customers, then contact us today and we’ll work with you to find a suitable solution.