How does AML work?
An AML programme starts with a risk assessment and builds controls on it: customer due diligence at the right moments, ongoing monitoring of transactions against what is known about the customer, controls on payment methods, and reporting of suspicious activity to the authorities. Thresholds trigger extra checks. The European Banking Authority’s guidelines, for example, allow verification of a low-risk e-money customer to be postponed until a later date or until a low monetary threshold is exceeded, whichever comes first, with the threshold set no higher than EUR 150 for products that are not reloadable or can be used cross-border.
Why does AML matter for payments?
Because payments are where laundering happens. The European Banking Authority’s guidelines treat e-money funded from an account in the customer’s own name as lower risk and funding from unidentified third parties as higher risk. As an illustrative example: a wallet that lets customers top up by card and cash out to any bank account cannot show that money returns to the person who paid. Enforcing a closed loop, with a documented fallback to an account in the customer’s verified name, closes that gap.
What are the trade-offs?
Strong AML controls add steps for genuine customers, and controls applied late, at payout, create delays and support contacts. The better pattern is risk-based: light controls for low amounts, stronger checks triggered by cumulative activity, and payment rules that make laundering hard by design.
Where does Omno use it?
In Omno, AML controls are defined by the merchant and enforced in routing: eligibility by customer verification level and customer group, verification gating for payouts through a given provider, card blocking, and a routing-decision log that records what was allowed and why.