Title 3: Targeted and proportionate limitation of access to products or services

Credit and financial institutions’ policies and procedures should, where permitted by national law, include options and criteria on adjusting the features of products or services offered to a given customer on an individual and risk-sensitive basis. These should include the following options:

In relation to ML/TF risks associated with customers who are particularly vulnerable, such as those persons referred to in paragraph 19, credit and financial institutions should ensure that their controls and procedures specify that possible limitations of products and services set out in paragraph 20 (b) are applied taking into consideration the personal situation of the individu-als, the ML/TF risks associated therewith and their financial basic needs. In those cases, proce-dures should include the assessment of the following options to potentially mitigate the asso-ciated risks:

• a. no provision of credit or overdraft facilities;
• b. monthly turnover limits (unless the rationale for larger or unlimited turnover can be ex-plained and justified);
• c. limits on the amount, the type and/or number of transfers (further or larger transfers are possible on a case-by-case basis);
• d. limits on the amount of transactions to and from third countries (while considering the cumulative effect of frequent smaller transactions within a set period of time), in particular where these third countries are associated with higher ML/TF risk;
• e. limits on the size of deposits;
• f. limits third party payments to those made by the authority that disburses support for such customers;
• g. limits on payments received from third parties that the institution has not verified; and
• h. prohibiting cash withdrawals from third countries.