For payment service providers offering euro instant credit transfers
How do you run daily sanctions screening for EU instant payments?
Regulation (EU) 2024/886 changed how sanctions screening works for euro instant credit transfers. Instead of screening every transaction against sanctions lists, an in-scope PSP verifies, at least once every calendar day, whether any of its own payment-service users is a person or entity subject to EU targeted financial restrictive measures, and re-checks immediately when new or amended EU listings take effect. This page sets out that workflow, the phased dates, and the obligations it does not replace.
Primary sources
- Regulation (EU) 2024/886 (Instant Payments Regulation)
Amends the SEPA Regulation (EU) No 260/2012, inserting a new Article 5d on verification by PSPs of whether a payment-service user is a designated person or entity. Adopted 13 March 2024.
- ECB, Instant Payments Regulation (application dates)
The ECB's reference page for the IPR, including the phased application dates for receiving, sending and screening obligations across euro-area and non-euro-area PSPs.
- Council Regulation (EU) No 269/2014, asset-freeze prohibition
The underlying strict prohibition on making funds or economic resources available to listed persons, the obligation daily screening supports, and which does not depend on any single screen succeeding.
The Article 5d model, in plain terms
Article 5d moves sanctions screening for in-scope instant credit transfers away from the payment flow and onto the customer base. A PSP verifies its own payment-service users against the EU list of designated persons at least once per calendar day, and again immediately whenever the EU adopts or amends a listing.
The intent is speed: an instant transfer settles in seconds, so screening the parties transaction-by-transaction would break the ten-second target. Verifying the user base on a daily cadence keeps sanctioned account-holders out without adding per-payment latency.
A workflow that produces evidence
- 1Maintain a current, versioned copy of the EU consolidated list of designated persons, and record the version you screened against.
- 2Screen your full payment-service-user population against that list at least once every calendar day.
- 3On every EU listing change, re-run the check immediately against the newly affected population, do not wait for the next daily cycle.
- 4For each run, retain what was screened, the list version, the outcome per user, and any match sent to review, so a supervisor can reconstruct that the daily obligation was met.
- 5Keep the underlying AML transaction monitoring and any non-EU (UN, OFAC, UK) sanctions screening you are separately obliged to perform; Article 5d does not replace them.
Phased application dates
Dates are as summarised on the ECB's IPR reference page. Confirm the exact obligation and date for your institution type and currency area before relying on them.
| PSP | Receiving + daily screening | Sending |
|---|---|---|
| Euro-area PSPs (banks) | 9 January 2025 | 9 October 2025 |
| Non-euro-area PSPs (banks) | 9 January 2027 | 9 July 2027 |
| EMIs / payment institutions | 9 April 2027 (euro) | 9 July 2027 (non-euro) |
Limitations
- Article 5d screens your own payment-service users against the EU list only. It does not screen the actual counterparty or beneficiary of a given transfer, and it does not cover UN, OFAC or UK lists.
- Removing transaction-by-transaction sanctions screening for in-scope transfers does not remove AML transaction monitoring, nor any non-EU sanctions screening you are independently required to run.
- The daily cadence is a floor. The immediate re-check on a new listing is the part most systems get wrong, a listing that lands mid-day must be actioned before the next daily cycle.
- This page is an implementation reference, not legal advice, and does not certify any regulatory outcome.
Build the evidence, not just the alert
Questions
Does Article 5d mean we stop screening transactions entirely?
For in-scope euro instant credit transfers it replaces per-transaction sanctions screening of the parties with daily verification of your own users against the EU list. It does not remove AML transaction monitoring, and it does not remove non-EU sanctions obligations that may still require transaction-level checks.
How fast must we react to a new EU listing?
Immediately, the obligation is to re-verify as soon as a new or amended EU listing enters into force, not merely at the next daily run. That is why the list version and the re-check timestamp belong in your evidence.
How does Verifex fit this?
Verifex can screen a population against configured sources, report the source state and list version, and preserve the per-run evidence. Where the EU source is unavailable, it says so rather than presenting an unscreened population as clear.
This page is an implementation reference for engineering and compliance teams. It is not legal advice and does not certify any regulatory outcome. Regulatory obligations, their interpretation, and the decision to treat any result as clear remain yours. Verifex supports the workflow and preserves the evidence; it does not make the compliance decision.