Key points include:
➡️ Reduced Transparency: Certain vIBAN structures may weaken visibility between the payer and ultimate beneficiary;
➡️ Multi-Layer & Intermediary Risk: Complex, multi-entity arrangements can increase transaction layering and monitoring challenges;
➡️ Cross-Border Exposure: Inconsistent regulatory frameworks may heighten ML risk in international contexts; and
➡️ Need for Stronger Coordination: Improved information sharing between intermediaries is critical to mitigating these risk.
✅ Firms should ensure that vIBAN arrangements are supported by robust transparency controls, effective customer due diligence and enhanced monitoring of multi-layered payment flows.