Screening for EMIs.

An Electronic Money Institution (EMI) authorised under PSD2 in the EU — or under the Electronic Money Regulations 2011 in the UK — is a fully obliged entity under AMLD. That means PEP and sanctions screening at onboarding, ongoing monitoring throughout the relationship, and an audit trail that satisfies a national-bank inspection. Substandard screening is one of the top reasons EMIs receive supervisory action.

What EMI supervisors expect

• Customer screening at onboarding against sanctions, PEP and adverse-media lists.
• Beneficial-owner screening for legal-entity customers — every UBO at ≥ 25% (lower thresholds in some Member States).
• Ongoing monitoring of the entire customer base against new list versions, with documented response times.
• Risk-based EDD for customers in high-risk jurisdictions, complex ownership structures, or with PEP exposure.
• Documented thresholds and reasoning. Why does your engine decide pass at 0.85 but review at 0.80? Be able to explain it.
• Audit trail: every screen, list version, decision, reviewer ID, EDD outcome — retained for 5 years (longer in some regimes).

Common findings in EMI examinations

• Lists not refreshed often enough (weekly batches when minutes are required).
• No coverage of UBOs — only the front-of-house customer is screened.
• "Ongoing monitoring" exists on paper but not in operations — re-screening happens at annual review only.
• Threshold tuning that is undocumented or impossible to explain.
• No audit-ready export: producing 18 months of screening evidence takes weeks.

Recommended ScreeningHub deployment

1. Customer + UBO screening at onboarding via the /v1/screen endpoint. Pass the customer in one call, every UBO over the threshold in their own calls.
2. Enable ongoing monitoring on Growth or Enterprise. New list versions push status changes via webhook — your case-management queue receives them within minutes.
3. Use per-key thresholds to differentiate retail accounts (looser) from corporate accounts (stricter).
4. Export the audit log on demand: list version, query payload, match logic, score, reviewer action — exportable as CSV or JSON for any retention window.

Why it matters operationally

EMIs typically operate with lean compliance teams. The screening programme has to be cheap to run and easy to explain. ScreeningHub's effective rate of ≈ €0.013 per screen on Growth (€399/mo for 25,000 screens + monitoring) keeps a 10,000-customer book covered for under €5,000 a year — a fraction of one full-time analyst.

For background, see sanctions screening explained and what is PEP screening. Compare with ComplyAdvantage, Sumsub and sanctions.io.