Article 25 Instructions to monitor transactions or activities

This short but operationally significant article grants FIUs the power to direct obliged entities to conduct targeted monitoring of specific accounts and business relationships.

It sits alongside Article 24, which deals with FIU powers to suspend transactions or freeze accounts, together forming a toolkit of reactive powers available to FIUs when dealing with high-risk situations.

Where Article 24 is about stopping activity, Article 25 is about watching it — requiring obliged entities to monitor and then report back to the FIU on what they find.

Important points:

• FIUs are empowered to instruct obliged entities to monitor bank accounts, payment accounts, crypto-asset accounts, or other business relationships for persons presenting a significant risk of money laundering or terrorist financing.
• Obliged entities must also report the results of that monitoring back to the FIU, for a period specified by the FIU.
• FIUs are required to impose these monitoring measures at the request of an FIU from another Member State, enabling cross-border coordination.