Four-eyes principle

Why it matters for PSPs and EMIs

A single analyst approving a high-risk merchant is a single point of failure: one mistake, one conflict of interest or one pressure from sales, and the decision stands. A second approval makes the decision more robust and, just as important, makes it visible who approved what and on which evidence.

What the law says

• Senior management approval for higher risk. AMLR Art. 34(4)(e): obtaining the approval of senior management to establish or continue the relationship is one of the enhanced due diligence measures.

• Politically exposed persons. AMLR Art. 42(1)(a): senior management approval is required for occasional transactions or for establishing or continuing relationships with PEPs, and (Art. 46) with their family members and close associates.

• Correspondent relationships. AMLR Art. 36: senior management approval before establishing new cross-border correspondent relationships involving the execution of payments with a third-country respondent institution.

• Who counts as senior management. AMLR Art. 2(1)(40): members of the management body in its management function, and officers and employees with sufficient knowledge of the firm's ML/TF risk exposure and sufficient seniority to take decisions affecting it.

• Human intervention for automated decisions. AMLR Art. 76(5)(b): decisions resulting from automated processes or AI systems on entering, refusing or maintaining a relationship must be subject to meaningful human intervention.

• In the AI Act. AI Act Art. 14(5) requires verification by at least two natural persons, but only for remote biometric identification systems (Annex III point 1(a)); it is not a general rule for compliance tools.