Presentation at Prepaid Summit Asia 2011, Mumbai India, focuses on financial regulatory issues for prepaid payment instruments with examples from Asia, Asia Pacific and Australia
2. Overview
Prepaid regulatory issues in Asia
Examples of different approaches to
regulation (regulator and industry)
Emerging themes
3. Asia – Regulatory Focus
Frontier/ Emerging Developing Developed
Personal Channelling Innovation
Safety remittance Competition
Financial flows
Inclusion – Legitimate, saf
Savings e and cost
effective
PNG Philippines Australia,
Singapore
4. Common Concern
Whatto do when non-banks are
proposing to be the issuers of the prepaid
value?
Regulatory response will depend on local
context
5. Regulations Influence…
How business models are structured
How agents are used in your model
How customers are able to register for
accounts
How customers can do cash-in and cash-
out transactions
6. Regulatory Focus
Safety Efficiency
Issuance and Interoperability
Management of the
Float Competition
Operational/Security
Risks
AML/CFT and KYC
Agents
Consumer Protection
7. Balance
Investment in security by issuers
Mitigation of risk - money laundering,
terrorist financing and fraud
8. AML/CFT and KYC
Financial Action Task Force (FATF)
Tiered KYC (Philippines, Singapore)
Financial
and Telco Regulators - is there
communication between the two
regulators? (Fiji)
9. Agency Arrangements
What can non-banks do? Cash-in and
cash-out?(Cambodia / Malaysia)
Liability of banks and non-banks – is it the
same? (Philippines / Kenya)
Liquidity and credit risk – mitigate through
improved clearing and settlement
arrangements (Philippines)
Consumer protection and role of agents
(Philippines)
12. Industry Approaches
Involve financial regulator early
(Philippines, Indonesia)
Encourage cooperation with regulator
(Cambodia)
Encourage cooperation among industry
players in working with regulator (Philippines)
Seek beneficial partnership solutions(China)