IIPS

1. 1 | P a g e
Which laws apply and who enforces them?
Regulatory act checklist
Is there an act which governs
the actions of the central
bank?
Is there an act which governs
payments and/or payment
systems specifically?
Have any policy statements or
vision documents been issued
by the finance ministry or
central bank with respect to
payments?
Is there an act which
addresses anti-money
laundering requirements?
Is there an act which
addresses competition issues,
such as defining and
outlawing anti-competitive
practice?
Is there an act which covers
consumer protection in the
financial sector?
Is there an act which
addresses data protection
and/or data privacy?

2. 2 | P a g e
Checklist question Why this is important Hint
1
Is there an act which governs
the actions of the central bank?
Usually, the operation and oversight of
payment systems is one of the authorized
functions of a central bank.
These acts are often quite old; where the reference to
payment systems may be very brief and general but
may convey wide powers.
2
Is there an act which governs
payments and/or payment
systems specifically?
This legislation may set out explicit
requirements for licensing and oversight
of payment systems, their operators and
payment service providers.
Be aware of the difference between an act which
focuses on the national payment system, and an act
which focuses on payment services.
Some acts may do both, but the latter is more
common. Also, look out for whether this act defines
and regulates e-money.
If so, note the areas covered by
regulations or directives issued
under the act.
This is where explicit licensing and
reporting requirements may be found.
Look at the names of the regulations to get a sense of
what the regulations cover or apply to. Regulations
are binding and must be implemented. Looking at
how precisely they are worded will inform how tightly
prescriptive they are, and the objectives they hope to
achieve.
3
Is there a law which covers the
issuance of e-money?
This will affect whether entities other
than banks may participate in payment
schemes.
This may be a separate law or embedded in a wider
payments law.
4
Have any policy statements or
vision documents been issued by
the finance ministry or central
bank with respect to payments?
Such documents are statements of intent
which will give you an idea about planned
changes in law or practice.
Note how recently these documents have been
issued, and what the main points of coverage are.
5
Is there an act which addresses
anti-money laundering
requirements?
This will likely affect participants in a
scheme which have to open new
accounts, more than the scheme itself.
Laws like this cover multiple sectors and can be quite
long. Look for regulations which address account
opening by financial institutions in particular.

3. 3 | P a g e
Checklist question Why this is important Hint
6
Is there an act which addresses
competition issues, such as
defining and outlawing anti-
competitive practice?
This will define the space in which
collaboration can happen among
participants which otherwise compete.
Laws like this are also long and cover a multitude of
issues related to the competition authority. Scan their
site to see whether they have issued decisions or
reports in relation to payment or financial sector
practices.
7
Is there an act which covers
consumer protection in the
financial sector?
This will define the ways in which
information must be provided and
complaints handled.
You may find this in various places: a general act, a
specific act for the financial sector, or in regulations
issued for a specific institutional type such as banks.
8
Is there an act which addresses
data protection and/or data
privacy?
This will define how digital information
can be processed, used and stored.
These laws are quite new in many countries so are
often in early stage of implementation under agencies
called data protection authorities.