Paper discussing the emergence of mobile commerce in the United States and comparing development in the US with more advanced adopters of the technology across the globe.
While innovative new technologies have been very efficient in combating traditional fraud, our research has found that digital technologies are also giving rise to new types of digital tax fraud: the increase in the number of e-filings of tax returns across geographies is driving new types of fraud using identity theft as the basis.
Another type of fraud taking shape is Zapping – using software programs to automatically skim cash from electronic cash registers (ECR) or point of sale systems.
Similarly, the growing usage of third-party payroll processors is opening up a whole new avenue of fraud where unscrupulous processors siphon off taxes due to the state.
Our analysis of these new digital tax frauds shows that inaction is not an option for tax authorities. We have modelled the evolution of tax fraud, taking into account new incidents of fraud enabled by digital technologies. Our findings are sobering for tax authorities. In a scenario where tax authorities continue to fight new tax fraud with conventional tools, we estimate digital tax fraud in the US will rise from $32 billion to $49 billion by 2020.
To combat this staggering scale of fraud, conventional methods are too slow for the digital age. Tax authorities must move away from an incremental, piecemeal approach to a much more comprehensive transformative line of attack with a long-term vision, roadmap and multifaceted solutions involving people, processes and technology.
What is the impact of inaction of tax authorities to rein in new types of digital tax fraud? How can analytics be used as an effective weapon to fight against digital tax fraud.
FinTech Applications & Tools for Financial HealthJohn Owens
During my presentation in March in Kyiv, Ukraine, I shared global examples of FinTech tools and applications that can not only support greater financial inclusion but, more importantly, can address the overall financial health of customers and improve consumer protection.
While innovative new technologies have been very efficient in combating traditional fraud, our research has found that digital technologies are also giving rise to new types of digital tax fraud: the increase in the number of e-filings of tax returns across geographies is driving new types of fraud using identity theft as the basis.
Another type of fraud taking shape is Zapping – using software programs to automatically skim cash from electronic cash registers (ECR) or point of sale systems.
Similarly, the growing usage of third-party payroll processors is opening up a whole new avenue of fraud where unscrupulous processors siphon off taxes due to the state.
Our analysis of these new digital tax frauds shows that inaction is not an option for tax authorities. We have modelled the evolution of tax fraud, taking into account new incidents of fraud enabled by digital technologies. Our findings are sobering for tax authorities. In a scenario where tax authorities continue to fight new tax fraud with conventional tools, we estimate digital tax fraud in the US will rise from $32 billion to $49 billion by 2020.
To combat this staggering scale of fraud, conventional methods are too slow for the digital age. Tax authorities must move away from an incremental, piecemeal approach to a much more comprehensive transformative line of attack with a long-term vision, roadmap and multifaceted solutions involving people, processes and technology.
What is the impact of inaction of tax authorities to rein in new types of digital tax fraud? How can analytics be used as an effective weapon to fight against digital tax fraud.
FinTech Applications & Tools for Financial HealthJohn Owens
During my presentation in March in Kyiv, Ukraine, I shared global examples of FinTech tools and applications that can not only support greater financial inclusion but, more importantly, can address the overall financial health of customers and improve consumer protection.
MTBiz is for you if you are looking for contemporary information on business, economy and especially on banking industry of Bangladesh. You would also find periodical information on Global Economy and Commodity Markets.
A need for peer to-peer strong local authentication protocol (p2 pslap) in mo...IJNSA Journal
Mobile phones are considered to be the most common devices in history of humankind. They have involved
in financial transaction such as mobile banking and mobile payment, which include sensitive information.
Public key cryptography is the proven solution that can provide secure transaction at every point of
interaction in mobile banking value chain. This paper proposes a need for peer-to-peer Strong Local
Authentication Protocol (p2pSLAP) for Mobile Banking Transaction that implements a peer-to-peer
architecture to provide local authentication mechanism between the customer and the agent. It employs
public key infrastructure (PKI).
Mobile Payments Reloaded - Ericsson Business Review #3 2008Giorgio Andreoli
After much hype in the late 90's, mobile payments again stand out as one of the most interesting options for enabling a new breed of non-voice mobile services. This is especially true in Europe, owing to a regulatory breakthrough that is liberalizing the payments sector and encouraging new players – namely, telecom operators – to enter this new area.
Overview of Digital Financial Services LandscapeJohn Owens
This presentation reviews the digital financial service landscape and is a primer for regulators and policy makers wishing to better understand current market developments.
"Digital and Mobile Payment Systems in Turkey" presentation in "Understanding FinTech in Islamic Finance Workshop" on February 20-21 2018 at Marmara Taksim Hotel, Istanbul
Sample Report: Global Online Payment Methods: Second Half 2017yStats.com
Free Report Samples for our publication " Global Online Payment Methods: Second Half 2017".
Find the full updated 2021 report available for purchase at: https://bit.ly/3wPpPbm
Sample Report: North America Online Payment Methods 2019yStats.com
Free Report Samples for our publication " North America Online Payment Methods 2019".
Find the full report available for purchase at: https://bit.ly/3LTgIw5
Mobile Wars: Fintech vs. Banks... and Big Tech in AmbushKatia Bazzocchi
Pure mobile banks gain users daily, as they benefit from accessible smartphone technology. Millenials are the principal users of mobile banks, and will soon be followed by Generation Z. As consumer expectations continue to be shaped by new technology and innovative consumer affairs, a full mobile strategy is key for traditional banks to maintain market share.
MTBiz is for you if you are looking for contemporary information on business, economy and especially on banking industry of Bangladesh. You would also find periodical information on Global Economy and Commodity Markets.
A need for peer to-peer strong local authentication protocol (p2 pslap) in mo...IJNSA Journal
Mobile phones are considered to be the most common devices in history of humankind. They have involved
in financial transaction such as mobile banking and mobile payment, which include sensitive information.
Public key cryptography is the proven solution that can provide secure transaction at every point of
interaction in mobile banking value chain. This paper proposes a need for peer-to-peer Strong Local
Authentication Protocol (p2pSLAP) for Mobile Banking Transaction that implements a peer-to-peer
architecture to provide local authentication mechanism between the customer and the agent. It employs
public key infrastructure (PKI).
Mobile Payments Reloaded - Ericsson Business Review #3 2008Giorgio Andreoli
After much hype in the late 90's, mobile payments again stand out as one of the most interesting options for enabling a new breed of non-voice mobile services. This is especially true in Europe, owing to a regulatory breakthrough that is liberalizing the payments sector and encouraging new players – namely, telecom operators – to enter this new area.
Overview of Digital Financial Services LandscapeJohn Owens
This presentation reviews the digital financial service landscape and is a primer for regulators and policy makers wishing to better understand current market developments.
"Digital and Mobile Payment Systems in Turkey" presentation in "Understanding FinTech in Islamic Finance Workshop" on February 20-21 2018 at Marmara Taksim Hotel, Istanbul
Sample Report: Global Online Payment Methods: Second Half 2017yStats.com
Free Report Samples for our publication " Global Online Payment Methods: Second Half 2017".
Find the full updated 2021 report available for purchase at: https://bit.ly/3wPpPbm
Sample Report: North America Online Payment Methods 2019yStats.com
Free Report Samples for our publication " North America Online Payment Methods 2019".
Find the full report available for purchase at: https://bit.ly/3LTgIw5
Mobile Wars: Fintech vs. Banks... and Big Tech in AmbushKatia Bazzocchi
Pure mobile banks gain users daily, as they benefit from accessible smartphone technology. Millenials are the principal users of mobile banks, and will soon be followed by Generation Z. As consumer expectations continue to be shaped by new technology and innovative consumer affairs, a full mobile strategy is key for traditional banks to maintain market share.
3 Things Every Sales Team Needs to Be Thinking About in 2017Drift
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Read the full story on the Drift blog here: http://blog.drift.com/sales-team-tips
How to Become a Thought Leader in Your NicheLeslie Samuel
Are bloggers thought leaders? Here are some tips on how you can become one. Provide great value, put awesome content out there on a regular basis, and help others.
The Internet of Things: A Prime Opportunity for Merchant AcquirersCognizant
For merchants, the Internet of Things’ vast connectivity makes it easy for consumers to purchase within an environment that is intuitive, familiar and comfortable. For acquirers, there is the opportunity to provide various interfaces for accepting payments from all connected touchpoints -- creating an omnichannel experience for customers.
M Com And Microsoft - Mobile Payments White Papermistervandam
M-Com and Microsoft collaborated on putting together a white paper on mobile payments for financial institutions. There is a lot of \'noise\' about M-Payments - this document aims to dissect the key elements of a successful mobile payments strategy.
The Article explores the possibility of Blockchain being the Saviour of the Banks.
The article was republished in Journal of Insitute of Bankers of Pakistan - July 2018
Mobile in Banking and Finance - What Make Sense and What Notr4b
In recent years, the banking & financial services industry has been undergoing rapid changes, reflecting a number of underlying developments. Internet, wireless technology, and global straight-through processing have created a paradigm shift - from brick-and-mortar banks to banking virtually across time zones, geographical locations, access points and delivery channels. Today Mobile revolution has disrupted banking industry and this presentation provides a detailed discussion about issues of Mobile Banking.
Secure Payments: How Card Issuers and Merchants Can Stay Ahead of FraudstersCognizant
Our latest research reveals that merchants and card issuers should take a layered approach to mitigating risk, by working with consumers to improve fraud detection and prevention.
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The evolution of FinTech (Financial Technology) drastically transformed the way traditional financial institutions – insurers and banks functioned. To thrive, global companies, retailers, and large tech giants realized the need to reinvent the value chain of financial services.
Sample Report_Middle East and Africa Online Payment Methods 2021_by yStats.pdfyStats.com
-What is the Value of Digital Wallet Spending 2020 & 2025f?
-What is the Value of Mobile Payment Transactions Authenticated via Biometrics 2020 & 2025f?
-What is the Share of Consumers Who Claimed That Digital Payments Help Them Save Money in 2021 in UAE?
Find the full report available at:
https://ystats.com/shop/middle-east-and-africa-online-payment-methods-2021/
This presentation explores what future of commerce may look like given the current trends in mobile devices, digital payments, social commerce and security including tokenization and new forms of identity verification
Falcon stands out as a top-tier P2P Invoice Discounting platform in India, bridging esteemed blue-chip companies and eager investors. Our goal is to transform the investment landscape in India by establishing a comprehensive destination for borrowers and investors with diverse profiles and needs, all while minimizing risk. What sets Falcon apart is the elimination of intermediaries such as commercial banks and depository institutions, allowing investors to enjoy higher yields.
How to get verified on Coinbase Account?_.docxBuy bitget
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Turin Startup Ecosystem 2024 - Ricerca sulle Startup e il Sistema dell'Innov...Quotidiano Piemontese
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2. Elemental Economics - Mineral demand.pdfNeal Brewster
After this second you should be able to: Explain the main determinants of demand for any mineral product, and their relative importance; recognise and explain how demand for any product is likely to change with economic activity; recognise and explain the roles of technology and relative prices in influencing demand; be able to explain the differences between the rates of growth of demand for different products.
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Seminar on gender diversity spillovers through ownership networks at FAME|GRAPE. Presenting novel research. Studies in economics and management using econometrics methods.
how to sell pi coins effectively (from 50 - 100k pi)DOT TECH
Anywhere in the world, including Africa, America, and Europe, you can sell Pi Network Coins online and receive cash through online payment options.
Pi has not yet been launched on any exchange because we are currently using the confined Mainnet. The planned launch date for Pi is June 28, 2026.
Reselling to investors who want to hold until the mainnet launch in 2026 is currently the sole way to sell.
Consequently, right now. All you need to do is select the right pi network provider.
Who is a pi merchant?
An individual who buys coins from miners on the pi network and resells them to investors hoping to hang onto them until the mainnet is launched is known as a pi merchant.
debuts.
I'll provide you the Telegram username
@Pi_vendor_247
how can I sell pi coins after successfully completing KYCDOT TECH
Pi coins is not launched yet in any exchange 💱 this means it's not swappable, the current pi displaying on coin market cap is the iou version of pi. And you can learn all about that on my previous post.
RIGHT NOW THE ONLY WAY you can sell pi coins is through verified pi merchants. A pi merchant is someone who buys pi coins and resell them to exchanges and crypto whales. Looking forward to hold massive quantities of pi coins before the mainnet launch.
This is because pi network is not doing any pre-sale or ico offerings, the only way to get my coins is from buying from miners. So a merchant facilitates the transactions between the miners and these exchanges holding pi.
I and my friends has sold more than 6000 pi coins successfully with this method. I will be happy to share the contact of my personal pi merchant. The one i trade with, if you have your own merchant you can trade with them. For those who are new.
Message: @Pi_vendor_247 on telegram.
I wouldn't advise you selling all percentage of the pi coins. Leave at least a before so its a win win during open mainnet. Have a nice day pioneers ♥️
#kyc #mainnet #picoins #pi #sellpi #piwallet
#pinetwork
What website can I sell pi coins securely.DOT TECH
Currently there are no website or exchange that allow buying or selling of pi coins..
But you can still easily sell pi coins, by reselling it to exchanges/crypto whales interested in holding thousands of pi coins before the mainnet launch.
Who is a pi merchant?
A pi merchant is someone who buys pi coins from miners and resell to these crypto whales and holders of pi..
This is because pi network is not doing any pre-sale. The only way exchanges can get pi is by buying from miners and pi merchants stands in between the miners and the exchanges.
How can I sell my pi coins?
Selling pi coins is really easy, but first you need to migrate to mainnet wallet before you can do that. I will leave the telegram contact of my personal pi merchant to trade with.
Tele-gram.
@Pi_vendor_247
Yes of course, you can easily start mining pi network coin today and sell to legit pi vendors in the United States.
Here the telegram contact of my personal vendor.
@Pi_vendor_247
#pi network #pi coins #legit #passive income
#US
The emergence of m commerce promises great benefits, but also poses significant regulatory concern
1.
2. resolve the regulatory uncertainty created by the conflicting duties the Bank Secrecy Act, 31 USC § 5311-5330, and the Stored Communications Act, 18 U.S.C. §§ 2701-2711, imposes on them, and
3.
4. The uninitiated release of information to the government from the provider. While AML laws require financial institutions to report financial information to the government without a government request, under a telecom centric M-pay model, the Stored Communications Act forbids such uninitiated reporting. As the telecom centric model can work outside the purview of a bank, it creates the potential of the Stored Communications Act forbidding any uninitiated reporting of suspicious or routine financial transactions that otherwise would be reported. <br />“Under the private search doctrine, the Fourth Amendment is wholly inapplicable to a search or seizure, even an unreasonable one, effected by a private individual not acting as an agent of the Government or with the participation or knowledge of any governmental official.” Eighteen U.S.C. § 2702 creates privacy safeguards by providing that a provider of an “electronic communication service” shall not divulge the contents of a communication held by it and shall not divulge information it receives on behalf of the user via an electronic transmission provided the user does not authorize such a release. The Act goes further and states that the service provider shall not knowingly release a “record or other information” pertaining to the user to “any governmental entity.” In addition to creating the crime, this title also provides for a punishment for non-commercial benefit, which is generally a fine and/or imprisonment of not more than one year for a first offense, or more than five years and/or a fine for other convictions under the statute. The Act also includes exclusions for law enforcement, but they consist of specific government requests for information and emergencies, and not routine disclosures by the telecoms to satisfy Bank Secrecy Act requirements.<br />The courts have drawn lines between a wealth transfer service that utilizes an electronic format and a communications provider providing the means for a wealth transfer. In Standefer, the court had the opposite issue, a financial institution using an ISP, in contrast to our dilemma, the telecom transferring wealth in its own right. In Standefer, Standefer, the defendant in a child pornography case, transferred a payment for access to a child pornography website using e-gold. E-gold had accepted a deposit from the defendant and allowed the defendant to fill out a form on e-gold’s website to transfer a sum to the child pornography website. In differentiating between the wealth transfer service and communications provider: <br />[t]he Court concludes that e-gold is not a service which provides users the ability to send or receive electronic communications, rather e-gold is a service which utilizes the ability to send or receive electronic communications to permit the instant transfer of gold ownership between its users.<br />(Emphasis in original). The court also cites a Senate report stating “Existing telephone companies and electronic mail companies are providers of electronic communication services,” which differentiates it from e-gold’s service. <br />Essentially, what has been created is a money laundering protection because the Stored Communications Act forbids the telecom from reporting on the electronic/radio messages. These messages fall clearly within the statute. Further, inside these messages contain the financial transaction activity. The irony is that the telecom centric M-pay enjoys greater privacy for transactions than their bank centric counterpart. This gives it a competitive advantage and opens the door for an unscrupulous telecom provider to assist in the laundering of funds. Even if the telecom wanted to report transaction information, the statute forbids it under a criminal penalty. Thus, the only way for the government to gather the information is through the subpoena or warrant process, but the concept of the Bank Secrecy Act is to provide the government the information that there is suspicious activity. We have a legislatively created Catch-22, as the telecoms have an affirmative duty to not report violations of the Bank Secrecy Act and anti-smurfing acts that were created to give the government the information needed to pursue AML activities. <br />How To Resolve The Catch-22 Regarding BSA Reporting<br />Before Congress looks into new regulatory mechanisms to combat ML, they first need to assess concerns about the market as a whole and the need to balance regulations with the need to keep the market open and free, to allow companies to experiment and innovate. “In any new market, enablement requires a blend of legal and regulatory openness, which creates the opportunity to startup and experiment, with sufficient legal and regulatory certainty that there will not be arbitrary or negative change to the regulatory framework, so that providers have the confidence to invest the resources necessary” to develop and expand their industry (emphasis in original). Thus far, the United States has not passed substantial legislation, allowing the States to take the lead. <br />Another consideration is the role of the Stored Communications Act in the first place. Its goal is to protect the privacy of individuals from dissemination of their communications, especially to the government. The Fourth Amendment offers weak protections from intrusion of a person’s expectation of privacy of electronic and mobile content. The Fourth Amendment applies to the government. Non-government actors are free to look over electronic communications placed within their control, such as an email sitting in one’s email inbox on a server. Further, many electronic companies are third parties. Once content is delivered to them for storage, it may be deemed that the customer had ceded control to them, destroying a reasonable expectation of privacy. Where a reasonable expectation of privacy was non-existent, Congress legislated one.<br />From these concerns, the goal is to balance the need to effect financial reporting while protecting a Statutorily created Reasonable Expectation of Privacy (SREP) while minimizing cumbersome regulation. First, Congress must decide where to insert a new of modified regulation, under Title 47, which governs telecommunications, under Title 31 which governs financial transactions, or under Title 18, which contains the criminal code. As the conflict of regulation exists outside of Title 47, it can easily be excluded. The question becomes whether Title 31 or Title 18 should give way to the other. <br />As stated earlier, the purpose of the Bank Secrecy Act under Title 31 is to require reporting information to the government that is suspicious or would be useful in a criminal investigation. In short, the Bank Secrecy Act assists in criminal investigations for crimes found under Title 18 as it prevents banks from being used, knowingly or not, as a conduit for money laundering activities and creates a paper trail that the government can later use for investigatory purposes. The Bank Secrecy Act also provides penalties of its own, and has been held to be a separate prosecutorial offense from money laundering. <br />The Stored Communications Act is a privacy act. It also is a standalone crime with punishment. The Act’s sole function is to create an SREP, which would naturally give way to a privacy invasion under reasonable circumstances. Further, it already contains exclusions, such as releasing information for law enforcement to respond to an emergency. The Stored Communications Act sits in Title 18, whereas Bank Secrecy Act is firmly rooted in Title 31, financial transactions. It seems that taking the Stored Communications Act statute and placing it into the financial services regulatory regime could cause unintended effects and potentially expose the telecoms to excess regulation. However, taking 31 U.S.C. § 5311-5330 and inserting them into the Stored Communications Act as an exception to the prohibition to uninitiated disclosures to the government would adequately address money-laundering concerns while still adhering to Congress’ goal of securing privacy through creation of an SREP.<br />Eighteen U.S.C. § 2702 (c) should be modified to create an exception commanding the telecom to monitor and report financial transactions in accordance with 31 U.S.C. § 5311-5330. This would firmly allow telecoms to report suspicious transactions as required under Bank Secrecy Act.<br />An Additional Housekeeping Matter<br />To alleviate any ambiguities in regards to the telecoms and financial reporting, Congress should also modify the definition of a financial institution. Eighteen U.S.C. § 1956 uses the definition found under 31 U.S.C. § 5312 which defines a financial institution in very broad terms that includes a telegraph company and the general catch all that stipulates any business that the Secretary of the Treasury may deem as a financial institution as falling within the confines of the expansive definition found in 31 U.S.C. § 5312. , Congress should amend 31 U.S.C. §5312 to specifically identify the telecoms to put them on notice, which could most easily be accomplished under 31 U.S.C. §5312 (2) (S), modifying “telegraph” to the more expansive “telecommunications company.” This would serve as a clear and fair notice to the telecoms that they can be financial institutions and avoid the generic snare through a catchall phrase. <br />How to Reign Invisible NFC Transfers<br />Congress should work with the telecom providers to develop a system that will achieve the goals of law enforcement and regulators to detect and prevent money laundering while being inexpensive and convenient enough to avoid dissuading investment and innovation. Congress could seek to establish a financial monitoring and reporting requirement for the telecoms to adhere. This duty should not prove overly burdensome, as telecoms already monitor much information about the cell while it is on, creating an already established electronic infrastructure for Congress and the telecoms to exploit. Additionally, Congress and the telecoms can look to successful programs adopted in the Philippines, which includes transactions limits, transactions caps and a paper trail, i.e. deposit and withdrawal forms.<br />NFC transfers occur P2P, bypassing the cell phone tower, thereby avoiding scrutiny by cellular telecommunications companies, i.e. making the transaction invisible. This essentially creates the problem of allowing electronic transfers of money without anyone learning about the movement until the ultimate receiver of funds chooses to enter it into the system. It can be presumed that this end receiver would have put forth the effort into properly having had laundered the money, thereby using only clean money. <br />While these transactions are invisible, the cell phone is not. The cell phone is “always” in communication with cell towers, regardless of calling status, to provide its location and identify itself on the network. The reason for these “check-ins” is so the telecom can bill their clients according to use, allow service, and provide location finding/GPS services and comply with Wireless E911. Further, cell phones are individually identifiable. To further understanding, a brief explanation of what happens when a user turns a cell phone on follows:<br />All cell phones have special codes associated with them. These codes are used to identify the phone, the phone's owner and the service provider. <br />Let's say you have a cell phone, you turn it on and someone tries to call you. Here is what happens to the call: <br />When you first power up the phone, it listens for an [System Identification Code] SID … on the control channel. The control channel is a special frequency that the phone and base station use to talk to one another about things like call set-up and channel changing. If the phone cannot find any control channels to listen to, it knows it is out of range and displays a quot;
no servicequot;
message. <br />When it receives the SID, the phone compares it to the SID programmed into the phone. If the SIDs match, the phone knows that the cell it is communicating with is part of its home system. <br />Along with the SID, the phone also transmits a registration request, and the [Mobile Telephone Switching Office] MTSO keeps track of your phone's location in a database -- this way, the MTSO knows which cell you are in when it wants to ring your phone. <br />The MTSO gets the call, and it tries to find you. It looks in its database to see which cell you are in. <br />The MTSO picks a frequency pair that your phone will use in that cell to take the call. <br />The MTSO communicates with your phone over the control channel to tell it which frequencies to use, and once your phone and the tower switch on those frequencies, the call is connected. Now, you are talking by two-way radio to a friend. <br />As you move toward the edge of your cell, your cell's base station notes that your signal strength is diminishing. Meanwhile, the base station in the cell you are moving toward (which is listening and measuring signal strength on all frequencies, not just its own one-seventh) sees your phone's signal strength increasing. The two base stations coordinate with each other through the MTSO, and at some point, your phone gets a signal on a control channel telling it to change frequencies. This hand off switches your phone to the new cell <br />(emphasis in original). Let's say you're on the phone and you move from one cell to another -- but the cell you move into is covered by another service provider, not yours. Instead of dropping the call, it'll actually be handed off to the other service provider. <br />If the SID [System Identification Code] on the control channel does not match the SID programmed into your phone, then the phone knows it is roaming. The MTSO [Mobile Telephone Switching Office] of the cell that you are roaming in contacts the MTSO of your home system, which then checks its database to confirm that the SID of the phone you are using is valid. Your home system verifies your phone to the local MTSO, which then tracks your phone as you move through its cells. And the amazing thing is that all of this happens within seconds ... <br /> <br />As can be seen, many things are going on while the cell phone is engaged in communications, regardless of calling status. This constant communication could provide the missing link to ensure adequate reporting of NFC transfers. Congress may seek to prod the telecoms to develop the technology, software, or just initiative to develop a way for the telecom to monitor for NFC transactions that have occurred and their amounts while the cell phone is transmitting its System Identification Code for network registration. In essence, Congress would create a duty for the telecoms to monitor for financial transactions occurring on their networks. <br />The result of these monitored and recorded NFC transactions would allow for compliance of Bank Secrecy Act reporting and recording standards. It would also provide a way for law enforcement to gather evidence if this technology were to develop to allow regular NFC transactions between people engaged in an illegal business, such as narcotics sales or prostitution. The suspects’ ability to hide or destroy evidence would be greatly hindered by a monitored network. Further, as these are electronic communications, they would also be protected by the Stored Communications Act, preventing unauthorized disclosure to government or private parties. This approach, if feasible, could satisfy Congress’ goals of privacy under Stored Communications Act with law enforcement and regulatory needs under Bank Secrecy Act and AML. However, as with many things, this is easier said than done, and the proper course of action would be for the Congress and telecoms to work together to formulate a satisfactory mutual solution.<br />A second option, one that is used in the Philippines is also available. In the Philippines, a company, Globe Telecom, offers P2P wealth transfers under the telecom centric model. It operates under a closed system, where the user can only transfer wealth to other Globe Telecom customers. In order to establish an account, the user must open the account in person, allowing Globe Telecom to perform traditional due diligence. Further, all withdrawals require a form to be filled out before funds are given. Probably most importantly, there are strict limits to the amounts of daily and monthly amounts that can be transferred, which are quite low. The financial caps, in effect, prices out ML activity, as the amounts are too small to launder money. Globe Telecom also monitors transactions.<br />While this can serve as a potential model for implementation in the US, it also has drawbacks. Namely, being a closed payment system could severally limit the telecoms and merchants ability to allow for transfers of wealth due to problems with service compatibility. Further, if one telecom becomes the dominant provider of m-commerce, it could monopolize the industry, as users and merchants may be reluctant to having to sign up for multiple cellular agreements to effect trade, and would naturally use only the most popular one. This restraint on trade would ultimately hurt the consumer, as their choice would be limited, and limited opportunities could result in limited innovation and certainly limited competition. Additionally, the SIM may be hacked and reprogrammed, thereby defeating built in NFC controls.<br />While Global Telecom’s solution may not be a perfect match for the expansive US telecommunications industry, it is worthy to note that Global Telecom has taken proactive measures to monitor financial transactions for irregular and suspicious activities. This monitoring occurs outside the NFC context, it does show that telecoms can efficiently monitor for illegal activities and seek to take counter measures to prevent or disrupt them. Another valuable tool that Globe uses is the withdrawal caps. These caps can be analogized to the ATM withdrawal caps in the United States, especially in response to suspicious activities. In short, there are opportunities and examples that Congress and the telecoms can look to develop appropriate safeguards to allow m-pay and m-banking to flourish.<br />Digital Know Your Customer<br />Another area that the Congress and telecoms can work to prevent and detect money laundering and enforcement of the Bank Secrecy Act is through proper due diligence, or Know Your Customer. KYC is a set of principals laid out by FATF that instruct banks how to prevent ML and Bank Secrecy Act violations by properly identifying customers, learning their habits, purposes for accounts, etc. As the digital world has expanded, it would be worthwhile to explore and recommend Digital Know Your Customer (DKYC) protocols that telecoms, regardless of whether they follow the bank or telecom centric m-pay or m-banking model, should enact, as physical distance will increase between customers and their accounts as they opt for more convenient methods of wealth transfers. <br />An interesting recommendation was made in a working paper of the Asian Development Bank, which discussed biometrics in the cell phone handset. Currently, there are wide variety of biometric handset security features available, including voice, facial and fingerprint recognition. However, the potential of hacking of the SIM was still possible, potentially allowing for defeating these countermeasures. Notwithstanding the caution, biometrics in other areas has helped prevent fraud. Research in the use of biometrics for visa application in Canada found:<br />Field trial enrolments [sic] for visa applications totalled [sic] 14,854. Of those 14,854 enrolments [sic], 394 matches were made because of multiple enrolments [sic]. Those match results show that biometric technology is a highly effective way to manage client identity:<br />97% of the fingerprint and facial biometrics enrolled were of high quality.<br />When facial and fingerprint recognition were combined, the system made matches in 100% of cases.<br />Verification was accurate in 96% of cases …<br /> While not completely alleviating concerns about SIM hacking, this study seems to support that biometrics can help prevent fraud. Fraud can allow cell phone users to swap accounts, establish false accounts, etc, so that they may be able to avoid financial transfer caps or to be able to structure transactions to avoid Bank Secrecy Act reporting requirements. <br />Another concern is whether biometrics can be cost effective or if imposing a new standard for m-commerce would cost too much. This maybe a red herring; however, as this technology already exists in other countries:<br />Japan’s leading cell phone provider, NTT DoCoMo, has recently launched the P930i, a new handset with the ability to recognize its owner’s face, and automatically lock down if anyone else tries to use it.<br />Simply storing three simple snapshots of your face on this cool new camera phone allows this innovative security feature to take effect, and protect your data from thieves and other prying eyes.<br />The feature is currently limited to the Japanese market, but with the help of new facial recognition applications, other countries aren’t far behind. Face Tracker, for example, a clever new piece of software from FotoNation makes it possible to follow a person’s face and auto-detect the best camera settings to take their picture.<br />While this example is not dispositive, it does show that the market is adapting to the new realities in the m-commerce world, so imposing heightened standards, such as biometrics as a form of DKYC would not impose an undue burden on the telecom industry.<br />Conclusion<br />Today, the United States is experiencing a new wave in the way business is conducted in the form of being able to use one’s cellular telephone to conduct business and banking transactions, i.e. engage in M-commerce. M-commerce has the ability to bring a new class of people who are traditionally underserved into the banking industry. Further, this development also will bring a new level of convenience to the consumer in the purchasing of various goods and services. This convenience also poses some regulatory concerns, especially in areas where various regulatory schemes seem to contradict each other. These contradictions can create uncertainty in the marketplace, potentially limiting investment, or worse, being exploited by unscrupulous telecom players to contravene various reporting and AML regulations, allowing for a black market to flourish, resulting in a greater reward for criminal behavior and potentially assisting terrorists in their nefarious schemes. <br />These uncertainties and risks can be adequately dealt with though, through modifying the current regulations, namely the Bank Secrecy Act and Stored Communications Act. Further, the goals of these acts, financial reporting and individual privacy, respectively, can be accommodated through a modification that adopts the Bank Secrecy Act under an exception of the Stored Communications Act. This adoption would allow the telecom to legally report financial transactions conducted through their communications without having to worry about violating the criminal code forbidding such disclosures. <br />The nature of banking is changing. Customers no longer need to go to the bank and meet with a teller in order to conduct a financial transaction. People no longer need to meet their banker before establishing an account with them. These personal contacts were at the heart of the traditional due diligence that a banker performed before establishing an account. 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