The Conference of State Bank Supervisors (CSBS) and the Money Transmitter Regulators Association (MTRA) released an important report on the state of the industry that is a must read for anyone in the industry and a report that all US Money Transmitters should be sending to their banks. The report is entitled “The state of state money services businesses regulation & supervision” and it examines the non-bank financial sector in the US and the bank discontinuance and de-risking challenges the industry faces. But the main objective is to let the banks know of the strict regulations and close supervision the state regulators have on all licensed MSBs.Details
As I leave Barcelona after IMTC EMEA 2016 this past May 18-20 and I reflect on the industry, I can’t help but feel proud of the work we do at IMTC and the people we serve. Even talking with long-time industry warriors who are tired of the increasing complexity of the sector, I am a positive person and I can’t help but look back on where we started, around 30-35 years ago, and where we are now. Yes, we face many problems: bank discontinuance, regulatory inconsistency, a somewhat tainted image, weak trade groups, just to name a few. But we are a strong and growing sector with new products and services, new client sectors and technology developments that are impressive. Let’s take a partial look at ourselves…Details
In the past IMTC BRASIL 2016 in Sao Paulo, Leonardo Costa made a presentation available in our Download Section entitled Nueva Guia GAFI Prestadores Servicios Transferencia Dinero Valores about the FATF – GAFI February 2016 document on the GUIDANCE FOR A RISK-BASED APPROACH for MONEY OR VALUE TRANSFER SERVICES. The Guidance in Page 46 (#125) urges the Banks to “not resort to the wholesale termination or exclusion of customer relationships within the MVTS (money or value transfer services) sector”.
Commenting on this Guidance and De-Risking and Bank Discontinuance problem – that is now extending as US Commercial Banks force local banks to close accounts of local MVTS companies – Leonardo use this great metaphor:Details
The Spanish Courts petitioned the European Tribunal for a guidance to clarify Bank Account Closure Cases and the presumption of remittances being high risk
Our IMTC speaker and colleague Antonio Selas from the firm Cremades & Calvo Sotelo in Madrid has been preventing Banks from closing bank accounts of MTOs in Spain by taking to court the banks and convincing judges that Banks are discriminating against their competitors and that their “remittances are high risk” argument has no factual evidence. We met Antonio Selas in IMTC EMEA 2015 in Istanbul and he came to Miami and made a presentation in IMTC WORLD 2015 entitled “Bank Account Closures Are Against the Law“.Details
Barcelona recibe a la industria mundial de remesas y transferencias internacionales de dinero en Mayo
Las remesas en España tienen una historia muy particular. En la actualidad y según el IFAD en Roma (Fondo Internacional de Desarrollo Agrícola – FIDA en español) España es el sexto país europeo en volumen saliente de remesas con un total anual de 9.600 millones en el 2014. Los datos del Banco Mundial (Factbook 2016) sitúan el total para España en 8.794 millones. Rusia se ubica en un primer lugar con 20.600 millones de dólares, seguido por el Reino Unido (17.100 millones), Alemania (14.000 millones), Francia (10.500 millones), Italia (10.400 millones). Los inmigrantes en Europa enviaron 109.400 millones de dólares (97.500 millones de euros) en 2014 a sus familias, alrededor del 25% de las remesas mundiales.Details
I developed the MTBIT FORUM in 2015 with the help of Andrew Ittleman, a Miami Attorney who represents companies and individuals in highly regulated sectors in the US and Greta Geankoplis, a fintech leader and industry trailblazer, both members of the IMTC Advisory Board. The forum was conceived as a chance for entrepreneurs, start-ups and project developers using blockchain-based protocols, for international money transfers, remittances & payments, to meet, network and share the challenges they face while at the same time discussing the realistic opportunities available in the industry.Details
The timing could not have been better. FATF just published – February 2016, a report that all Compliance Officers of this industry must read, entitled Guidance for a Risk-Based Approach for Money or Value Transfer Services (Summary – Full Report (69 pages). I want to highlight three statements in the presentation of the report:
- The risk-based approach, the cornerstone of the FATF Standards, requires that measures to combat ML/TF are commensurate with the risks. Such measures should not necessarily result into the categorization of all MVTS providers as inherently high-risk.
- The overall risks and threats are influenced by the extent and quality of regulatory and supervisory framework, as well as the implementation of risk-based controls and mitigating measures by each MVTS provider.
- While this Guidance is applicable to the entire MTVS sector (both banking and non-banking institutions offering MVTS); it is primarily intended for non-banking MVTS providers.
I think it is very important that every person in this industry reads the GAO Report published on February 16th, 2016, entitled INTERNATIONAL REMITTANCES: Actions Needed to Address Unreliable Official U.S. Estimate – Highlights Page (1 page), Full Report (62 pages). A second report published the same day is entitled INTERNATIONAL REMITTANCES: Money Laundering Risks and Views on Enhanced Customer Verification and Record keeping Requirements– Highlights Page (1 page), Full Report (59 pages), Accessible Version (62 pages).Details
Hugo Cuevas-Mohr puts together every year the 10 Most important Issues for the industry. To download the PDF go to Download/IMTC Publications.
Bitcoin, as a remittance tool, is now being used by a few pioneer firms, while the overall acceptance of the blockchain protocol as a significant invention has shifted the rhetoric about VCs for the better. With MTBIT, at IMTC, we have been actively seeking individuals and firms using blockchain protocols to offer solutions to cross-border customers.Details