Industry In attempting to determine future trends in the payments industry, a good question to ask is, “What are customer expectations?”. I believe we can all agree that customers want the payments they send and receive to be realized in real-time with minimum fees. They also want the option of which payment service provider they choose to…
This article was conceived after discussing with colleagues in the industry why the payments world has been driven into the Cash vs. Digital dichotomy. My research on cash has been inspired by analyzing the penalization of cash-based industries, such as the money transfer industry by the banking sector, which has resulted in the derisking phenomenon…
PART ONE: Cash: Is the payments king dying? or is the king creating its own separate kingdom? Although is not exactly clear how the payments industry will evolve in the near future, we agree that 2018 is likely to be a significant year for the financial services industry: banks, eCommerce, fintechs, payment institutions and other alternative…
In my recent visit to Chile, where I traveled to make sure the country would be the best site for our 2019 IMC LATAM conference, I was very surprised by the large number of migrants entering the country, the growing number of agents & branches of established money transfer companies such as AFEX, MORE Money…
QUÉ NOS DEJÓ EL 2017 y cómo vemos a la industria en el próximo año. En un breve resumen escrito según mi perspectiva, voy a recorrer cuatro principales acontecimientos que vivimos en la Industria durante el 2017 y presentarles lo que podemos esperar para el 2018 con el fin de, en conjunto, mantener las empresas del…
We thank our colleague Carlos Grossman, for the report out of Chile where the Antimonopoly Division of the National Economic Prosecutor Office (División Antimonopolios de la Fiscalía Nacional Económica – FNE) reports the investigation that took place after an August 2015 complaint by a Forex Firm denouncing seven banks of denying the opening of a…
As you recall from the earlier blog, there are many reasons for MSBs to be cautiously optimistic: new banks are opening with a focus on various types of MSBs, regional and community-based financial institutions are gearing up to perform appropriate due diligence on potential clients, online firms who do not require branches for deposits are…
Key positive developments in banking for MSBs It’s been a bleak period for money transmitters over the past several years. The specter of derisking —that business-killing policy of many banks in the US and globally—may be disappearing. At least in the US where other entities are stepping up. Our colleagues in other parts of the…
De-risking was an acute illness for the Caribbean financial sector in 2015 and 2016. In 2017, the height of the fever has broken, but the patient is still sick. Though correspondent banks in developed countries are no longer dropping services to Caribbean banks at a rapid pace, the region’s economies remain encumbered with a residue…
How De-Risking is changing the face of Financial Services worldwide In July 6th & 8th the Economist published two articles that, again, raised the de-risking threat discussion to new levels. The July 6th article was entitled “The great unbanking [1] – Swingeing fines have made banks too risk-averse – It is time to rethink anti-money-laundering…
Los migrantes mexicanos en los EEUU son los mexicanos de primera clase. Es en general la población tomadora de riesgos, trabajadora, que tiene un diferente Work Ethic, aun con respecto a los propios trabajadores americanos promedio. Le dan un valor diferente al esfuerzo y la remuneración que por dicho esfuerzo perciben. Algunos son verdaderos emprendedores…
How the financial crisis, the evolution of Banking and Unbanking and the rise of technology in financial services are all connected The financial crisis and the rise of technology in financial services, that has led to an increase in the importance of NBFIs (Non-Bank Financial Institutions) in the provision of financial services, has created a…
Update – February 16, 2018 ; New Bill in Oklahoma and Nebraska – Contributed by the MSBA Georgia & Iowa move to leverage a tax on remittances – Financial Institutions are reacting In a previous blog (in Spanish), posted in the midst of the many reporter calls, especially from Latinamerica (driven by the anxiety over the…
Después de una serie de entrevistas a los medios un par de semanas atrás, en un viaje a Guatemala, me di cuenta en un momento que estaba siendo testigo de un cambio en la percepción pública de las remesas que no había captado antes. Respondiendo una por una las preguntas de los periodistas, era incuestionable…
Durante las primarias presidenciales republicanas del año pasado, Donald Trump expuso su propuesta de cómo forzar a México a pagar por el muro de 1,000 millas en la frontera entre Estados Unidos y este país. Los periodistas Bob Woodward y Robert Costa del Washington Post publicaron en Abril 5 de 2016 la noticia (http://wapo.st/2jbWHFn) en la cual Trump manifestaba su intención de amenazar a México con “cortar el suministro de remesas”. Trump envió en esta ocasión un memorando de dos páginas…
On December 12 in São Paulo, Brazil at the 2nd ABRACAM COMPLIANCE DAY an International Commission of Associations of Money Transfers Companies, Non-Bank Financial Services Companies, Foreign Exchange Firms and their Agents, was formed to make a public statement, signed by all the Associations, voicing their extreme concern regarding the negative impacts of “DE-RISKING” in the economic, financial e social areas of several countries in the region. They had met previously in November 11th, as part of IMTC WORLD 2016 “DE-RISKING & BANK DISCONTINUANCE FORUM” that discussed the impact of this practice in the Money Transfer, Remittance and Payment Industry. The termination of correspondent accounts of foreign financial institutions (FFIs) by US Commercial Banks as well as some these US Banks forcing local bank account closures by their corresponding banks in many countries in the region was also discussed at IMTC WORLD in an afternoon round table on Nov. 10, moderated by Daniel Trias.
On November 11th, as part of IMTC WORLD 2016 we will be having a “DE-RISKING & BANK DISCONTINUANCE FORUM” to discuss the impact of this practice in the Money Transfer, Remittance and Payment Industry as well as the U.S. depository institutions termination of correspondent accounts of foreign financial institutions (FFIs) as well as some US Banks forcing local bank account closures by their corresponding banks in many countries in the world.
As we informed all our special Friday Newsletter to subscribers in the UK, the Commonwealth Secretariat invited the International Money Transfer & Payments Industry to the “Disconnecting from Global Finance: A Conversation on De-Risking” meeting that was programmed this past Thursday, August 10th at Marlborough House in London. The meeting was called following the release of the Commonwealth’s report “Disconnecting from Global Finance: The Impact of AML/CFT Regulations in Commonwealth Developing Countries”. Passions ran high at the meeting as money transfer businesses and smaller financial institutions complained about the “detrimental” decline in international banking for many businesses and individuals.
To show how critical MSBs are to the functioning of the U.S. financial system, a 2013 Federal Deposit Insurance Corp. survey found 9.6 million U.S. households did not have bank accounts and 24.8 million households — 20 percent of the U.S. population — were underbanked, meaning they had bank accounts but also used alternative financial services outside of the banking system
Today, MSBs worldwide are caught in a banking crisis showing no signs of relenting. Based on real and imagined enforcement risks, most banks have categorically decided against providing accounts to MSBs, while others have been ordered by regulators to stop serving MSBs. This process of “de-risking,” by which banks terminate relationships with “high-risk” customers, has been brutal for the MSB industry and resulted in unforeseen consequences, including:
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.
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…
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…
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“.
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:
On De-Risking, Recent Bank Account Closures, The Somalian Remittance Crisis and the loud calls to try to resolve the MSB Bank Discontinuance crisis in the US (and UK, Australia… and almost everywhere) In English, a “moving target” is when you set your expectation for something – some task, some desirable outcome, a target, and then when it…
Right at 9 am, in the Cash Room of the Treasury Building last Tuesday, January 13th,, 100+ attendees gathered to participate in the Roundtable.
Bank Discontinuance of MTOs in Australia has been in the news for a couple of weeks and all the small and medium sized companies in the country are being forced to shutdown because all the major banks have been closing their accounts and letters of discontinuance have been sent to the 5,000+ MTOs in the…
We can’t say that the access to banking accounts problem is new in the Money Transfer Industry, not in the USA or a number of other countries. It was one of the reasons why the NMTA was formed back in 1996, David Landsman, Executive Director, reminds us every now and then. So why is this a such an urgent issue in 2014? I think the answer is that in the last decade a large number of small money transfer companies, with very little capital and minimal compliance structures were the first to go, now is the medium sized, larger companies, well funded, with large investments in technology and compliance the ones that are feeling the brunt. What should the industry do?
