Our industry, our image, our trade groups…

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…

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The Best Bank De-Risking Metaphor

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…

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MONEY TRANSFER COMPANIES WIN A MATCH AGAINST BANKS IN BRUSSELS

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“.

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The MTBIT Forum in 2016: Remittances, Blockchains & Bitcoin

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.

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FATF-GAFI GUIDANCE – A Risk-Based Approach for Money or Value Transfer Services

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 (SummaryFull 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.
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GAO Reports on International Remittances

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 RequirementsHighlights Page (1 page), Full Report (59 pages), Accessible Version (62 pages).

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The 10 Most Important Issues – 2015 Edition – 10

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.

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The 10 Most Important Issues – 2015 Edition – 9

Hugo Cuevas-Mohr puts together every year the 10 Most important Issues for the industry. To download the PDF go to Download/IMTC Publications.

The rise of P2B, B2B, and Forex services in the industry is making the “Payments” side of the International Money Transfer & Payments Industry more dynamic and more important, overall, with new services, new entrants and new offerings. The P2P money transfer and remittance market has been historically closely linked to the Forex Market, although regulations in many countries, as well as currency controls due to AML compliance concerns, broke the bond and led to the demise of many Forex firms, most prominently, the “casas de cambio” in Latin America.

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