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

Compliance, De-Risking

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.

GAO Reports on International Remittances

10 Most, Compliance

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).

The 10 Most Important Issues – 2015 Edition – 10

10 Most

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.

The 10 Most Important Issues – 2015 Edition – 9

10 Most

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.

The 10 Most Important Issues – 2015 Edition – 8

10 Most

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 continued decline in the price of oil is affecting remittances worldwide, although the effects are varied, depending on the region of the world. But even if oil prices fell to their lowest levels in a decade, remittance outflows from the GCC were not heavily impacted during 2015. Remittances to Egypt, Jordan, and Yemen, with over 70% coming from the GCC, were not affected.

The 10 Most Important Issues – 2015 Edition – 7

10 Most

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

It was a good year for Mergers & Acquisitions (M&As) in the IMTC&P Industry, with the most notable news coming from the U.S: The July, 2015, $890M deal for the purchase of XOOM by PayPal. You can google hundreds of news articles on PayPal’s acquisition of Xoom or read the SEC merger report.

The 10 Most Important Issues – 2015 Edition – 6

10 Most

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 digital race heats up in the U.S. with the entrance of World Remit and TransferWise into the U.S. market, while Western Union opens up online channels in Europe. SaveOnSend articles, written by Alexey Artamonov and his multinational team, are probably one of the best sources to explore the rise of TransferWise and its initial strategy in Europe.

The 10 Most Important Issues – 2015 Edition – 5

10 Most

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

Digital IMT&Ps are continuing to increase their market share as investors and bankers favor online/mobile channels. At IMTC WORLD 2015’s M&A roundtables, the message was clear: Investors and bankers are favoring digital channels, overwhelmingly, and not only is the valuation of digital money transfer companies very high, but there is very small interest in the investment world for investing in traditional agent-based MTOs.

The 10 Most Important Issues – 2015 Edition – 4

10 Most

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

Mobile Money Services continue to expand across the developing world with new cross-border functionalities, systems integrations, partnerships, and regulatory advances for the industry. Domestic use of mobile transfer services spreads. The Global Mobile Systems Association (GMSA) reports that mobile money industry continues to expand globally, with more than 250 live mobile money services in nearly 90 countries.

The 10 Most Important Issues – 2015 Edition – 3

10 Most

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

Price to the public of industry services have been fairly stable during the year. MTOs interviewed have seen a slight upward trend even though they state that competition in every channel is fierce, more so in the exchange spread than in the fees. According to Remittance Prices Worldwide (RPW), the global average cost of sending remittances (including all fees and charges) remained basically the same in 2015 with a slight downward trend. RPW reports that the global average was 7.72% in 1Q, 7.68% in 2Q,  7.52% in 3Q and 7.37% in 4Q – a change of – 0.35% for the year).

The 10 Most Important Issues – 2015 Edition – 2

10 Most

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

Bank discontinuance and de-risking of MSBs/MTOs/money transmitters is still a major global problem industry-wide, but we think there has been a slight shift in the discussion with reports, regulations, and statements being published that gives us a sense of the issue moving forward; the small positive steps might seem irrelevant to a number of companies caught with limited or no banking relationships.

The 10 Most Important Issues – 2015 Edition – 1

10 Most

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

Although the volume of International Money Transfer & Payments (IMT&Ps) continues to increase, the percentage increase YTY has slowed down. According to the World Bank and Knomad, in their latest Brief #25, the growth rate of remittances to developing countries is projected to fall from 3.3% in 2014 to 2% in 2015 (down from 7% in 2010-2013). The slower growth rate is not uniform at all since the sharp decrease in remittances from Russia and slower growth in the Middle East significantly affected the global average.