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Meeting the compliance challenge

Meeting the compliance challenge. Regulatory hot topics – how can PI’s/MSB’s comply (and still stay in business) ?. UKMTA Conference roundtable, 25 th February 2010. Question 1. How can Payment Institutions prepare themselves to respond to a request for information from the FSA? That is:

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Meeting the compliance challenge

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  1. Meeting the compliance challenge Regulatory hot topics – how can PI’s/MSB’s comply (and still stay in business) ? UKMTA Conference roundtable, 25th February 2010

  2. Question 1 • How can Payment Institutions prepare themselves to respond to a request for information from the FSA? That is: • A written request • An FSA interview • An FSA visit/inspection • What are the likely lines of enquiry going to be? • How should firms respond?

  3. Question 2 • In terms of the broader business environment, what are the likely issues which are going to impact on Payment Institutions in the next 12 months? In particular, how will possible governmental, legislative and regulatory changes impact the sector?

  4. Question 3 • How should money transmitters respond to the following which appeared on the HMRC MLR website on 15th February? Specifically, should they treat this as guidance from HMRC, guidance from HMT or from neither?: Impact of Supreme Court ruling on sanctions orders HM Treasury has obtained a delay in the implementation of a recent Supreme Court judgement relating to freezing assets of terrorists and other groups. Money Service Businesses should continue to monitor the financial sanctions lists as usual. For updates log onto the Treasury’s Financial sanctions page (Opens new window). Read about the judgement (PDF 115K) (Opens new window)

  5. Question 4 • We are a money transfer company which makes remittance payments to India via a local PSP. However, the local PSP requests that we make settlement by means of an invoice payable to an account in Dubai? In terms of reporting to the FSA, how do we report both the remittances paid out in India and also the settlement invoice? What may this mean in terms of our monthly turnover and how is it likely to effect how we must be regulated by FSA (as either SPI or API)?

  6. We are a small Payments Institution (that is transacting less than 3 million Euros on average per month) – what policies and procedures should we put in place to ensure that we are compliant with the law? If we are voluntarily ‘safeguarding’ client funds what do we need to do? Will the policies/procedures we put in place differ according to our status (either as transitioning PI or already FSA registered PI)? Question 5

  7. Question 6 We are a wholesaler MSB – our customers are other MSB’s (who we describe as ‘arms length agents’). When dealing with these customers, what processes should we put in place to ensure that we are compliant with regulatory requirements? (PSR’s, financial crime, etc)

  8. Question 7 Most MSBs or PIs use reputable banks for online payments. When payments are delayed, say for compliance reasons asking more info on a payment, who is responsible if payment exceeds the value date/time given to the client: the bank or the MSB?

  9. We are wanting to use electronic verification sources as a basis for CDD on our non face to face customers. Will this be sufficient on its own to meet regulatory requirements, or are other measures needed? Question 8

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