Solutions from RiskSkill
E-Money Risk, Fraud & Compliance Solutions
About Riskskill's e-Money Compliance Services.
Riskskill helps businesses to find, identify and then avoid €$£multi-million in fines, but also to stop unwarranted brand damaging mistakes that arise from non-compliance fines or regulator challenges or orders. We also help businesses when things are much more advanced, such as when the regulator, schemes or other bodies have already taken action, levied the fines or imposed other restrictions.
E-money Licence Changes:
Financial services legislation in the UK, led to the Financial Conduct Authority (FCA) introducing a Payments Systems Regulator (with teeth) from April 2015. The European Central Bank (ECB), and the European Commission have also proposed regulation to govern the way in which the e-money industry operates, but so too have the card schemes (i.e. Visa and MasterCard). E-money licences issued by the FCA are also being reviewed for observance with ALL regulations and also best-practices.
We can see that the FCA have worked out that the payment systems, including e-money issuers, need greater governance that includes finding ways to continuously supervise and maintain its oversight in the same way that other payment systems and schemes already are governed (e.g. in particular those for the international card schemes).
If you are an e-money licence holder, your organisation as well as all of your agents, are obliged to be fully aware of and engaged in full due diligence in your customer selection and identification processes, in your transaction/event screening, suspicion reporting, record-keeping, corporate assessment of exposures and risk, and the Base II (and III) capital adequacy requirements to measure and manage the risks and exposures. It is essential as an FCA regulated organisation (and especially as a non-regulated member of the community), that in all your areas of operation that you have a clear payment strategy and a strong understanding and observance of all laws that apply to you for making payments.
The Money Laundering regulations for you country and meeting the requirements of the EU Money Laundering Directive is of course one of the greatest priorities today if you hold an e0money licence, but the requirements upon you and all your ‘Passport Holders’ are now significant and need to be managed carefully. We all know of those organisations that have failed overnight - often because of the controls that were (not) in place.
Not following the basic requirements of your e-money licence or the European Money Laundering directive must be the quickest way of exposing your business to losses, but also to being fined, suffering poor media attention, or losing your market-share. Ultimately the loss of your e-money licence and/or your business can really happen and will happen more as this market evolves.
You need to do several things before the FCA performs its own audits upon you and starts to validate individual license holders (especially as its plans will be to ‘make examples’ of those who are not acting appropriately):
A. Ensure that your process, operation and importantly, your compliance team follows all regulatory requirements, laws and best practices that apply to your business.
B. That you have the confidence that all your agents / Passport Holders are equally compliant and observant of the requirements as you are responsible for their actions too. The 'buck' does stop with you.
Riskskill can and will help you in:
Reviewing your current state of readiness, and will show you the areas that need attention or action prior to an FCA or other regulator (in your areas of operation) review of your business.
Assessing how ready and prepared your third party agents and Passport-holders are and how compliant and knowledgeable they are too; and then tell you what needs to be done by them and you as the principal licence holder.
We have a team of payment industry specialists, and will show you what has worked elsewhere in many banks and card schemes, as we have helped many organisations to review and evaluate their status, and then either become compliant or remain compliant.
Our team works extensively with the rules, regulations, legislation and best practice across the payments industry and across Europe. We advise payment organisations on market direction and strategy and direction - and we never operate as simple 'tick-box' auditors.
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