Global Payments Newsletter, January 2022

Hogan Lovells
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Key developments of interest over the last month include:

  • Hong Kong: HKMA issues Discussion Paper on crypto and stablecoins
  • Ireland: Central Bank publishes "Dear CEO" letter on supervisory expectations for payment and e-money firms
  • United Kingdom: Payment Systems Regulator publishes its final five-year Strategy

In this Newsletter:

For previous editions of the Global Payments Newsletter, please visit our Financial Services practice page.

Regulatory Developments

Hong Kong: HKMA issues Discussion Paper on crypto and stablecoins

On 12 January 2022, the Hong Kong Monetary Authority (HKMA) issued a Discussion Paper on Crypto-assets and Stablecoins. The Discussion Paper includes some principles for a potential regulatory regime for payment-related stablecoins.

The Payment Systems and Stored Value Facilities Ordinance (PSSVFO) created a licensing regime for stored value facilities such as pre-paid cards and e-wallets. However, in practice, many types of stablecoins do not fall under the definition of "stored value facility". For example, where there is no undertaking by the issuer to use the stablecoin as a means of payment to third parties, such a stablecoin will not be regulated under the PSSVFO, even if it operates in a manner similar to that of a regulated "stored value facility". Recognising the growing adoption and rapid evolvement of cryptoassets and the gaps in existing regulations, the HKMA proposes in the Discussion Paper to introduce a new regulatory framework for payment-related stablecoins which are asset-linked, for example those which are pegged to fiat currencies (e.g. USD), commodities (e.g. gold) or other financial assets, as opposed to algorithm-based stablecoins, for example those which maintain value via protocols that provide for changes in the supply of stablecoins in response to changes in demand.

According to the Discussion Paper, under the new regime certain activities relating to payment-related stablecoins (such as the issuance of coins, management of reserve assets, redemption of coins and execution of transactions) will be regarded as regulated activities, and any person who carries out such activities or actively markets to the public of Hong Kong such activities will be required to be licensed by the HKMA. In order to be licensed, such persons must satisfy certain requirements, such as maintaining adequate financial resources, having controllers and directors that are fit and proper, and ensuring the stabilisation mechanism is effective and reliable.

The consultation invites stakeholders to provide feedback on the direction and scope of the new regime by 31 March 2022. The HKMA aims to introduce the new regulatory regime no later than 2023/24.

For more on this development, take a look at this Engage article by members of Hogan Lovells’ Hong Kong office.

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Ireland: Central Bank publishes "Dear CEO" letter on supervisory expectations for payment and e-money firms

On 9 December 2021, the Central Bank of Ireland published a "Dear CEO" letter setting out its supervisory expectations for payment and e-money firms.

In the letter, the Central Bank highlights seven areas of priority in relation to the supervision of these types of firm:

  1. Governance and Risk Management;
  2. Conduct and Culture;
  3. Safeguarding;
  4. Business Model and Financial Resilience;
  5. Operational Resilience;
  6. Financial Crime; and
  7. Resolution and Wind-Up.

With due regard to the contents of the letter, the Central Bank expects firms to undertake a comprehensive assessment of their compliance with (i) safeguarding obligations under Regulation 17 of the Payment Services Regulations 2018 and Regulations 29-31 of the Electronic Money Regulations 2011 and (ii) the conditions of their authorisation. A Board approved attestation confirming the completion and conclusion of this assessment must be provided to the Central Bank by 31 March 2022.

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United Kingdom: Payment Systems Regulator publishes its final five-year Strategy

On 13 January 2022, the Payment Systems Regulator (PSR) published the final version of its Strategy for the next five years, together with a press release and a summary version of the Strategy.

The Strategy sets out the PSR’s four strategic outcomes and details of the strategic priorities that are intended to enable it to achieve each of these outcomes. Its strategic outcomes are:

  1. Access to payment systems that meet everyone's needs.
  2. Protection for people and businesses making payments.
  3. Effective competition in payment services.
  4. Efficient and commercially sustainable payment systems.

The priorities linked to these outcomes are to:

  • Ensure users have continued access to the payment services they rely on, and support a choice of payment options.
  • Ensure users are sufficiently protected when using the UK's payment systems.
  • Promote competition between UK payment systems and the markets supported by them, protecting users where that competition is not sufficient.
  • Act to ensure the interbank systems provide the infrastructure, rules and incentives that foster innovation and competition in payments.

The PSR has also published its response (RP22/1) to its June 2021 consultation (CP21/7) on a draft version of the Strategy. The response highlights some key changes to its proposed Strategy:

  • Clarification that the PSR may need to act to protect users before the impact of effective competition has had time to take effect.
  • Revision of its fourth strategic priority to reflect the PSR's view that there is currently no single body that can apply common conduct or liability standards across all Faster Payments users.
  • Clarifications on how the PSR intends to measure whether it is achieving its Strategy.

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Ireland: Central Bank publishes final cross-industry guidance on operational resilience

On 1 December 2021, the Central Bank of Ireland published its final Cross-Industry Guidance on Operational Resilience, following its consultation paper (CP140) from April 2021.

The Guidance has immediate effect from 1 December 2021.

A feedback statement accompanies the Guidance with explanatory commentary and some insight into industry views.

Changes from the draft guidance published as part of CP140 are relatively minimal, with firms expected to be actively and promptly addressing operational resilience vulnerabilities and be in a position to evidence actions/plans to apply the Guidance at the latest within two years of its being issued.

The Central Bank states that the purpose of the Guidance is to:

  • Communicate to the boards and senior management of Regulated Financial Service Providers (RFSPs) the Central Bank’s expectations with respect to the design and management of operational resilience;
  • Emphasise board and senior management responsibilities when considering operational resilience as part of their risk management and investment decisions; and
  • Require that the boards and senior management take appropriate action to ensure that their operational resilience frameworks are well designed, are operating effectively, and are sufficiently robust. This should ensure that the risks to the firm’s operational continuity do not transmit into the financial markets and that the interests of the customers and market participants are safeguarded during business disruptions.

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Ireland: Central Bank publishes final cross-industry guidance on outsourcing

On 17 December 2021, the Central Bank of Ireland published its final Cross-Industry Guidance on Outsourcing, following its consultation paper (CP138) from February 2021.

The Guidance has immediate effect from 17 December 2021.

A feedback statement accompanies the Guidance with explanatory commentary and some insight into industry views.

Changes include annual uploads of firms’ outsourcing registers (starting Q2 2022) and templates for formal notification of critical or important outsourcing arrangements.

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Indonesia: New payment system launched

On 21 December 2021, Bank Indonesia announced the launch of the Bank Indonesia Fast Payment (BI-FAST) system. The BI-FAST system is intended to create a more efficient retail payment system infrastructure that provides fast, affordable, secure and reliable economic and financial transactions, while also strengthening the national payment system industry and helping to build an integrated, interoperable and interconnected digital economy that fosters innovation. The new system will be available 24/7.

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Hong Kong: Amendments to the HKAB Code of Banking Practice

The Hong Kong Association of Banks and the DTC Association have published their revised Code of Banking Practice. The amendments took effect on 10 December 2021 and require Hong Kong banks to take steps to revise terms and conditions, customer journeys and other operating practices in order to meet the new requirements.

The Code is a non-statutory code jointly issued by HKAB and the DTCA, and endorsed by the Hong Kong Monetary Authority (HKMA). The Code provides general principles covering the overall relationship between authorised institutions and their customers in Hong Kong, as well as recommendations on specific aspects of banking practices. The Code was introduced in 1997 and has undergone a number of major amendments to bring it in line with new international standards. This most recent set of revisions of the Code are the first since 2015.

The revisions focus on updating the Code to better reflect the increasing digitalisation of banking in Hong Kong. The amendments expand the Code’s coverage to better address internet banking, contactless mobile payments, the use of self-service terminals and telephone banking services. At the same time, a number of the amendments reflect a move to ensure that traditional banking customers more comfortable with in-branch banking and paper-based services are not left without means of receiving an appropriate level of service.

Authorised institutions are expected to fully comply with the new Code as soon as practicable and should achieve full compliance within six months of the effective date, with extensions of 12 to 18 months for certain provisions.

For more on this development, take a look at this Engage article by members of Hogan Lovells’ Hong Kong office.

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European Union: EPC provides SEPA "Brexit reminder" to scheme participants

On 21 December 2021, the European Payments Council (EPC) issued a "Brexit reminder" press release. The reminder highlighted that SEPA transactions executed or settled after 1 January 2021 involving a UK-based SEPA payment scheme participant must contain:

  • The full address details of the Originator for SEPA Credit Transfer and SEPA Instant Credit Transfer transactions; and
  • The full address details of the Debtor for SEPA Direct Debit Core and SEPA Direct Debit B2B collections.

The press release explains that the EPC has been notified that some SEPA payment scheme participants are not complying with these information requirements, which are required by the EU Funds Transfer Regulation (2015/847). The EPC therefore urges all SEPA payment scheme participants to ensure compliance as soon as possible.

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United Kingdom: PSR publishes response paper on lowering risks to NPA delivery

On 14 December 2021, the Payment Systems Regulator (PSR) published a response paper setting out the final changes to its Specific Directions 2 and 3. The revised directions follow the PSR's consultation (CP21/8) earlier in 2021 on proposed changes to lower the risks to successful delivery of the New Payments Architecture (NPA). In particular, the PSR has:

  • Changed the Specific Direction 2 reporting requirements so that Pay.UK must submit a plan for developing the Bacs strategy to the PSR by 31 March 2023 and then submit subsequent reports on progress within nine months of the previous report;
  • Moved the Specific Direction 3 compliance deadline to 1 July 2026 (rather than 1 April as originally proposed) to provide for some additional contingency given there is less certainty about the baseline plan upon which the deadline is based; and
  • Reinstated provisions in Specific Directions 2 and 3 that allow the PSR to amend the compliance deadlines for those directions, recognising that with a programme of the size and scale of the NPA factors outside of Pay.UK's direct control could arise that mean it is unable to meet these deadlines.

The changes implemented as a result of the new Specific Directions 2 and 3 came into force on 1 January 2022.

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European Union: EPC updates 2021 SEPA scheme rules

On 13 December 2021, the European Payments Council (EPC) published updated versions of a number of SEPA scheme rulebooks and payment system management rules. The updates affect the following:

  • 2021 SEPA Direct Debit Core Scheme Rulebook. The new version includes an updated version of the SEPA Payment Scheme Management Rules. These rules now reflect the disbandment of the Scheme End-User Forum and the EPC Scheme Technical Forum, and the creation of the Scheme End-User Multi-Stakeholder Group and of the Scheme Technical Player Multi-Stakeholder Group at the start of 2022. This new version entered into force on 11 January 2022 and remains in effect up to and including 18 November 2023.
  • 2021 SEPA Direct Debit Business-To-Business Scheme Rulebook. The new version includes an updated version of the SEPA Payment Scheme Management Rules. These rules now reflect the disbandment of the Scheme End-User Forum and the EPC Scheme Technical Forum, and the creation of the Scheme End-User Multi-Stakeholder Group and of the Scheme Technical Player Multi-Stakeholder Group at the start of 2022. This new version entered into force on 11 January 2022 and remains in effect up to and including 18 November 2023.
  • 2021 SEPA Instant Credit Transfer (SCT Inst) Scheme Rulebook. The new version includes an updated version of the SEPA Payment Scheme Management Rules. These rules now reflect the disbandment of the Scheme End-User Forum and the EPC Scheme Technical Forum, and the creation of the Scheme End-User Multi-Stakeholder Group and of the Scheme Technical Player Multi-Stakeholder Group at the start of 2022. This new version entered into force on 11 January 2022 and remains in effect up to 19 November 2023.
  • Maximum Amount for Instructions under the 2021 SCT Inst Scheme Rulebook. This sets the maximum amount per instruction that can be processed under the SCT Inst scheme based on the 2021 SCT Inst rulebook. This document also gives the EPC the possibility to adapt the maximum amount per instruction under the SCT Inst scheme outside the regular payment scheme rulebook release management cycle as defined in the Payment Scheme Management Rules of the rulebook. This new version is effective as of 11 January 2022 up to 19 November 2023.
  • 2021 SEPA Credit Transfer Scheme rulebook. The new version includes an updated version of the SEPA Payment Scheme Management Rules. These rules now reflect the disbandment of the Scheme End-User Forum and the EPC Scheme Technical Forum, and the creation of the Scheme End-User Multi-Stakeholder Group and of the Scheme Technical Player Multi-Stakeholder Group at the start of 2022. This new rulebook entered into force on 11 January 2022 and remains in effect up to and including 18 November 2023.
  • SEPA Payment Scheme Management Rules. This version reflects the disbandment of the Scheme End-User Forum and the EPC Scheme Technical Forum, and the creation of the Scheme End-User Multi-Stakeholder Group and of the Scheme Technical Player Multi-Stakeholder Group at the start of 2022. This new version entered into force as of 11 January 2022 and will remain in effect until further notice.

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Global: FSB publishes report on remittance corridor risk

On 13 December 2021, the Financial Stability Board (FSB) made available a September 2021 report proposing a draft framework and methodology for assessing risk in remittance corridors and identifying "safe remittance corridors".

The draft framework is the first action under Building Block 7 of the FSB's Roadmap for Enhancing Cross-Border Payments, which aims to promote "safe payment corridors". Building Block 7 has two phases:

  1. The development of a framework and methodology for assessing AML/CFT risk in remittance corridors and the identification of potential "lower risk corridors".
  2. The proposed framework is then expected to be piloted in some corridors with a view to testing and further refining the assessment methodology.

The report reaches a number of conclusions, including that:

  • Based on the Corridor Risk Assessment conclusions, certain remittance activities can be insulated and designated as a "safe remittance corridor".
  • Establishing the lower risk nature of the remittance corridor would allow a prioritisation of risk mitigation measures employed by remittance service providers, their banks, and correspondent banks.
  • For safe, lower risk remittance corridors, the customer due diligence requirements can be simplified in a risk-based manner.

The Corridor Risk Assessment conclusions may also be used to exempt remittance service providers from some AML/CFT requirements.

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India: RBI releases framework for offline digital payments

On 3 January 2022, the Reserve Bank of India (RBI) published its framework for facilitating small value digital payments in offline mode, which will allow for payment transactions which do not require internet or telecom connectivity.

Under the new framework, payments can be conducted face-to-face using cards, wallets, mobile devices and other methods. These transactions will not require an Additional Factor of Authentication. Alerts (by SMS and/or e-mail) will be received by the customer after a time lag. Transactions are subject to a limit of 200 rupees per transaction and an overall limit of 2,000 rupees for all transactions.

Customer consent is required to enable the offline payment method. Customers will also have protection under the Reserve Bank circulars limiting customer liability, and recourse to the Reserve Bank's Integrated Ombudsman Scheme.

Offline transactions are expected to boost digital transactions in areas with poor internet or telecom connectivity.

The new framework is applicable with immediate effect, and incorporates comments received from pilots conducted in 2020 and 2021.

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The Bahamas: Central Bank consults on cheque elimination

On 28 December 2021, the Central Bank of the Bahamas announced that it is beginning a consultation on its strategy to eliminate the use of cheques in the Bahamas, with a view to fully eliminating the domestic use of cheques by 2024.

The press release explains that the policy has been developed in light of the increased redundancy of cheques in modern economies, and notes that other countries are adopting similar policies. The press release also confirms that the elimination strategy will proactively address financial inclusion and promote legitimate access to alternatives for both individuals and businesses. This will include adequate public education around the use of digital alternatives.

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Sri Lanka: Central Bank extends incentives for inward remittances

As reported in the December 2021 Global Payments Newsletter, on 1 December 2021, it was announced that the Central Bank of Sri Lanka would be paying an incentive of 8 Sri Lankan Rupees per US dollar for workers' remittances, in addition to the existing incentive of 2 Sri Lankan Rupees under the "Incentive Scheme on Inward Workers' Remittances".

The incentive scheme was initially set to last until 31 December 2021, but the Central Bank of Sri Lanka announced on 24 December 2021 that it will be extended to 31 January 2022.

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Global: BIS publishes report on interoperability between payment systems across borders

On 10 December 2021, the Bank for International Settlements (BIS) published a report on the interoperability between payment systems across borders. The report starts by noting that cross-border interoperability is needed to make cross-border payments faster, cheaper and more accessible. The report goes on to note that global coordination is needed in order to promote interoperability. For example, while the ISO 20022 system promotes interoperability, domestic implementation of the new system varies across jurisdictions.

The report then sets out four potential interoperable cross-border payment systems, and discusses some of the advantages and disadvantages of each:

  1. Single access point. Participants in one (domestic) system have access to a foreign system through a single "gateway" entity (for example, a payment service provider (PSP)) that operates in both systems. Despite simplicity and low cost, the single access point has scalability limitations.
  2. Bilateral link. Participants in one system can directly reach all participants in a foreign system. Transactions between linked systems are typically settled through accounts that PSPs in each system hold with their counterparts in the other system. In this setup, both systems must address the three interoperability attributes. For example, if the AML/CFT rules and procedures of the linked systems are misaligned, one (or both) systems must either change its rules or find a technical solution. Establishing a bilateral link can be relatively cost-effective and serve as an interim step towards a more centralised approach. However, a large number of bilateral links results in complex processes, as multiple interoperability arrangements must be maintained.
  3. Hub and spoke (or multilateral link). Using a common settlement agent (the hub), participants in one system can directly reach all participants in two or more foreign systems (the spokes). The intersystem accounting, clearing and settlement are carried out by the common settlement agent (the hub) with which participants in each system hold their settlement account. The attributes relevant for interoperability in this model are the same as for bilateral links, except for the added complexity of applying to three or more jurisdictions, including defining standardised and harmonised structures. In this model, a hub would need to be set up from scratch, with the costs varying according to the functions offered.
  4. Common platform. Participants from one jurisdiction can directly reach participants in other jurisdictions through one common payment system, which runs on a single, integrated technical platform. As a common platform requires the harmonisation of many attributes, it is technically the most complex model, since it does not interlink existing systems but requires a new fully fledged payment system to be set up. The only interoperability issue concerns the participants who need to establish a link to the new central entity. This model is the costliest up-front because of the initial investment, as well as the need to ensure operational resilience and to address the "single point of failure" risk. At the same time, it offers extensive scalability options and the greatest long-run efficiency.

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United Kingdom: FCA publishes Handbook Notice 94

On 17 December 2021, the FCA published Handbook Notice 94, setting out the changes made to the FCA Handbook on 25 November 2021 and 16 December 2021. In particular, the Notice highlights changes to the following two instruments:

  1. Perimeter Guidance (Payment Services) Instrument 2021 (FCA 2021/44).
  2. Technical Standards on Strong Customer Authentication and Common and Secure Methods of Communication (Amendment) (No 2) Instrument 2021 (FCA 2021/45).

Following publication of FCA policy statement PS21/19, the instruments amend the FCA's technical standards on strong customer authentication and common and secure methods of communication, as well as guidance in the FCA's payment services and electronic money approach document and in PERG.

FCA 2021/44 came into force on 30 November 2021. The provisions of FCA 2021/45 come into force on 30 November 2021, 26 March 2022 and 26 May 2023.

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Jamaica: Bank of Jamaica completes CBDC pilot

On 31 December 2021, the Bank of Jamaica announced that it had completed a Central Bank Digital Currency (CBDC) pilot.

The press release explains that in early 2021, the Bank of Jamaica tested a prototype central bank digital currency with vendor eCurrency Mint Inc in Bank of Jamaica's Fintech Regulatory Sandbox. This was followed by an 8-month pilot, which ended on 31 December 2021. A number of activities were targeted and completed during the pilot:

  • CBDC minting;
  • CBDC was issued to wallet providers; and
  • CBDC was distributed to retail customers.

Following the pilot, the national roll-out of the CBDC is scheduled for Q1 2022.

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India: RBI hints at introduction of CBDC

On 28 December 2021, the Reserve Bank of India (RBI) published a report in which it outlines the benefits of India introducing a Central Bank Digital Currency (CBDC). While acknowledging that there are questions which need to be addressed before its introduction, the RBI notes that CBDC provides a safe, robust, and convenient alternative to physical cash, and can offer benefits to users in terms of liquidity, scalability, acceptance, anonymity and faster settlement.

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United Kingdom: House of Lords Economic Affairs Committee publishes report on CBDCs

On 13 January 2022, the House of Lords Economic Affairs Committee published a report on the potential introduction of a UK retail central bank digital currency (CBDC).

The Bank of England (BoE) and HM Treasury (HMT) established a CBDC Taskforce in April 2021 and announced in November 2021 that they would consult in 2022 on their assessment of the case for a UK CBDC (as mentioned in the November 2021 Global Payments Newsletter).

Among other things, the Committee’s report concludes that it has not yet heard a convincing case for why the UK needs a retail CBDC. It highlights significant challenges arising for financial stability, particularly in respect of cyber-security, and the protection of privacy, as well as the work needed to find workable solutions to the design trade-offs that may make a CBDC unattractive.

The report also sets out questions that it considers the Taskforce should address in its assessment work and calls on HMT and the BoE to work with international partners on principles and standards for CBDCs and to learn lessons on technical design and usage from the experiences of countries that opt for an early introduction of a CBDC.

The Committee recommends that the Taskforce consults on whether a wholesale CBDC would have any material advantages over the continued development and widened membership of the real-time gross settlement (RTGS) system alongside its consultation on the retail CBDC.

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Estonia: Government has no plans to ban crypto

On 23 December 2021, the Estonian government approved draft legislation regulating virtual asset service providers (VASPs). In a press release issued on 2 January 2022, the Estonian Ministry of Finance clarified that the new legislation will not prevent customers from owning or trading crypto. However, the planned rules for VASPs (such as capital requirements) could apply to decentralised wallet creators.

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Iran: Government orders crypto-mining ban to save power

On 28 December 2021, it was reported that the Iranian government had closed crypto-mining centres until 6 March 2022 in order to ease winter energy shortages. It is the second time in 2021 that such a ban has been imposed. A ban was imposed earlier in 2021 following blackouts across major Iranian cities, which were blamed on a surge in crypto-mining activity.

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Turkey: President to send crypto law to parliament

On 24 December 2021, it was reported that Turkey's president Erdogan was planning to send a crypto law to Turkey's parliament. It comes as cryptocurrency has gained popularity in Turkey due to the country's high rate of inflation. The precise content of the new law is not yet clear.

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Russia: Bank of Russia seeks to ban crypto

On 23 December 2021, it was reported that the Bank of Russia is planning to ban digital currencies. In a recent press conference, the Bank's governor said that "cryptocurrencies are opaque in that they are frequently used for illegal operations or criminal nature. Therefore, we cannot welcome investments in them" and that the Bank is seeking "to prevent the Russian financial infrastructure from using crypto transactions".

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Bahrain: Central Bank trials JPM Coin digital currency

On 5 January 2022, the Central Bank of Bahrain announced that it had successfully completed a test of the JPM Coin System. The JPM Coin System allows instant cross-border settlement between J.P. Morgan's wholesale business clients. Commenting on the test, the Central Bank's Deputy CEO commented that he hoped to expand this technology to currencies other than USD in future.

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United Kingdom: Bank of England Financial Stability Report and FPC summary and record published

On 13 December 2021, the Bank of England (BoE) published the Financial Stability Report for December 2021 and the financial policy summary and record of the meetings of its Financial Policy Committee (FPC) held on 29 November and 9 December 2021.

In the documents, the FPC sets out its view of the outlook for UK financial stability and issues relating to the resilience of the financial system. Regarding the risks from cryptoassets, the FPC noted that:

  • Direct risks to the stability of the UK financial system from cryptoassets are currently limited. However, at the current rapid pace of growth, and as they become more interconnected with the wider financial system, cryptoassets will present a number of financial stability risks.
  • Enhanced domestic and global regulatory and law enforcement frameworks are necessary to influence developments in these fast-growing markets to manage risks, encourage sustainable innovation and maintain broader trust and integrity in the financial system. The FPC welcomes international work on these issues.
  • In the UK, the FPC supports the work of HM Treasury, the FCA and the BoE Cryptoassets Taskforce on assessing the regulatory approach to unbacked cryptoassets and their associated markets and activities, to shape developments in this area and support safe innovation. It also welcomes HM Treasury's proposal for a regulatory regime for stablecoins, including bringing systemic stablecoins into the BoE's regulatory remit.
  • The FPC will continue to pay close attention to developments in this area and will aim to ensure that the UK financial system is resilient to systemic risks that may arise from cryptoassets. Any future regulatory regime should aim to balance risk mitigation with supporting innovation and competition. The FPC considers that financial institutions should take an especially cautious and prudent approach to any adoption of these assets until such a regime is in place.

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United Kingdom: Bank of England warns of crypto risk

On 14 December 2021, it was reported that the Bank of England's deputy governor, Jon Cuncliffe, had told the BBC's Today programme that fast-growing crypto-currencies pose a danger to the financial system.

The deputy governor warned that, while only a small portion of UK household wealth is held in crypto-currencies, this number is rising and a fall in their value could have knock-on effects. He warned that if cryptocurrencies become integrated into the financial system, then a big price correction in their value could have a large effect on the market, and therefore that now is the time to properly regulate crypto.

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European Union: ESMA launches call for evidence on DLT pilot regime

On 4 January 2022, ESMA published a call for evidence on the DLT pilot regime and review of MiFIR regulatory technical standards on transparency and reporting.

The call for evidence explains that the Regulation on a pilot regime for market infrastructures based on distributed ledger technology (DLT) aims at developing the trading and settlement for 'tokenised' securities. The DLT pilot requires ESMA to assess whether the regulatory technical standards developed under MiFIR relating to certain transparency and data reporting requirements need to be amended in order to be effectively applied also to securities issued, traded and recorded on DLT.

The call for evidence comes following the release on 21 December 2021 by the European Commission of a "I" item note (11055/20 ADD 1-2), accompanied by the final compromise text of the proposed Regulation on a pilot regime for market infrastructures based on distributed ledger technology.

Stakeholders are invited to provide comments by 4 March 2022 and based on the feedback received, ESMA will consider whether amendments to the regulatory technical standards are necessary. If amendments are necessary, ESMA will consult on its proposal in a consultation paper before submitting the final draft regulatory technical standards to the European Commission for adoption.

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United Kingdom: JMLSG publishes revisions to monitoring customer activity guidance

On 20 December 2021, the Joint Money Laundering Steering Group published revisions to Part I Chapter 5.7 of its Guidance, which contains provisions relating to the monitoring of customer activities. Changes to the guidance include:

  • Requiring firms to establish an appropriate governance mechanism for the oversight, review and approval of monitoring processes and parameters, which will include documenting their monitoring arrangements and rationale.
  • Noting that firms which outsource monitoring processes remain responsible for their regulatory obligations.
  • Requiring firms which undertake manual monitoring to have procedures to manage the risk of manual error.
  • Adding to the list of examples of "transaction characteristics" which should be looked at as part of an effective monitoring process. Additions to the list include known threats and typologies, and networks of connected accounts.

In an accompanying press release, the JMLSG confirms that it has submitted the revised guidance to HM Treasury for Ministerial approval.

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United Kingdom: OFSI announces change in format of UK sanctions list

On 13 December 2021, the Office of Financial Sanctions Implementation (OFSI) announced that the structure and the format of the UK sanctions list is changing from February 2022. Guidance has been published for businesses and industry that regularly use the UK sanctions list and the OFSI consolidated list to help them understand and prepare for the change. There will be no material updates to listings when the changes occur. Updates to the list will continue to be communicated separately.

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United Kingdom: Joint Committee reports on draft Online Safety Bill

On 14 December 2021, the House of Lord and House of Commons Joint Committee on the draft Online Safety Bill (OSB) published a report recommending major changes to the draft OSB, which was published in May 2021.

The current draft imposes a duty of care on companies in scope to prevent the proliferation of illegal content and activity online and protect users against content that is harmful, although not illegal. Companies have to put in place systems and processes to improve user safety. Ofcom will oversee compliance and be able to issue fines of £18 million or 10% of global annual turnover.

Online fraud is discussed at chapter 4 of the Joint Committee’s report. While welcoming the inclusion of fraud and scams in the draft OSB, the Joint Committee recommends:​

  • Prevention must be prioritised and this requires platform operators to be proactive in stopping fraudulent material from appearing in the first instance, not simply removing it when reported. Clause 41(4) of the OSB should be amended to add “a fraud offence” under terrorism and child sexual exploitation and abuse offences and related clauses should be similarly introduced or amended so that companies are required to proactively address it. The Government should consult with the regulatory authorities on the appropriate offences to designate under this section. The Government should ensure that this does not compromise existing consumer protection regulation. ​
  • The OSB must make clear that ultimate responsibility for taking action against criminal content remains with the relevant regulators and enforcement bodies, with Ofcom reporting systemic issues relating to platform design and operation - including in response to “super complaints” from other regulators. The OSB should contain provisions requiring information-sharing and regulatory cooperation to facilitate this.

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United Kingdom: House of Lords Committee publishes follow-up report on effectiveness of digital regulation

On 13 December 2021, the House of Lords Select Committee on Communications and Digital published the report on its inquiry into the work of digital regulators. Building on its March 2019 report "Regulating in a digital world", in September 2021 the Committee issued a call for evidence on several issues, including the effectiveness of the Digital Regulation Co-operation Forum (DRCF) and digital regulators' horizon scanning.

Among other things, the report found that:

  • Following the creation of the DRCF, regulatory horizon scanning has improved, but more still could be done to facilitate co-ordination and co-operation, both between and beyond regulators. The DRCF's current approach to co-operation between members should be formalised, with the introduction of statutory measures such as new duties to consult and the creation of statutory information sharing mechanisms to facilitate joint work between regulators. The report also makes recommendations on expanding the DCRF's membership and strengthening its links with industry and academia.
  • To enhance the DRCF's effectiveness and accountability in the long term, the DRCF (to be renamed the Digital Regulation Board) should be placed on a statutory footing, with the power to resolve conflicts by directing its members. Also, statutory duties should be placed on regulators in the DRCF to co-operate and consult with each other, allowing them to share their powers and jointly regulate.
  • A joint committee of both Houses of Parliament should be established to oversee digital regulation.

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European Union: EBA publishes final report on AML/CFT central database

On 20 December 2021, the EBA published a final report on the regulatory technical standards setting up an AML/CFT central database.

The database is being established pursuant to Article 9a of the EBA Regulation (1093/2010), which gives the EBA a mandate to establish and keep up-to-date a central AML/CFT database.

The central AML/CFT database will contain information on material AML/CFT weaknesses in financial sector operators that competent authorities have identified. It will also contain information on the measures competent authorities have taken in response to those material weaknesses. The draft regulatory technical standards in this report specify when weaknesses are material, the type of information competent authorities have to report, how information will be collected and how the EBA will analyse and disseminate the information contained in the database. They also set out the rules necessary to ensure confidentiality, the protection of personal data and the effectiveness of the database.

The EBA will now submit the draft regulatory technical standards to the European Commission for approval and once approved, the regulatory technical standards will apply in all member states.

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European Union: EBA consults on remote customer onboarding under MLD4

On 10 December 2021, the EBA published a consultation paper on the use of remote customer onboarding solutions under Article 13(1) of Directive 2015/849 (MLD4).

The consultation has been published because the European Commission believes that the customer due diligence rules in MLD4 are not sufficiently clear on what is allowed in a remote context. As a result of this, there is significant regulatory divergence on this point across member states, which the Commission views as a hindrance to the cross-border provision of financial services.

The draft guidelines therefore set common EU standards on the development and implementation of sound, risk-sensitive initial customer due diligence processes in a remote context. They set out the steps financial sector operators should follow when choosing remote customer onboarding tools and what financial sector operators should do to satisfy themselves that the chosen tool is adequate and reliable.

The deadline for comments on the draft guidelines is 10 March 2022.

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European Union: EBA issues final reports on risk-based approach to AML/CFT supervision and co-operation and information exchange between prudential supervisors, AML and CFT supervisors and FIUs

On 16 December 2021, the EBA published guidelines on the characteristics of a risk-based approach to AML/CFT supervision, and the steps to be taken when conducting supervision on a risk-sensitive basis.

Article 48(10) of Directive 2015/849 (MLD4) requires the EBA to issue guidelines to competent authorities on the characteristics of a risk-based approach to AML/CFT supervision. The first version of these guidelines was published in 2016. Since then, concerns have been raised about the adequacy of some competent authorities' approach to AML/CFT supervision, which is the reason behind the EBA's decision to amend the guidelines.

The proposed amendments address key challenges for supervisors when implementing the risk-based approach. They also take into consideration changes to the EU legal framework that have come into force since the guidelines were first issued, as well as new international guidance from the Financial Action Task Force and the Basel Committee on Banking Supervision on this topic. In summary, the revised guidelines:

  • Emphasise the need for a comprehensive risk assessment to support competent authorities' identification of risk areas that require higher levels of supervisory attention;
  • Explain different supervisory tools available to competent authorities and provide guidance on selecting the most effective tools;
  • Emphasise the importance of a robust follow-up process and offer guidance on selecting the most appropriate follow-up process;
  • Provide further guidance on the implementation of a robust supervisory strategy and plan, to ensure that the allocation of supervisory resources by competent authorities is as efficient as possible;
  • Clarify competent authorities' obligations as regards the AML/CFT supervision of groups and emphasise the need for competent authorities, that are responsible for the supervision of the group's head office, to develop a good understanding of AML/CFT risks to which the group is exposed;
  • Highlight the importance of cooperation among competent authorities and between competent authorities and other stakeholders; and
  • Provide further guidance on how competent authorities can determine the type of guidance needed within the sector and how to communicate this guidance in the most effective manner.

The guidelines will be translated into official EU languages and published on the EBA website, and the deadline for competent authorities to report whether they comply with the guidelines will be two months after the publication of these translations.

Also on 16 December 2021, the EBA published a final report containing guidelines on co-operation and information exchange between prudential supervisors, AML and CFT supervisors and financial intelligence units (FIUs) under the CRD IV Directive (2013/36/EU). The guidelines apply from 1 June 2022.

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European Union: European Commission adopts new Delegated Regulation amending list of high-risk third countries under MLD4

On 7 January 2022, the European Commission adopted a Delegated Regulation (C(2021) 4335 final) amending the list of high-risk third countries with strategic AML and CTF deficiencies produced under Article 9(2) of MLD4 ((EU) 2015/849). The Delegated Regulation will be submitted to the Council of the EU and the Parliament to consider for approval and, if neither objects, it will enter into force 20 days after it is published in the Official Journal of the European Union.

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European Union: EBA publishes report and opinion on de-risking

On 5 January 2022, the EBA published an opinion on de-risking (that is, the practice of not providing services to categories of customers associated with higher money laundering risk). Annexed to the opinion is a report on de-risking and its impact on access to financial services.

The EBA is concerned that unwarranted de-risking is taking place, and notes that de-risking of entire categories of customers without due consideration of individual customers' risk profiles can be unwarranted and a sign of ineffective AML/CFT risk management.

Following a consultation on the topic, the EBA found that de-risking can lead to adverse economic outcomes or amount to financial exclusion. In light of this, the EBA considers that, to address unwarranted de-risking and promote sound AML/CFT risk management, further action by competent authorities is required to support the effective implementation of provisions in existing EBA instruments and to ensure that unfair de-risking practices stop.

In particular, the EBA is encouraging competent authorities to:

  • Engage more actively with financial institutions that de-risk, and seek to raise awareness of the rights and responsibilities of both institutions and their customers.
  • Remind credit and financial institutions that, if this is warranted by the outcome of their assessment of AML/CFT risk associated with a customer, they can opt to offer only basic financial products and services in order to restrict the ability of users to abuse these products and services for financial crime purposes.

The EBA also proposes that the European Commission should clarify the relationship between provisions in the Payment Accounts Directive (2014/92/EU) (PAD), PSD2 ((EU) 2015/2366) and the EU's anti-money laundering and counter-terrorism financing (AML/CFT) frameworks. In particular, it should clarify the interaction between AML/CFT requirements and the right to open and use a payment account with basic features, potentially by including a mandate in the PAD for guidelines on this issue. According to the EBA, the Commission should also clarify the application of Article 36 of PSD2 in its forthcoming review of the Directive.

In addition, the EBA is advising the European Commission to take steps to reduce inappropriate de-risking.

The EBA will follow up with competent authorities on steps taken to tackle unwarranted de-risking to inform its next opinion on ML/TF risks under Article 6(5) of MLD4 ((EU) 2015/849), which is due to be issued in 2023.

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European Union: ECB publishes action plan to address IT outages

On 17 December 2021, the ECB published an action plan following five major IT incidents affecting the TARGET2 systems in 2020. The action plan consists of six workstreams:

  1. Change and release management;
  2. Business continuity management;
  3. Fail-over and recovery tests;
  4. Communication protocols;
  5. Governance; and
  6. Data centre and IT operations.

Certain recommendations were agreed or implemented in the course of 2021, and most of the remaining recommendations will be implemented by the end of 2022.

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European Union: EBA publishes final report on guidelines on delineation and reporting of available financial means of deposit guarantee schemes

On 17 December 2021, the EBA published a final report on guidelines on the delineation and reporting of available financial means (AFM) of deposit guarantee schemes (DGSs) under the Deposit Guarantee Schemes Directive (2014/49/EU) (DGSD).

The DGSD defines the term "AFM" as cash, deposits and low-risk assets that can be liquidated within seven working days, as well as payment commitments. Under Article 10(10) of the DGSD, member states are required to inform the EBA each year about the amount of their DGS' AFM.

The purpose of the guidelines is to clarify the criteria for delineating different subsets of available financial means, in particular the subset that counts towards reaching the target level. They seek to address the EBA's concerns that there were differences across member states concerning the interpretation of the concept of AFM.

The guidelines specify that AFM are comprised of two subsets:

  • Qualified AFM (QAFM): funds stemming directly or indirectly from contributions of DGS member institutions that qualify towards reaching the target level of the DGS fund.
  • Other AFM: funds that are not QAFM, including borrowed funds that stem from liabilities such as loans, and consequently do not count towards reaching the target level of the DGS fund.

The EBA expects that competent authorities should ensure that a DGS only includes QAFM when determining whether the target level for a DGS's financial means has been reached.

The guidelines also set out requirements on the information competent authorities should report to the EBA concerning DGSs under their supervision, including the reporting of outstanding liabilities of DGSs and high-level information on alternative funding arrangements that are in place.

The guidelines apply from 30 March 2022.

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United Kingdom: Access to Cash Action Group announces initiative to ensure long-term cash availability

On 14 December 2021, UK Finance published a press release announcing that the Access to Cash Action Group (CAG) had reached agreement on an initiative to ensure the long-term availability of cash across the UK.

Under the new model, any community facing the closure of a core cash service, such as a bank branch or ATM, will have its needs independently assessed by LINK. LINK will determine whether a new solution should be provided to meet the cash needs of the community as a whole, not solely the customers or members of a particular bank or building society. Communities will also be able to request a review of their needs from summer 2022.

The press release includes information on the locations of new services, with announcements of further services to come in early 2022. Shared banking hubs will be established, together with free ATMs, enhanced Post Office services and cashback without purchase. These new shared services will complement other industry initiatives to support cash and banking.

A related webpage explains that CAG's agreed cash access model was informed by Community Access to Cash Pilots, an independent initiative. The pilots finished in October 2021 and CAG has published the final report (dated December 2021).

In response to CAG’s announcement, the FCA and the Payment Systems Regulator (PSR) published a statement welcoming firms taking steps to maintain access to cash. The regulators note that, in July 2021, the government consulted on legislating to protect access to cash in the long-term. Ahead of future legislation, the FCA and PSR will continue to monitor access to cash and they will watch how CAG's initiative develops. The FCA will use what it learns to inform any work on the proposed future regulatory regime, including future requirements for cash access.

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United Kingdom: PSR extends Specific Direction 8 in relation to protected ATMs

On 17 December 2021, the Payment Systems Regulator (PSR) published a revised version of Specific Direction 8 (SD8), which requires the adoption of appropriate policies, measures and reporting obligations regarding protected ATMs. SD8 was due to expire on 2 January 2022. However, the revised version, as varied by Specific Direction 8a, will now remain in place until 31 March 2022 unless it is varied or revoked by the PSR.

The Specific Direction is given to LINK Scheme Holdings Ltd (LINK), the operator of the LINK ATM system, and is designed to ensure that LINK does all it can to fulfil the public commitments it made at the beginning of 2018 regarding the ongoing availability of access to free-to-use ATMs for UK consumers. Under the Direction, the PSR requires LINK to fully develop its policies and processes for applying and implementing its public commitments and to report to the PSR on a regular basis.

SD8 has been extended following the October 2021 consultation on a new Specific Direction to replace it, which closed on 16 November 2021. The PSR is reviewing the consultation feedback and is keen to fully consider it before deciding whether to issue a new Specific Direction.

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United Kingdom: FCA publishes forms for payment services and e-money firms exiting TPR or SRO

On 5 January 2022, the FCA updated its webpage on cancelling a temporary permission to provide information for payment services and e-money firms in the temporary permissions regime (TPR) or the supervised run-off (SRO) regime. It has also published the following notification forms:

  • TPR/SRO cancellation (PSRs/EMRs), to be used by a payment or e-money firm notifying the FCA that it intends to cease engaging in new business providing services under the TPR or to cease to provide services under the SRO. The webpage sets out the implications for firms that have closed, or will close, their UK business and want to exit the TPR or the SRO.
  • TPR to SRO notification, to be used by a payment or e-money firm notifying the FCA that it will cease relying on a temporary permission and will enter the financial services contracts regime (FSCR). The webpage sets out the implications for firms that want to exit the TPR but that have UK business to run off.

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United Kingdom: PRA publishes Dear CEO letters on 2022 supervisory priorities

On 12 January 2022, the PRA published two Dear CEO letters sent to UK deposit-takers and international banks active in the UK setting out its 2022 supervisory priorities. Some common areas of focus will be financial resilience, operational risk and resilience and financial risks arising from climate change.

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United Kingdom: Pilot of AI standards hub announced and research published

On 12 January 2022, the Department for Digital, Culture, Media and Sport (DCMS) and the Office for Artificial Intelligence announced that The Alan Turing Institute, supported by the British Standards Institution and the National Physical Laboratory, will pilot a new artificial intelligence (AI) standards hub. This is one of the actions set out in the government's national AI strategy, published in September 2021 (see the October 2021 Global Payments Newsletter). In December 2021, the Centre for Data Ethics and Innovation published a roadmap setting out the steps to an effective AI assurance ecosystem, in which the priority activities identified included developing standards that provide a common language and scalable assessment techniques for AI assurance.

The aim of the standards hub will be to increase the UK's contribution to the development of global AI technical standards. There will be a series of roundtables with a wide range of organisations led by The Alan Turing Institute to shape the hub’s activities ahead of the pilot’s launch.

Also on 12 January 2022, the government published new research, carried out by Capital Economics, on the scale of AI activity in UK businesses and scenarios for growth over the next twenty years. Findings include that more than 1.3 million UK businesses could be using AI by 2040, and that future spending on AI technologies is set to increase, but has a wide range of possible trajectories.

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Payment Market Developments

Malaysia and Indonesia: Boost partners with Mastercard on Malaysian and Indonesian payment solutions

On 10 December 2021, it was reported that Boost, the fintech arm of Axiata Digital, is partnering with Mastercard to provide a range of innovative payment solutions. One of the first expected products is a Mastercard prepaid card, which according to Boost will allow customers to make easy payments in Malaysia, Indonesia and countries where Mastercard is accepted. Mastercard and Boost also plan to work together on certain SME financial products.

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India: Paytm obtains scheduled bank status from RBI

On 9 December 2021, it was reported that Paytm Payments Bank has obtained scheduled bank status from the Reserve Bank of India (RBI). Commenting on the news, Paytm Payments Bank's CEO said that "The inclusion of Paytm Payments Bank in the Second Schedule to the Reserve Bank of India Act, 1934, will help us innovate further and bring more financial services and products to the underserved and unserved population in India".

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United Kingdom: Visa introduces crypto advisory service

On 8 December 2021, it was announced that Visa is launching a crypto advisory service, in order to help its partners navigate the crypto landscape. In the press release, Visa explains that in the past year they have seen a change in their clients' mindset on crypto, with growing numbers of clients starting to build crypto strategies and products.

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Europe: Nuvei and Visa launch crypto-friendly debit card

On 13 December 2021, it was announced that Nuvei and Visa have partnered to launch crypto-friendly debit cards in the UK and the EEA. It is hoped that the card will provide customers with an easy way to spend crypto anywhere that Visa is accepted.

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Global: HSBC and Wells Fargo launch blockchain FX solution

On 16 December 2021, it was reported that HSBC and Wells Fargo are planning to use blockchain technology to settle foreign currency (FC) trades. The solution will allow Wells Fargo and HSBC to settle FC trades bilaterally multiple times a day, with settlement taking less than three minutes. Commenting on the plans, HSBC said that the bank sees distributed ledger technology as an efficient cross-border settlement method, and a good way to achieve audit trail transparency.

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United States: Travala.com to accept Bitcoin payments

On 15 December 2021, it was announced that travel company Travala.com is now accepting Bitcoin payments through OpenNode's Bitcoin Lightning Network. Travala.com had already been accepting Bitcoin, but this integration means that their platform can now accept such payments instantly.

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Lithuania: Revolut receives banking licence

On 16 December 2021, it was reported that Revolut Bank has been granted a banking licence by the Bank of Lithuania. Revolut’s CEO has said that Lithuania is set to remain Revolut's base in the European Union.

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China: Tencent partners with Paysend on Weixin remittances

On 29 December 2021, it was announced that Tencent is partnering with Paysend to enable users to receive money through Weixin, the PRC version of WeChat. Under the partnership, Paysend users will be able to send money cross-border, with the funds reaching bank accounts linked to the Weixin app.

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United Kingdom: Judopay partners with Mastercard to strengthen mobile payments

On 4 January 2022, it was reported that Judopay has partnered with Mastercard to strengthen mobile payments. Judopay will use Mastercard's SCA compliant Click to Pay solution, which it is hoped will offer consumers and merchants a more convenient and secure check out experience, supported by intelligent recognition.

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Israel: Stripe launches operations

On 4 January 2022, Stripe unveiled its operations in Israel. For now, the company is only engaging in sales and support operations in Israel, and no R&D activity.

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Africa: Pipit Global enters 12 new markets

On 17 December 2021, it was announced that Pipit Global is entering 12 new African markets in partnership with Cellulant. The partnership will see the companies providing both B2B and B2C payments services to customers.

The partnership between Pipit Global and Cellulant now covers 18 countries, namely Egypt, Kenya, Uganda, Tanzania, the Democratic Republic of the Congo, Zambia, Mozambique, Zimbabwe, South Africa, Mali, Burkina Faso, Ghana, Cote D'Ivoire, Guinea, Nigeria, Cameroon, Rwanda and Senegal.

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The Netherlands: Adyen launches Android POS terminals

On 5 January 2022, it was announced that Adyen has launched an Android point of sale (POS) terminal in the EU, UK and US. The terminals are said to function as an all-in-one solution which eliminates the need for separate cash registers and barcode scanners. In addition, the terminals come with an app management system.

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Surveys and Reports

Singapore: Fintech reaches critical mass

On 4 January 2022, it was reported that a report on the Singaporean fintech market had been released. The report found that Singapore's fintech market has reached a critical mass, and that the COVID-19 pandemic has acted as a catalyst for this by driving up demand for digital payments, virtual banking and Buy Now Pay Later (BNPL).

In particular, the report notes that:

  • The move towards cashless payments and developments in real-time payment are driving a surge in digital payment solutions, in particular in e-wallets.
  • BNPL has also surged in popularity since the start of the pandemic. Data shows that 30% of Singaporeans aged 25-40 have used BNPL, with 67% of users citing rewards or cashbacks as their top reasons for using BNPL.
  • 20% of fintech companies in Singapore are blockchain/crypto firms, 17% are payments firms, 13% are investment/wealthtech firms, and 10% are regtech firms.

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United States: Federal Reserve reports on payment trends

On 22 December 2021, the Federal Reserve published its Federal Reserve Payments Study (FRPS) for 2020 and 2021. In particular, the report notes that:

  • Payment behaviour changed sharply in 2020 due to the COVID-19 pandemic.
  • The total number of card payments declined in 2020, driven by a decline in in-person card payments. This is the first annual decline in the number of card payments recorded by the FRPS.
  • The decline in in-person card payments in the spring of 2020 was largely counterbalanced by an increase in remote card payments. Later in the year, in-person card payments recovered somewhat.
  • The pandemic may have helped to stimulate the growth of innovative payment methods, such as in-person contactless card, digital wallet, and P2P payments.

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United States: Visa study finds that digital payments preferred for remittances

On 17 December 2021, Visa announced that it had commissioned a study which had found that digital payment is the preferred method in the US for sending money abroad. The survey found that:

  • 23% of surveyed US adults have sent money from the US to another country.
  • Of those remittance users, 65% planned to send money to another country over the Christmas period.
  • 59% of remittance users surveyed said that they have sent, or plan to send, money using digital-only platforms.

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[View source.]

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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