Saturday, June 26, 2004
What about special recommendation VI of the FATF?
VI. Alternative remittance
Each country should take measures to ensure that persons or legal entities, including agents, that provide a service for the transmission of money or value, including transmission through an informal money or value transfer system or network, should be licensed or registered and subject to all the FATF Recommendations that apply to banks and non-bank financial institutions. Each country should ensure that persons or legal entities that carry out this service illegally are subject to administrative, civil or criminal sanctions.
This SR implies that the 'postpone-the-discussion-to-the-New-Legal-Framework-solution' will conflict with the duties of government under the FATF. The New Legal Framework is clearly not yet sufficiently designed and thought-through to be effective regulation in February 2005. So, as in 2000, all regulatory roads lead to a regulation of mobile operators as e-money institutions (of full banks if they so desire). And it will be interesting to see what new arguments and solutions will be put forward by the mobile operators lobby.
To be continued....
Posted by Simon on 09:46 | link