Legal from a Layman

A snapshot of what is happening in payment regulations

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Judge us by the company we keep – Gx members

Going where no man has gone before

1. What’s happening?• The tsunami of change• Where you should be worried

2. What can you do? • Avoiding the Ostrich

Strategy

What’s happening?

1. Current payment Directives in the spotlight• 4th Anti-Money Laundering Directive• 2nd Payment Services Directive• 3rd E-Money Directive

2. New Payment Systems Regulator3. Interchange regulation4. Limited Network regulations/guidelines5. Crypto-currency phenomenon 6. Banking Crisis What Crisis

Directives are a description

of the END RESULTAdapted for local situations

Please nudge your neighbour

Payment Systems Regulator

Limited Networks

Interchange

4th AML Directive

2nd Payment Services Directive

3rd E-Money Directive

Crypto Currency

Regulations

Highlights

• PSR • 12 concerns highlighted

1. Improve direct and indirect access routes to the infrastructure

2. Facilitating and directing innovation• OPEN FOR BUSINESS

• PSD• Complexity – terms, value chain, technology – 901

amendments• Multi-country differences• Limited networks• Purpose – who, what, when are we regulating?

Concerns

Concerns, continued

• AML• Significant constraints likely to be imposed• Prepaid seen as being vehicles for money-laundering• Enhanced due diligence could destroy 40% of prepaid products

• EMD• Gathering evidence but the door seems shut• Excludes mobile• Should there even be e-money?

• Crypto-currencies• Should be part of PSD• Currently not being addressed

Concerns

• Limited Networks• BIS has an agenda• Not listening• Could destroy important and profitable part of the industry

And another thing . . .Whatever happened to SEPA?

‘I still see almost nothing happening in SEPA-land’ March 2010, CELENT

‘SEPA migration has started to rock and roll’March 2014, GT News

‘We are nowhere near having a single euro payments area’

March 2014, Tony Craddock

 

Don’t just sit there . . .

• The sand is getting hotter

• Submit your responses to the Call for Input from PSR• Directly• Through your trade

association

• Approach the consultancy reviewing 3rd EMD and make your case

• Create a point of view• And promote it

Tony CraddockCEOGx58 Southwark Bridge RoadLondon, SE1 0AS, UK

Tony.Craddock@yourgx.com+44 (0)20 7928 0040 office+44 (0)7803 203 405 mobile

www.yourgx.comwww.prepaidawards.comwww.emergingpaymentsawards.com

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