Legal from a Layman
A snapshot of what is happening in payment regulations
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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
[email protected]+44 (0)20 7928 0040 office+44 (0)7803 203 405 mobile
www.yourgx.comwww.prepaidawards.comwww.emergingpaymentsawards.com
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