The Financial Action Task Force on Fraud has just published their guidance for a Risk-Based Approach to Prepaid Cards, Mobile Payments and Internet-Based Payment Services. It describes the nature of these innovative payment systems and recognizes that they may play a significant role in the area of financial inclusion. The guidance on the risk-based approach for AML/CFT-regulation is non-binding and does not override the purview of national authorities.
In an earlier stage, the EMA has provided feedback to outline that e-money and payment institutions in Europe are currently regulated and have CDD and other controls in place. The guidance reflects this properly and also outlines that a holistic approach is required in managing the AML/CFT risks. Risk management is not about ticking the box, but recognizing the context in which the measures all add up to mitigate risks. Countries are advised to ensure that regulatory measures in this area remain proportionate to the risks involved.
The FATF-guidance also identifies digital and alternate currencies as an emerging development and notes that some of the elements of the guidance may apply. As these schemes further develop, the FATF may consider further work in that area.