Financial Crime World

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Implementing AML/CFT Regulations for Non-Bank Card-Based Payment Instrument Issuers, Electronic Money Issuers, and Non-Bank Electronic Wallet Providers

Guidelines Overview

It appears that you’ve provided a comprehensive overview of guidelines for implementing anti-money laundering and countering the financing of terrorism (AML/CFT) regulations for non-bank card-based payment instrument issuers, electronic money issuers, and non-bank electronic wallet providers.

Key Components

The guidelines are broken down into several key components:

Customer Information

  • The presence of customer information features
  • Electronic wallet (EW) nominal transactions for credit cards, debit cards, other EM issuers, EM own products, virtual accounts, and others
  • The volume or frequency of EW transactions

Delivery Channel

  • A transaction network is a medium for carrying out transactions of a product or service
  • High risk inherent in the delivery channel that allows transactions to occur without adequate CDD process
  • Data required from Providers includes:
    • Number of issuers and 3rd parties brokering CBPI, EM, and/or EW marketing
    • Number of offline merchants
    • Number of online merchants
    • Number of principals

Cross-Border Transaction

  • The presence of cross-border transaction features
  • EW nominal transactions for credit cards, debit cards, other EM issuers, EM own products, virtual accounts, and others
  • The volume or frequency of EW transactions

Politically Exposed Person (PEP)

  • Definition of PEP: a person who is given the authority to perform prominent functions by another country, the country, or international organizations
  • Presence of PEP increases risk of using Issuer/Provider’s products for ML/FT
  • Data required from Providers includes:
    • Number of PEP

Assessment

  • Self-assessment by Issuers/Providers using a questionnaire on the Self-Assessment form provided by BI (Appendix 2)
  • Assessment based on compliance with applicable regulations, including active supervision by the Board of Directors and adequate monitoring
  • Risks can be classified as Low, Medium, or High, depending on the inherent risk value calculated using the RBA tool prepared by Bank Indonesia (Appendix 1)