La monnaie électronique 2 ème génération : vecteur de développement du prépayé?

Transcription

1 La monnaie électronique 2 ème génération : vecteur de développement du prépayé? EIFR & Wragge & Co Paris Overview of the development of e-money in the EEA February 2012 Dr Thaer Sabri Chief Executive Electronic Money Association

2 Introduction The Electronic Money Association association for e-money issuers and PIs in the EEA The factors that have characterised growth in the industry Current regulatory challenges and current opportunities Growth Data Some conclusions

3 Members of the EMA include: 3

4 Recent history of e-money The first EMD created the opportunity for non-bank service providers The internet unleashed the opportunities for new payment methods E-Bay and peer to peer money transfers Gambling Digital content US gift card and open loop gift card innovations opened the way for EU markets Diversification of business models into range of niches has characterised the current phase Innovation in mobile acquiring has opened up competition in a previously inaccessible market Square, izettle etc.

5 Growth characteristics for e-money Current opportunities lie in adding value around the payment transaction: integrating payment within applications solving payment-related problems such as invoicing, fraud management and reporting Addressing the needs of the financially excluded, from teens to migrant workers E-money products are merging with straight-through payments and credit to create a class of new payment methods The market is much more accessible than previously possible: ease of access to consumers and hardware is high: - the iphone effect

6 Regulatory challenges and opportunities Regulatory Review of 3rd Money Laundering Directive waters down Simplified Due Diligence provisions creating barriers to entry Practically, the means of undertaking DD remotely needs to evolve New ECB guidelines on the security of internet payments will need to be implemented by regulators in a risk sensitive manner Much of it is good practice, but there are some areas of concern Obligation for two-factor authentication for both funding and payment transactions may present customer experience challenges

7 Challenges and opportunities Review of the PSD may open up opportunities for a greater range of services to be offered Formalisation of overlay services Access to bank balance information Access to designated payment systems Regulation can help create a market by opening up avenues of competition or by enabling a more sophisticated set of relationships to evolve. Regulation can, however, also suffocate fledgling businesses

8 Challenges and opportunities Member states may, for example, respond to perceived risks with regulation, stifling business: Regulation of distributors in Germany is one example Seeking to apply host country AML legislation to cross border services is another The availability of information that is associated with payment transactions provides much mitigation: it enables risk engines to be built and compensates for the non face-to-face nature of transactions US approach of laissez-faire is no panacea as it requires significant investment to address state-by-state regulation

9 ECB Data: E-money purchases: (transaction volume in millions) Note these numbers exclude the UK Euro area EU Germany Volume of transactions in millions Euro area EU German y Growth rate Euro area EU Germany % 71% -8% % 9% -9% % 19% -10% % 18% -8%

10 Some conclusions The relationship between industry and the regulator is key to developing an appropriate regulatory framework The implementation of the framework must also be proportionate Growth in the industry occurs in niche markets that widen in scope The market players are diverse, small players are able to exert influence far beyond their size; both issuing and acquiring are highly competitive The market opportunity is global and not just French, or EEA.

11 Thank You M