Does this change the Bank of England's policies related to CHAPS that are an equally significant blocker:
Do the IT/Disaster Recovery requirements of CHAPS alter? I would have thought that these would outweigh a reduction of £40,000 p.a. in fees.
23 Jan 2015 11:26 Read comment
Proper usage of the apostrophe is also a key RM skill
24 Nov 2014 10:52 Read comment
55 banking professionals surveyed out of 5,000 SIBOS delegates - impressive - of whom 28 agreed with the leading statement, and 10 agreed with the other one, the latter being 0.2% of SIBOS delegates. How many of the 55 agree that Earthport is the solution to the problem? Putting in place "international payments products with low value international clearing" could mean implementing SEPA.
30 Oct 2014 10:03 Read comment
How different are these from the medallions of the England 1970 World Cup squad you got free from Esso with 4 gallons of 4-star?
Securely, extravagantly numbered bits of brass, or of silver if you buy the expensive ones, in a velvet case. At least the silver ones have a value - their weight in silver. The brass ones are literally valueless. Why should they ever have a value, that is after the punter has paid out whatever price is put on them in real money?
You don't even get an image of Peter Bonetti to help you remember the quarter final.
What happens to the money paid in - I mean the real money? Do the sponsors just take it out and spend it? There is no doubt that with all that security and a proper certificate, you definitely own the coin and the claim on whatever it represents, but what does it represent?
These tokens are very different from the £5 commemorative coins issued for Kate & Will's wedding - that is legal tender, issued by the Bank of England.
Has the Bank of England anything to say about a company launching a rival physical note&coin to its own in the UK?
I cannot believe that this can be offered as an "investment" to UK residents, even from somewhere like the Isle of Man. This looks like an Icesave model, except that was with a proper bank (albeit a dud one) and the funds were invested in businesses (albeit failing ones). Do the Isle of Man authorities want thier environment to risk getting classed as the new Iceland?
What assets are the proceeds invested in here such that the value of a partial claim on the asset portfolio might result in the price of the bitcoin rising? What is the credit rating? Where is the liquidity? Where is the ombudsman? Is this a Limited Network within the meaning of Payment Services Directive? Are we looking at a form of Green Shield Stamps? What is the VAT treatment? What is the Capital Gains Tax treatment? Are these 'goods' or 'money'? Who accepts these in payment and at what value? Even the kind of investment that is advertised on page 27 of the Sunday Times colour supp alongside the devices to get you in and out of the bath has to state what regulation regime it sits within.
The precious piece is the statement that they "need to perform an analysis of what local regulations apply in each country we hope to sell in first, so are focussed on launching in the UK for the time being".
So there are no local regulations here in the UK on trying to tout brass ovals as an investment? Has the Financial Conduct Authority anything to say about? HMRC? The Financial Ombudsman? Inland Revenue?
Here are two quotations from a warning brochure I received on Saturday from the FCA:
"Watch out for these common features: transfers of your money or investments overseas, meaning the money is harder to recover"
"Make sure the adviser is authorised by the FCA at www.fca.org.uk/register"
I'll stick to my medallions, I think, and investments in real investments.
27 Oct 2014 09:23 Read comment
Here are the research papers used as the basis for my opinion:
European Banking Authority EBA/Op/2014/08 EBA Opinion on ‘virtual currencies’
FATF Report June 2014 – Virtual Currencies: Key Definitions and Potential AML/CFT Risks
Elements of the EU Payments Regulatory Package:
- Draft of the 4th EU AML Directive 2013/0025
- Draft Funds Transfer Regulation 2013/0024
- Draft of the 2nd Payment Services Directive 2013/0264
2012 FATF Recommendations (global-level basis of 4th EU AML Directive)
From my angle these amount to a sufficiently authoritative package and – in my opinion – it behoves the industry to adhere to both the spirit and the letter, rather than creatively seeking unregulated areas in which to lay the groundwork for a future South Sea Bubble that authorities (and through them the taxpayers) will be called upon to remedy.
By staying on the reservation that the regulators and political authorities have circumscribed, the industry would show that it has changed its culture and can be a reliable enough partner to be accorded self-regulation at some point in the future.
03 Oct 2014 12:45 Read comment
Baffled by crypto (secret) offerings being embraced at SIBOS where many other sessions are about transparency and integrity within the traditional payments eco-system.
We have recent papers from the US and European regulators that state definitively that the crypto world is for criminality, money-laundering and tax evasion.
Creation of money supply without governmental authority used to be known as forgery; at least - if the crypto currency is allowed to flow into the real world - this artificial increase in money supply causes inflation and the reduction in the value of other assets (pensions, investments, savings), or else asset bubbles such as in property to the detriment of ordinary citizens.
We have enough of the kind of increase in money supply with the various central bank instances of Quantitative Easing; the last thing we need is another unofficial source of money supply.
If economic activity migrates to the crypto world - an untaxed world without the inconveniences of Pay-as-you-Earn taxation - you have a threat to the affordability of state pensions and the public services on which many of our fellow citizens depend.
At this conference where we have (in my opinion) an industry responsibility to assure and strengthen the transparency and the integrity of the payment mechanisms behind a fair, open and democratic society, we should be working on techniques to isolate the crypto world hermetically, not to allow it to co-mingle.
02 Oct 2014 11:29 Read comment
Shared KYC database - very dangerous to the system but very good for new entrants. Little players should have the same risks and responsibilities as big players in this area; otherwise they can become a soft point-of-entry. Once a rogue person or entity has been established falsely in such a database, you have a mole inside the system that can burrow freely and in any direction. How could it be ensured that KYC data was regularly refreshed? From which Trusted Third Parties would it derive its data and who decides whether the processes of those TTPs are watertight? Who would carry the legal liability for a failure and pay the heavy financial penalty (and that is the key to making sure the work is done properly)? And who would run it? I think we can see who is putting themselves up for that role.
23 Sep 2014 12:32 Read comment
Is this SEPA-compliant?
18 Sep 2014 13:48 Read comment
Since you can skype and Facetime through a tablet and a laptop this research seems only to indicate that people want to do stuff on a slightly bigger screen but not too big. Wow! What is the exact definitional breakpoint between a mobile and a tablet, as my iPhone is 12.5x6cm and my iPad is 24.5x19cm? Is it 18.75x12.5cm? Can we deduce that by 2016 >50% of people will be using a device >18.75x12.5cm and <50% will use <18.75x12.5cm? And in Sweden by 2018 it will be 89% >18.75x12.5cm but in Italy 46% <18.75x12.5cm? The earth really has moved here on the basis of that intelligence. What is the definitional breakpoint between a wireless laptop PC and a tablet? My wirless laptop is 38x26cm so issszzzzz....
20 May 2014 21:42 Read comment
Is this another current account paid for by interchange fees levied on merchants? I notice it is a MasterCard, maybe a premium brand. In other words a current account subisidised by other consumers through the higher prices that merchants charge the many in order to absorb the deductions caused by the cards proferred by the few.
07 Mar 2014 16:59 Read comment
Bhuvan Satwahconsultant at TCS
Michael JoyceConsultant at Shorebank International
Reghunathan Sukumara PillaiConsultant at Infosys
Peter MoranConsultant at Certicate Limited
YeeKai LaiConsultant at United Overseas Bank Limited Co.
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