De-Risking

The problem

We can’t say that the access to banking accounts problem is new in the Money Transfer Industry, not in the USA or a number of other countries. It was one of the reasons why the NMTA was formed back in 1996, David Landsman, Executive Director, reminds us every now and then. So why is this a such an urgent issue in 2014? I think the answer is that in the last decade a large number of small money transfer companies, with very little capital and minimal compliance structures were the first to go, now is the medium sized, larger companies, well funded, with large investments in technology and compliance the ones that are feeling the brunt. What should the industry do?

On November 11th, as part of IMTC WORLD 2016 we will be having a “DE-RISKING & BANK DISCONTINUANCE FORUM” to discuss the impact of this practice in the Money Transfer, Remittance and Payment Industry as well as the U.S. depository institutions termination of correspondent accounts of foreign financial institutions (FFIs) as well as some US Banks forcing local bank account closures by their corresponding banks in many countries in the world.

As we informed all our special Friday Newsletter to subscribers in the UK, the Commonwealth Secretariat invited the International Money Transfer & Payments Industry to the “Disconnecting from Global Finance: A Conversation on De-Risking” meeting that was programmed this past Thursday, August 10th at Marlborough House in London. The meeting was called following the release of the Commonwealth’s report “Disconnecting from Global Finance: The Impact of AML/CFT Regulations in Commonwealth Developing Countries”. Passions ran high at the meeting as money transfer businesses and smaller financial institutions complained about the “detrimental” decline in international banking for many businesses and individuals.

To show how critical MSBs are to the functioning of the U.S. financial system, a 2013 Federal Deposit Insurance Corp. survey found 9.6 million U.S. households did not have bank accounts and 24.8 million households — 20 percent of the U.S. population — were underbanked, meaning they had bank accounts but also used alternative financial services outside of the banking system

Today, MSBs worldwide are caught in a banking crisis showing no signs of relenting. Based on real and imagined enforcement risks, most banks have categorically decided against providing accounts to MSBs, while others have been ordered by regulators to stop serving MSBs. This process of “de-risking,” by which banks terminate relationships with “high-risk” customers, has been brutal for the MSB industry and resulted in unforeseen consequences, including:

In the past IMTC BRASIL 2016 in Sao Paulo, Leonardo Costa made a presentation available