In the past IMTC BRASIL 2016 in Sao Paulo, Leonardo Costa made a presentation available in our Download Section entitled Nueva Guia GAFI Prestadores Servicios Transferencia Dinero Valores about the FATF – GAFI February 2016 document on the GUIDANCE FOR A RISK-BASED APPROACH for MONEY OR VALUE TRANSFER SERVICES. The Guidance in Page 46 (#125) urges the Banks to “not resort to the wholesale termination or exclusion of customer relationships within the MVTS (money or value transfer services) sector”.

Commenting on this Guidance and De-Risking and Bank Discontinuance problem – that is now extending as US Commercial Banks force local banks to close accounts of local MVTS companies – Leonardo use this great metaphor:

We are being asked to trade our old cars for very new state-of-the art cars, we have to pass all the emission tests, we are being required to get the most stringent vehicle driving licenses… and the banks are not allowing us to use the highway.


The metaphor has not been copyrighted so use it freely. Specially in front of regulators and yes, even banks. Give credit to Leonardo. And if you want to send us your own metaphor, we will publish it here!