Do white-labeled online payment providers in receiving countries also handle regulatory compliance in sending countries?
Payments
Asked by Question Bot09/Apr/20121 answer
1 Answer
F
Faisal Khan
Answered 09/Apr/2012
Mixed answer. They can't take care of it per se, but if the white-label provider is the license holder (most cases) then to be approved for white-labeled services, be it RBI or SBP, etc. you need to have the following:
A couple of important things to remember/note:
- Full 50 state license verification (45 states for US) as a money transmitter , - assuming the white-labeled service is stemming from US
- FSB registration document that the license holder has filed and registered with Department of Treasury
- Your AML, KYC registration as filed with FinCEN and approved
- You then provide all this (along with the financial information of the company that holds the license) to the regulatory bank (RBI/SBP) and then obtain the necessary approval with the local bank to proceed ahead.
- Fail on any points - and you will not be allowed to go live (by Feds and the central bank in your beni country)
A couple of important things to remember/note:
- Your online processor must be registered with FinCEN, and MSB holder and also must have a money transmitter license in the approved 45 states
- Your online processor must be AML / KYC registered and approved by both FinCEN and the State they are physically operating out of.
- The large 45 state license holder banks already are in some arrangement with large money service businesses (like Western Union, Moneygram, etc.) and would most likely not disturb that arrangement for you.
- You must obtain Fed approval for a special charge-back nostro trust account
- As per Fed guidelines, you would be required to have a 60 day (or even 90 day) rolling reserve deposit into the trust account