Is a digital wallet legally the same as a bank account?
1 Answer
Faisal Khan
Answered 09/Apr/2023
Not necessarily. It depends on how the digital wallet is set up. In all instances, the fiat balances of the wallet(s) will always be in a chartered/licensed banking institution. Whether the digital wallet it offered by a mobile money operator, an app, a banking app, an e-money issuer, that statement will always hold true for fiat balances. The money will reside in a bank account.
How the wall is structured, will vary. If it is a digital wallet offered directly, by a licensed, deposit-taking FI directly, then chances are the digital wallet is a bank account. If the same is offered by a non-banking financial institution, such as an e-money issuer (EMI, etc.) then the digital wallet could mimic a bank account, but not necessarily, as the money is most likely in a pooled account.
If the money is provided by an app provider, then in most cases it is the same as the e-money issuer case, i.e. it exists in a pooled account, or FBO (For Benefit Account), sometimes even labeled as an Omnibus Account. The banking nomenclature will differ, but the basics would be the same.
If the digital wallet is offered by a mobile money operator, then the same would apply, it would be a bank account with a chartered/licensed banking institution.
If however, the digital wallet is holding non-fiat balances, then it might not even be a bank account or even a financial institution would not be holding balanced (individually or pooled) of the wallet operator.