What is the difference between white-label sponsorship and being an agent of a money transfer company?
Money Transmitter License
Asked by Question Bot01/Jun/20201 answer
1 Answer
F
Faisal Khan
Answered 01/Jun/2020
The answer can vary from geography to geography. Each financial regulator provides its own prescribed set of rules on how such a relationship can be established.
For example, in the UK or EU, there is the white-label sponsorship program and a registered agent program, better known as an EMD (electronic money distributor).
https://www.youtube.com/watch?v=...
The differences between the two are summed up below:
As an EMD:
- You essentially have a license, even though it is a sub-license arrangement, but a license nonetheless
- The correct term is you are a 'registered agent'
- You can touch the funds
- You need an MLRO
- You will need to have a compliance program in place
- Depending on the jurisdiction where you get the EMD status, you might have to maintain, and in-country office or presence (minimum presence)
- You can sign up customers directly and do KYC on your customers
- You would be open for audit by the EMI
- Depending on the arrangement you can do correspondent tie-ups
- You can do your own assigning of the IBANs to your customers
- You are legally bound by the transactions that are executed by your company
- You work with the API
If you opt for the Sponsored route:
- You are an ISO (Independent Sales Organization) so to speak, so you do not have a license but you work "with" an entity that has a license
- The correct term is an ISO/MSP (Independent Sales Organization / Managed Services Provider)
- You cannot touch the funds
- You do NOT need an MLRO
- Your Compliance is essentially the hand-me-down as provided by the EMI and it is their compliance manual that is followed and adhered to
- You do NOT have to maintain and in-country office or presence (minimum presence)
- You cannot sign up customers directly
- You cannot do KYC on your customers
- You are not subject to an audit
- You cannot do any correspondent tie-ups
- You cannot do your own assigning of the IBANs to your customers, the EMI will have to do it for you
- You are not legally bound by the transactions carried out. The EMI is. You are absolved.
- You get a white-label platform to work on, and additionally, you can also work with an API
In both cases, you would be allowed (under EU) to passport client information (once you get your own license), get a copy of the transaction logs/history.