Supervising Nonbank E-Money Issuers
Nonbank e-money issuers (NEMIs) can play an important role in providing an array of financial services--particularly payments, transfers, and savings--for those who are currently excluded from the formal financial system. In some countries, private sector interest in establishing NEMI operations has been hindered by policy maker concerns over the lack of a clear supervisory framework for this relatively new category of financial institution. In light of this, CGAP researched the current supervisory practice in 10 countries that permit NEMIs and found that while few have a clear supervisory approach, all engage in minimal post-licensing supervision. This Brief addresses only the supervision of e-money issuing activities of a NEMI. It highlights the primary risks presented by NEMIs and concludes that the minimal supervision undertaken in the researched countries reflects two current realities: NEMIs are engaged in limited activities, and they do not present a systemic risk given the limited funds involved. The minimal approach taken by supervisors today is consistent with the proportionality principle endorsed or supported by, among others, three international standard-setting bodies (i.e., the Basel Committee on Banking Supervision, the Committee on Payment and Settlement Systems, and the Financial Action Task Force) relevant to the supervision of NEMIs.