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Table 1: Nonbank E-Money Issuers: Global Approaches to Protecting Customer Funds*
Fund Safeguarding Restrictions on Fund Use Isolation Measures Other Risk Mitigants
Afghanistan
(Amendment to the Money
Service Providers Regulation to
Extend Regulatory Oversight
to E-Money Institutions, 25
November 2009)
At all times, an e-money issuer must
maintain liquid assets to at least
100% of e-float. (Section 2.5.5.1)
Liquid assets consist of the sum of
AFN-denominated banknotes and
coins, held in a trust account at a
banking organization (full-fledged
bank licensed or permitted by Da
Afghanistan Bank. (Section 2.5.5.1)
Liquid assets must be held in trust
account at a banking organization
(full-fledged bank licensed or
permitted by Da Afghanistan
Bank). (Section 2.5.5.1)
If total electronic value liabilities
are greater than AFN 250 million,
no more than 25% of liquid assets
can be held at a single banking
organization. (Section 2.5.5.2)
If total electronic value liabilities
are less than AFN 250 million,
the e-money issuer is expected
to observe prudent diversification
of its liquid assets across financial
institutions. (Section 2.5.5.3)
BCEAO
(Instruction No. 01/2006/SP (31
July 2006) Relative a l’Emission
de Monnaie Electronique et
aux Etablissements de Monnai
Electronique)
E-money issuers shall maintain
investments of an amount at least
equal to their financial liabilities
related to debt representing the
e-money issued and only in assets
listed below:
a) Cash deposits in a bank
b) Bonds issued by the central
government or its entities or by
the central bank
c) Securities (i) other than those
referred to in point b above
and (ii) issued by companies
licensed by the Regional
Council of Public Saving and
Capital Markets, other than
companies that have qualifying
equity in the e-money issuer
concerned or which must be
included in the consolidated
accounts of those enterprises.
(Article 18.1)
Commercial activities of e-money
issuers are limited to the provision
of services related to the issuance,
the provision or management of
e-money, and the storage of data
on electronic devices on behalf of
other corporations. (Article 9)
Indonesia
(Bank Indonesia Regulation
Concerning Electronic Money, No.
11/12/PBI/2009, 13 April 2009)
(Circular Letter Concerning
E-Money, No. 11/11/DASP, 13
April 2009)
In the case the issuer is an
institution other than a bank,
managed float funds must be
placed with a commercial bank
in the form of a deposit account
consisting of savings account,
current account, and/or time
deposit account.
Issuer can use float funds
only in the interest of liability
fulfillment for e-money holders.
Float funds may not be used for
financing activities beyond the
liabilities toward the respective
holders such as financing issuer
operations. (Circular Letter,
Section VII.H.3)
License required only if float
totals or is expected to total 1
billion IDR (approx. US$110,000).
(Circular Letter, Section VII. B.1.a)
“Float funds placed at a
commercial bank… must total
100% of the funds derived from
sales proceeds of electronic money
that represent the Issuer’s liability
towards e-money holders…”
(Circular Letter, Sections VII. H.1
&2)
Malaysia
(Guideline on Electronic Money
BNM/RH/GL -16-3, July 2008)
To avoid commingling of funds, the funds collected from users should be deposited and managed separately
from the issuer’s working capital funds. (Article 10.1)
Large E-money Issuer (MYR 1 million or more for six consecutive months)
An issuer of a large e-money scheme should deposit the funds collected in exchange of the e-money issued
in a trust account with a licensed institution. Such funds can be used only to refund to uses and effect
payment to merchants. (Article 10.2(b))
Funds may be invested only in high-quality liquid ringgit assets that are limited to deposits made with
licensed institutions, debt securities issued or guaranteed by the Federal Government and Bank Negara
Malaysia, Cagamas debt securities, and other instruments as may be specified by Bank Negara Malaysia.
(Article 10.2 (c))
Small E-money Issuer
An issuer of a small e-money scheme shall place funds collected in exchange for the e-money issued in a
deposit account with a licensed institution, separated from its other accounts, and should be managed by the
issuer in a matter akin to a trust account arrangement. The funds deposited can be used only to refund users
and effect payment to merchants, and the funds shall not be invested in any form of assets other than as
bank deposits. (Article 10.3)
Issuers of large e-money schemes
who are unable to restrict their
activities to e-money business
only shall deposit and maintain an
additional 2% of their outstanding
e-money liabilities in the trust
account at all times. (Article
10.2(f))
An issuer of e-money shall not use
the money collected to extend
loans to any other persons.
(Article 13.1(ii))
Philippines
(Circular 649, 9 March 2009)
The e-money issuer should have
sufficient liquid assets equal to the
amount of outstanding e-money
issued. The liquid assets should
remain unencumbered and may
take any of the following forms:
1. Bank deposits separately
maintained for liquidity
purposes
2. Government securities set aside
for the purpose
3. Such other liquid assets as the
BSP may allow. (Section 5.D)
E-money issuers shall engage
only in the business of e-money
and other activities related or
incidental to the business of
e-money such as money transfer/
remittances. An existing entity
engaged in activities not related
to the business of e-money but
wishing to act as an e-money
issuer must do so through a
separate entity duly incorporated
exclusively for such purpose.
(Section 5.B)
Nonbank e-money issuers shall
not engage in the extension of
credit. (Section 5.C)
*Information in this table is based in part on unofficial English translations of relevant regulation. It is not intended as legal guidance or opinion, and reference should always be made to
the original text.