E-wallets and CRS
- Pistu
- Gaining experience
Post
Re: E-wallets and CRS
Yes, but their prepaid mastercard is issued by Choice Bank Ltd. which is located in Belize which signed the CRS (Automated Exchange Of Information) treaty.
- Pete1928
- Gaining experience
Post
Re: E-wallets and CRS
what about skrill's mastercard? issued by paysafe.
Btw, for me two things are important:
1) no self certification
2) skrill and neteller still state in repiies to customers that they are not subject to it.
So unless there are no rules in the world, this means they are not reporting.
Btw, for me two things are important:
1) no self certification
2) skrill and neteller still state in repiies to customers that they are not subject to it.
So unless there are no rules in the world, this means they are not reporting.
Last edited by Pete1928 on Tue Aug 08, 2017 8:35 am, edited 1 time in total.
- JX123
- Gaining experience
Post
If that was true, entropay would be dangerous as well, as the virtual CC they offer is issued by a bank in Malta, which is also participating in CRS.
Re: E-wallets and CRS
This is interesting. Are you sure that if you use their credit card, that you will get reported although the e-wallet itself is located in a country that does not participiate in CRS?Pistu wrote: Yes, but their prepaid mastercard is issued by Choice Bank Ltd. which is located in Belize which signed the CRS (Automated Exchange Of Information) treaty.
If that was true, entropay would be dangerous as well, as the virtual CC they offer is issued by a bank in Malta, which is also participating in CRS.
- Pistu
- Gaining experience
Post
Re: E-wallets and CRS
Really hard to know, i personally think that nobody is 100% sure about the rules, even the "financial institutions" themselves. So it's probably coming down to luck who is going to report and what and when. :-/
- Pistu
- Gaining experience
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Re: E-wallets and CRS
http://www.oecd.org/tax/automatic-exchange/common-reporting-standard/CRS-related-FAQs.pdf
8. E-money providers – qualification as a Depository Institution What is the status of electronic money providers for CRS purposes?
No special rules apply to electronic money providers. Like other financial industry participants, they must determine
whether they are a Financial Institution, as defined by the CRS. That determination will depend on the facts and
circumstances. For instance, in order to determine whether an electronic money provider is a Depository Institution,
the analysis must be done with reference to Section VIII(A)(5) and the related Commentary, in particular paragraph 13.
7. Excluded Accounts - low-value electronic money accounts
Under what conditions can electronic money accounts that are Depository Accounts be Excluded Accounts pursuant to Section VIII(C)(17)(g)?
The mere fact that a Financial Account is an electronic money account does not by itself enable that Financial Account
to be specified by a jurisdiction in its domestic law as a low-risk Excluded Account. In order for such Financial
Accounts to be specified as Excluded Accounts under the domestic law of an implementing jurisdiction pursuant to
Section VIII(C)(17)(g), the jurisdiction needs to ensure that the accounts present a low risk for being used for tax
evasion, have substantially similar characteristics to another category of Excluded Accounts and that their status as an
Excluded Account does not frustrate the purposes of the CRS. The Commentary on Section VIII(C)(17)(g) provides
examples of such low-risk jurisdiction-specific Excluded Accounts.
As an example of a low-risk Excluded Account in the context of financial inclusion, Example 5 states that a
Depository Account subject to financial regulation (i) that provides defined and limited services, so as to increase
financial inclusion, (ii) on which monthly deposits cannot exceed USD 1 250 and (iii) for which Financial Institutions
have been allowed to apply simplified AML/KYC procedures consistent with the FATF Recommendations may be a
low-risk Excluded Account.
Provided that electronic money accounts are regulated and meet the requirements of Section VIII(C)(17)(g), they may
be defined as an Excluded Account by the implementing jurisdiction. The above-mentioned example can provide
further illustrative guidance as to when the requirements of Section VIII(C)(17)(g) would be met in the context of
financial inclusion.
8. E-money providers – qualification as a Depository Institution What is the status of electronic money providers for CRS purposes?
No special rules apply to electronic money providers. Like other financial industry participants, they must determine
whether they are a Financial Institution, as defined by the CRS. That determination will depend on the facts and
circumstances. For instance, in order to determine whether an electronic money provider is a Depository Institution,
the analysis must be done with reference to Section VIII(A)(5) and the related Commentary, in particular paragraph 13.
7. Excluded Accounts - low-value electronic money accounts
Under what conditions can electronic money accounts that are Depository Accounts be Excluded Accounts pursuant to Section VIII(C)(17)(g)?
The mere fact that a Financial Account is an electronic money account does not by itself enable that Financial Account
to be specified by a jurisdiction in its domestic law as a low-risk Excluded Account. In order for such Financial
Accounts to be specified as Excluded Accounts under the domestic law of an implementing jurisdiction pursuant to
Section VIII(C)(17)(g), the jurisdiction needs to ensure that the accounts present a low risk for being used for tax
evasion, have substantially similar characteristics to another category of Excluded Accounts and that their status as an
Excluded Account does not frustrate the purposes of the CRS. The Commentary on Section VIII(C)(17)(g) provides
examples of such low-risk jurisdiction-specific Excluded Accounts.
As an example of a low-risk Excluded Account in the context of financial inclusion, Example 5 states that a
Depository Account subject to financial regulation (i) that provides defined and limited services, so as to increase
financial inclusion, (ii) on which monthly deposits cannot exceed USD 1 250 and (iii) for which Financial Institutions
have been allowed to apply simplified AML/KYC procedures consistent with the FATF Recommendations may be a
low-risk Excluded Account.
Provided that electronic money accounts are regulated and meet the requirements of Section VIII(C)(17)(g), they may
be defined as an Excluded Account by the implementing jurisdiction. The above-mentioned example can provide
further illustrative guidance as to when the requirements of Section VIII(C)(17)(g) would be met in the context of
financial inclusion.
- ropulos
- Gaining experience
Post
Re: E-wallets and CRS
“E-money” providers that are governed by the provisions of the European Union Electronic Money Directive (2009/110/EC) (EMD) are not deposit takers for the purposes of the Banking Consolidation Directive (2006/48/EC). Recital 13 to the EMD specifically states that “The issuance of electronic money does not constitute a deposit-taking activity pursuant to Directive 2006/48/EC”, consequently such providers will not fall within the definition of Depository Institution that requires deposits to be accepted in the ordinary course of a banking or similar business.
Official Skrill statement:
"Our Head of Group Regulatory has recently commented on this matter, and I quote for your reference:
From the latest guidance notes, published by HMRC in September, we conclude that UK licensed e-money institutions, like Skrill Limited, will not be subject to the automatic exchange of information by OECD between countries under the Common Reporting Standards.
The CRS cover entities that fall into certain categories of institutions, which include custodial institutions, depository institutions, investment entities and specified insurance companies. There was some uncertainty as to whether or not E-money institutions might be regarded as depository institutions. The latest guidance notes however specifically state that “E-money” providers that are governed by the provisions of the European Union Electronic Money Directive (2009/110/EC) (EMD) are not deposit takers for the purposes of the Banking Consolidation Directive (2006/48/EC). Accordingly such providers will not fall within the definition of depository institution and therefore also not in the scope of the CRS".
I believe that all these statements are based on the interpretation of this:
https://www.gov.uk/government/upload...nformation.pdf
Official Skrill statement:
"Our Head of Group Regulatory has recently commented on this matter, and I quote for your reference:
From the latest guidance notes, published by HMRC in September, we conclude that UK licensed e-money institutions, like Skrill Limited, will not be subject to the automatic exchange of information by OECD between countries under the Common Reporting Standards.
The CRS cover entities that fall into certain categories of institutions, which include custodial institutions, depository institutions, investment entities and specified insurance companies. There was some uncertainty as to whether or not E-money institutions might be regarded as depository institutions. The latest guidance notes however specifically state that “E-money” providers that are governed by the provisions of the European Union Electronic Money Directive (2009/110/EC) (EMD) are not deposit takers for the purposes of the Banking Consolidation Directive (2006/48/EC). Accordingly such providers will not fall within the definition of depository institution and therefore also not in the scope of the CRS".
I believe that all these statements are based on the interpretation of this:
https://www.gov.uk/government/upload...nformation.pdf
- Pistu
- Gaining experience
Post
Re: E-wallets and CRS
That guidance was unfortunately revoked by the issuer authority. That's my concern. Furthermore, that was only a guidance and only for the UK. PP is seated in Luxembourg as we know.
- ropulos
- Gaining experience
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Re: E-wallets and CRS
CRS compliance require more steps and questions to the clients... if they don't ask they arent CRS compliant ... so they don't partecipate today... tomorrow we dont know
- ropulos
- Gaining experience
- vivekananda
- Gaining experience
Post
Re: E-wallets and CRS
Changes to the Skrill Terms and Conditions from januar 2018
https://www.skrill.com/en/footer/terms-conditions/skrill-account-terms-of-use-new/?v=1&utm_source=newsletter&utm_medium=email&utm_campaign=
5) Processing your personal information
We have clarified that by using the Skrill Services, you give us consent to process your personal information to the extent necessary to provide the services to you. You may withdraw this consent at any time by closing your Skrill Account. Please be aware that even if you take such steps, we will still process your personal information provided we have lawful grounds to do so, such as complying with applicable laws and regulations or if we provide other services to you. For more information on how we use your personal information, please view our Privacy Notice.
hope nothing with CRS
https://www.skrill.com/en/footer/terms-conditions/skrill-account-terms-of-use-new/?v=1&utm_source=newsletter&utm_medium=email&utm_campaign=
5) Processing your personal information
We have clarified that by using the Skrill Services, you give us consent to process your personal information to the extent necessary to provide the services to you. You may withdraw this consent at any time by closing your Skrill Account. Please be aware that even if you take such steps, we will still process your personal information provided we have lawful grounds to do so, such as complying with applicable laws and regulations or if we provide other services to you. For more information on how we use your personal information, please view our Privacy Notice.
hope nothing with CRS
- thorocska
- Gaining experience
Post
Re: E-wallets and CRS
And for Neteller too.vivekananda wrote: Changes to the Skrill Terms and Conditions from januar 2018
https://www.skrill.com/en/footer/terms-conditions/skrill-account-terms-of-use-new/?v=1&utm_source=newsletter&utm_medium=email&utm_campaign=
5) Processing your personal information
We have clarified that by using the Skrill Services, you give us consent to process your personal information to the extent necessary to provide the services to you. You may withdraw this consent at any time by closing your Skrill Account. Please be aware that even if you take such steps, we will still process your personal information provided we have lawful grounds to do so, such as complying with applicable laws and regulations or if we provide other services to you. For more information on how we use your personal information, please view our Privacy Notice.
hope nothing with CRS
What does it mean "account information services providers"?"1) Account Information Service Providers (third party providers)
You will be able to allow authorised account information services providers to access your account and make payments on your behalf. However, we reserve the right to choose how such third parties can access your account and not to allow access if we do not believe they have the appropriate consent."
- desmodromico
- Gaining experience
Post
Re: E-wallets and CRS
I understand that if they are going to provide information to the countries, no? as of 2018.