Overview of Anti-Money Laundering and Combating the Financing of Terrorism
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Table 3.2 Example of the Evolution of Retail Outlets’ Regulation in Brazil, Various Years (continued) Year
Resolution and description
2000
Resolution CMN 2707/00 Limitation on location is lifted. Retail outlets may be located anywhere, regardless of the presence of a bank branch. Resolution CMN 2953/02 – Retail outlets are permitted to analyze identification documents for account opening. – In addition to banks, consumer credit companies are allowed to hire retail outlets. Resolution CMN 3110/03 – All financial institutions are allowed to hire retail outlets. – Subagents are allowed. Resolution CMN 3156/03 – All other CBB-licensed entities are allowed to hire retail outlets. Resolution CMN 3568/2008 – Retail outlets are permitted to offer international transfers on behalf of a financial institution (limited to $3,000 per transaction),a subject to a simple online CBB registration process. Resolution CMN 3654/2008 – The need for previous authorization by CBB for banks wishing to hire retail outlets was lifted. – A financial institution willing to deliver services through retail outlets is required only to register each outlet in CBB’s online system.
2002
2003
2003 2008
2008
Source: CGAP, http://www.cgap.org/gm/document-1.9.42396/Updated_Notes_On_Regulating_Branchless_ Banking_Brazil.pdf. Note: In 2006 in Brazil, 95,000 retail outlets, equipped with point-of-sale and bar-code readers, processed 1.53 billion transactions, valued at $ 104 billion. Seventy-eight percent of those transactions were bill payments and deliveries of government benefits. The remainder included deposits, withdrawals, and loan repayments and disbursements. Six million new accounts were opened in 2006. In Brazil, virtually any entity can be engaged as a retail outlet. The most common types are lottery kiosks, post offices, grocery stores, and other merchants. Banco Central do Brasil has issued comprehensive regulations governing other aspects of the business (particularly to protect consumers), but the lack of prohibitions on who may act as a retail outlet seems to have opened up the field for innovation and allowed rapid growth (GSMA 2008). a. It should be noted that person-to-person services are not available, so this transaction limit relates to mobilebased payments for goods.
Notes 1. As stated by CGAP (Rosenberg 2009), “challenges are intensified by the fact that many services have been widely available for only a short while. As a result, there are no ‘off-the-shelf’ regulatory frameworks that can successfully mitigate risks and address problems in complex and far-reaching branchless banking systems. Nor is there a rich trove of historical data to use in shaping policies.”