Customer Due Diligence Obligations and Mobile-Money Services
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5. Of course, there are limits to the clarity that the FATF can provide. Its standards have universal application. Given the complexity of the questions and the fact that risks and risk appetites may differ from country to country, the FATF can and should give only broad, principled guidance. 6. According to recent surveys of customers using branchless channels in Brazil, India, Kenya, the Philippines, and South Africa, today’s customers are primarily not the unserved majority—although the unbanked and the poor are starting to use branchless channels. See Pickens, Porteous, and Rotman (2009). 7. However, there is great demand for cross-border payments because of the need to cheaply remit money to relatives back home. See Solin and Zerzan (2010). 8. In South Africa, for example, Exemption 17 eliminates the need to obtain and verify the residential address details on low-value, low-risk accounts. 9. The features of a Mzansi account reflect the following risk parameters: type of customer: the product is only available to natural persons; nationality of the customer: the customer must be a South African citizen or resident; limited to domestic transactions: cross-border transfers are not permissible, except for point-of-sale payments or cash withdrawals in the Rand Common Monetary Area; monetary limits: there is a daily limit on withdrawals, transfers, and payments. A capped monthly limit also applies. In addition, there is a limit on the balance that may be maintained in this account. The customer is restricted from maintaining more than one such account at an institution (see FATF/ESAAMLG [2009], p. 100). It is important to note that the FATF/ESAAMLG evaluators had no negative comments on this exemption. 10. The center was the Wall Street Exchange Center of Dubai, from which the financier wired $5,000 to the United States. 11. The hijackers also used multiple aliases. 12. As set forth in the directive, member-states may allow the institutions and persons covered by the directive not to apply CDD in some particular circumstances (Article 11, para. 2). As for e-money issuers, this exemption is permitted (1) if the maximum amount stored on a device that cannot be recharged does not exceed €150 or (2) if a limit of €2,500 is imposed on the total amount transacted in a calendar year on a device that can be recharged (Article 2, para. 5(d). CDD may also be skipped for any other product or transaction representing a low risk of ML/TF (Article 2, para. 5). The full text of the directive may be viewed at http://eur-lex.europa.eu/LexUriServ/ LexUriServ.do?uri=OJ:L:2005:309:0015:0036:EN:PDF. 13. The European directive seems to be a good example of a bill that gives policy makers some flexibility when it comes to applying or eliminating CDD obligations.