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2.1.4. Global Regulatory Gaps

Effective from 1/8/2022

Countries take a variety of approaches to regulating the Payment Sector and there is no one widely accepted classification of participants. As a result, two regulators in two different jurisdictions may subject a single company to very different requirements based on each jurisdiction’s regulatory framework. The company may be regulated as a financial institution in one jurisdiction, and thus subject to AML/CFT requirements, but treated as a tech company in another with no requirement to apply preventive measures. Companies may provide services to customers in a given country without being regulated in that country at all. Even where Payment Sector participants are fully regulated and subject to stringent AML/CFT requirements, supervisors’ expectations for this sector may be lower than for traditional financial institutions such as banks. And participants, as relatively new market entrants, may lack the experience, expertise, or commitment to apply fully effective preventive measures. These entities may be less able to protect themselves and their partners, and thus vulnerable to abuse by illicit actors.