Approaches to Regulating E-Money Market in the Eurasian Economic Community: Comparative Analysis

Abstract

The goal of this paper is to identify relevant (general and particular) elements of electronic money regulation in Russia, Kyrgyzstan, Kazakhstan, Belarus and Armenia. For the purposes of comparative analysis, the paper first introduces the methodology by outlining such factors as the legal status of electronic money issuers (including prudential requirements), differentiation of customer due diligence requirements in e-money systems, e-wallet usage rules, and division between the issuing and e-money transfer functionalities. Second, these factors are analyzed for each country, based on current regulatory acts. Finally, synthetic conclusions regarding major regional trends for regulation of e-money as a financial service are made. In most countries, e-money issuers are subject to licensing for the purposes of financial stability. Yet, approaches to differentiating functions of e-money actors vary across countries: in some of them, regulation recognizes “e-money operators” which transfer e-money but do not issue it. However, actual effects of this differentiation merits additional research. Almost all countries have implemented remote (simplified) identification which underlines the role of e-money as a “simplified” product aimed at financial inclusion. All countries except the Republic of Belarus and the Kyrgyz Republic still recognize non-personified electronic wallets. The research confirms that electronic money is still a specific instrument aimed at supporting financial inclusion and satisfying demand for instant cashless payments. More research is required to assess the actual effects of different regulatory approaches on the development of the e-money market.

Keywords

• regulation of e-money
• eurasian economic community
• types of identification
• e-money issuers
• agents for providing services in the e-money system
• e-money operators
• e-money institutions
• e-wallets
• prepaid cards