13 March 2015, Holland FinTech Meetup - Regulations & Compliance by Van Doorne

Holland FinTech MeetUp Amsterdam

13 March 2015

Regulations & Compliance Opportunities for FinTech

Arno Voerman

FinTech Lawyer

[email protected]

Van Doorne | 2 Holland FinTech MeetUp Amsterdam

Topics

•  Customer Due Diligence •  Customer Authentication •  DNB Background: •  AMLD4 •  PSD 2 •  ECB Recommendations and EBA Guidelines security internet

payments •  eIDAS •  General Data Protection Regulation


Customer Due Diligence

Basic-principles: •  Identification •  Verification of the customer’s identity


Identification

•  Who is the customer?

•  Wwft: identification = the statement of the customer’s identity


Verification

•  Are you really who you say you are?

•  How can you prove it?


Ways to verify

documents, data or information obtained from reliable and independent source


Traditional


Enhanced measures


How?

a.  verifying the customer’s identity on the basis of supplementary documents, data or information;

b.  verifying the authenticity of the documents submitted;

c.  ensuring that the first payment made in connection with the business relationship or transaction is transferred to or from an account the customer has with a credit institution …


Online - Mobile Verification Opportunities for FinTech Solutions


Online - Mobile Verification Opportunities for FinTech Solutions

Be the reliable and independent source!


Strong Customer Authentication

Regulatory Requirement PSPs shall apply (or for cards: support) SCA


also Liability Shift •  No SCA means no proof that transaction was authorized •  Issuer liable towards payer •  PSP that did not apply SCA liable to Issuer


Two factor 2 out of 3: i.  Something you know ii.  Something you have iii.  Something you are


At least one of the elements should be non-reusable and non-replicable (except for inherence), and not capable of being surreptitiously stolen via the internet. The SCA procedure should be designed in such a way as to protect the confidentiality of the authentication data.



Another FinTech opportunity!



Another FinTech opportunity!

Traditional PSPs have to rely on FinTech!


Supervisory themes 2015 •  Complex IT •  Technological Innovation


Contact Arno Voerman FinTech Lawyer t +31 (0)20 6789 250 [email protected] Van Doorne N.V. Amsterdam

13 March 2015, Holland FinTech Meetup - Regulations & Compliance by Van Doorne

Economy & Finance

Transcript of 13 March 2015, Holland FinTech Meetup - Regulations & Compliance by Van Doorne