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AML & Financial Services Regulatory

Asia Pacific: PayNow-PromptPay/PromptPay-PayNow Linkage White Paper

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In collaboration with the Monetary Authority of Singapore (MAS), Bank of Thailand (BOT), bank participants and operators, we are pleased to present this white paper on the project to link Singapore’s PayNow and Thailand’s PromptPay fast payment systems (PPPN Linkage).

Glean highlights of the technical, operational, commercial and governance issues addressed by the participants in the PPPN linkage, which include: 

  • anti-money laundering
  • sanctions screening
  • data usage
  • redundancy practices

This paper seeks to promote a better understanding of the key considerations for establishing cross-border linkages between two or more national fast payment systems, thereby paving the way for national authorities to pursue more of these linkages in the future.

While supporting the coordination of the project, Baker McKenzie’s Singapore and Thailand offices advised on and drafted the documentation for the legal and governance framework. This being a novel and unprecedented cross-border initiative, for which there were no direct precedents, careful consideration of the legal and regulatory issues was required and novel solutions were necessary, such as a unique governance model. This needed to be scalable for new participants and new jurisdictions to join in the future and, by being based on common principles, capable of being mirrored and adapted to similar arrangements with other countries.

About the PPPN Linkage White Paper

This white paper outlines how this first-of-its-kind linkage was conceived and developed by the MAS and the BOT, working closely with industry partners in both countries. The PPPN linkage represents a first step toward a broader vision of unlocking the multilateral connectivity of countries’ fast payment systems. This will help establish a comprehensive cross-border transfer network to enable customers in participating countries to make fast and secure cross-border transfers via their mobile phones or internet devices at a competitive cost.

PromptPay-PayNow Linkage White Paper

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At the 2021 Singapore FinTech Festival Showcase Stage, Ken Chia and Kullarat Phongsathaporn provide an overview of the PayNow-PromptPay/PromptPay-PayNow Linkage and its impact on the ASEAN e-payment market. They also share their insights and key takeaways from co-leading the project. Ken is a principal from Baker McKenzie Wong & Leow and Kullarat is a partner from Baker McKenzie Thailand.

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Author

Jiro Toyokawa heads the Firm's Corporate/M&A practice group in Tokyo and he has over 20 years of experience in legal practice. He has been listed as a leading individual in Japan for Corporate/M&A in Chambers Asia-Pacific for a decade (2010-2020). Prior to joining Baker McKenzie, he was a partner at Linklaters.

Author

Karen Man is a partner in Baker McKenzie’s Financial Services group, leading the non-contentious Financial Services Regulatory practice. Her clients include global, Chinese and local banks, fund managers, brokers/dealers, money service operators and fintech firms. Karen is admitted to practice in Hong Kong, the UK, and Australia.

Author

Ken Chia is a member of the Firm’s IP Tech, International Commercial & Trade and Competition Practice Groups. He is regularly ranked as a leading TMT and competition lawyer by top legal directories, including Chambers Asia Pacific and Legal 500 Asia Pacific. Ken is an IAPP Certified International Privacy Professional (FIP, CIPP(A), CIPT, CIPM) and a fellow of the Chartered Institute of Arbitrators and the Singapore Institute of Arbitrators.

Author

Stephanie Magnus co-heads the Asia Pacific Financial Institutions Group and heads up the Financial Services Regulatory Practice Group in Singapore. Stephanie is ranked Band 1 for FinTech in Singapore by Chambers FinTech 2020. She is also ranked as a Leading Individual for Financial Services Regulatory: Local Firms in Singapore by Legal 500 Asia Pacific 2020. She is recognised as a leading lawyer for Banking & Finance: Regulatory in Singapore by Chambers Asia Pacific and Chambers Global 2020. Stephanie was quoted in Chambers Asia Pacific for her "timely, practical and business-oriented" advice, with a "deep understanding of the regulatory regime." She is also recognised as "very business-savvy and brilliant every time," and is admired for her "very strong grasp of the legal issues from both a technical and practical perspective."

Author

Kullarat is a partner in the Financial Services Practice Group at Baker & McKenzie Ltd. She is recognized in banking and finance, securities, derivatives and structured finance, FinTech, e-payment, venture capital, exchange control, anti-money laundering / counter terrorism financing, and financial and tech-related laws and regulations. She leads the FinTech team at the Bangkok office. Kullarat has assisted the largest and fastest growing companies in and outside Thailand on matters related to the use of technology and digitalization in financial markets, including both money and capital markets.

Author

Thinawat Bukhamana joined Baker McKenzie in 1989 after working as a legal analyst for the merchant banking division of Bangkok Bank Public Company Limited. He became a partner in 1995, and currently heads the Bangkok office’s Banking & Finance Practice Group. In addition to his legal practice, Mr. Bukhamana serves as a visiting lecturer at Bangkok’s Chulalongkorn University.

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