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AML & Financial Services Regulatory

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Baker McKenzie’s Global Financial Services Regulatory Guide has been fully revised for 2024 and covers 35+ jurisdictions worldwide, making it our most expansive edition to date. The Guide acts as a quick reference tool when distributing financial products and offering services into new markets, providing a comprehensive summary of regulations applicable to banks and other financial services companies around the world. This expanded edition includes the rapidly growing area of cryptoassets, AML and CFT supervisors, and the extension of regulation to critical third-party outsourcers. Given the pace of regulatory change in this domain, staying informed is critical for market participants. Baker McKenzie is exceptionally well-positioned to simplify the complexity and provide expert guidance.

The Primer on Fintech in the Philippines covers legal and regulatory issues and considerations related to the financial technology sector in the Philippines, including data privacy and cybersecurity considerations, anti-money laundering compliance, and the business challenges that the sector may face.

On 19 July 2024, pursuant to the National Payment Systems Act, the Bangko Sentral ng Pilipinas (BSP; Philippine Central Bank) issued Circular No. 1198, Series of 2024 on the Regulatory Framework for Merchant Payment Acceptance Activities (MPAA). The regulatory framework aims to establish standards and best practices to safeguard customer funds and protect merchants’ rights when dealing with operators of payment systems (OPS) engaged in MPAA.
BSP Circular No. 1198 took effect on 8 August 2024, 15 days after the circular’s publication in a newspaper of general circulation.

On 26 July 2024, the Monetary Authority of Singapore (MAS) updated the Guidelines on Licensing for Payment Service Providers (PS-G01), which became effective on 26 August 2024. These changes are applicable to current and future Standard Payment Institutions (SPIs) and Major Payment Institutions under the Payment Services Act (PSA).
The updates can be divided into those that relate to (i) the application process for a new MPI or SPI license or a variation of an existing license under the PSA; and (ii) those that relate to ongoing business conduct.

On 26 July 2024, the Monetary Authority of Singapore (MAS) updated the Guidelines on Licensing for Payment Service Providers (PS-G01), which became effective on 26 August 2024. These changes are applicable to current and future Standard Payment Institutions (SPIs) and Major Payment Institutions under the Payment Services Act (PSA).
The updates can be divided into those that relate to (i) the application process for a new MPI or SPI license or a variation of an existing license under the PSA; and (ii) those that relate to ongoing business conduct.

On 29 August 2024, the Central Bank of the Republic of Argentina (BCRA, after its Spanish abbreviation) issued Communication “A” 8099, which sets forth the implementation of the foreign exchange benefits provided by the Incentives Regime for Major Investments (RIGI, after its Spanish abbreviation).

AAOIFI released a Sukuk exposure draft in early November 2023 in response to a rapid increase in the use of Sukuk and the development of the market in the past decade. A key change in the draft standard is that it requires an actual transfer of ownership to occur under an Ijara Sukuk investment. It is unclear what the appetite will be for asset-backed Ijara Sukuk if the standards are tightened and whether, at this stage, the standard will pass.

Recently, the Egyptian Financial Regulatory Authority has introduced a series of groundbreaking regulations to create a robust framework for the accreditation, issuance, listing, delisting, and trading of carbon emissions reduction certificates. On 13 August 2024, the FRA officially launched the first regulated voluntary carbon market. These steps underscore Egypt’s dedication to sustainable development and its ambition to lead the carbon trading market in the Middle East and Africa.

In a recent circular issued on 7 August 2024, the Central Bank of Egypt (CBE) mandated Egyptian banks to open non-resident bank accounts for foreign customers not residing in Egypt. This directive aims to expand the access by foreigners to a range of banking services allowing them to benefit from the same while ensuring compliance with account opening regulations, KYC requirements and anti-money laundering laws and regulations.
The CBE emphasized the need for such a decision and noted that denying non-residents the opportunity to open accounts could heighten the risks associated with financial transactions conducted outside the regulated market and have adverse effects on the reputation of banks operating within the Egyptian banking sector.

As a continuation of the 2025 Payment System Blueprint, which led to the successful implementation of key initiatives such as (i) the continued domestic and cross-border implementation of the Quick Response Code Indonesia Standard (QRIS), (ii) the National Open API Standard (SNAP), (iii) the real-time payments infrastructure (BI-FAST), and (iv) regulatory, licensing, and supervisory reforms, Bank Indonesia has now issued the 2030 Blueprint of Payment System (“2030 Blueprint”).
The key objectives of the 2030 Blueprint are to ensure the payment system’s resilience against economic and technological challenges and to integrate various payment systems, creating a more efficient and cohesive structure.