Faq Type List

What is digital wallet ?

Digital wallet is a online stored multi currency digital currency account , you can send and receive money instantly and securely, anywhere in the world.Digital wallet allows money transfer fast, simple and secure way to instantly send money online. Available through your free atw digital payment account, Money Transfer with ATW EXCHANGE is an alternative to traditional methods of sending money that millions of consumers in more than 200 countries can have account, add, withdraw and transfer funds to and from other e money service providers , banks, cards merchants and other atw customers. When you sign up for an account you gain access to a host of services, including: Epay card, remit2world card, atwpay etc

What is Remit2world Remittance Card?

The ATW Remit2world Remittance Card is the most convenient way of to send money across the world to the designated country in local currency. It is a local currency denominated Visa card on which the remitter can send money to beneficiary. It allows the cardholder to withdraw cash at any ATMs and make payments at merchant establishments.

Is it safe to pay via ATW?

Paying online with ATW cards and digital accounts are safe because, like paying in cash, no personal details, such as bank account or credit card information, ever have to be entered. However, it is still important to look after your card PINs and to follow our tips for paying safely online. These will help save you from any nasty surprises..

For a customer which is a company, do we need to identify and verify directors who purport to act on behalf of the company to operate the account?

Paying online with ATW cards and digital accounts are safe because, like paying in cash, no personal details, such as bank account or credit card information, ever have to be entered. However, it is still important to look after your card PINs and to follow our tips for paying safely online. These will help save you from any nasty surprises..

Do FIs need to verify the address of beneficial owners, directors or persons purporting to act on behalf of a customer including account signatories?

FIs should obtain the address of a beneficial owner and adopt a risk-based approach to determine the need to verify the address. and For directors and persons purporting to act on behalf of a customer, in high-risk situations, consideration may be given to obtaining and taking reasonable measures to verify the addresses of directors and persons purporting to act on behalf of the customer.

Can verification of identity be completed in a period of time longer than that specified in paragraph 4.7.8?

The time periods provided in paragraph 4.7.8 are what the RAs consider as reasonable timeframes for completing verification. Where verification takes longer in individual cases, FIs should be prepared to justify the rationale and/or reasons and appropriately document the processes undertaken.

Do FIs need to record the names of all directors of a customer who is eligible for SDD?

FIs should record the names of all directors and verify the identity of directors on a risk-based approach whether or not the customer is eligible for SDD.

Does public body cover state-owned enterprises (SOE)? Can a subsidiary of a SOE be subject to SDD?

SDD may be applied to state-owned enterprises fully owned by a government of an equivalent jurisdiction. Where the enterprise is only partially owned by a government, SDD would apply only to the part of the enterprise owned by the government. For the part not owned by the government, FIs should identify and take reasonable measures to verify the identities of beneficial owners along that ownership chain.

Does simplified customer due diligence apply to a wholly/partially owned subsidiary of a listed company?

SDD may be applied to the customers set out in section 4 of the Schedule 2 to the AMLO which do not include wholly/partially owned subsidiaries of a listed company. However, the FI is not required to identify or verify the beneficial owners of the listed company in the ownership chain of the wholly/partially owned subsidiary. For partially owned subsidiaries, the FI should still identify and take reasonable measures to verify the identity of beneficial owners in the ownership chain that are not connected with the listed company.

Do the special requirements under section 10 of Schedule 2 to the AMLO apply to PEPs from Hong Kong, Macau and Taiwan?

The special requirements under section 10 of Schedule 2 to the AMLO apply to PEPs in a place outside the People's Republic of China. However, domestic PEPs may also present a high risk situation where EDD should be applied. FIs should apply a risk based approach to determine whether to apply EDD measures in respect of domestic PEPs. Domestic PEPs include those from Mainland China, Hong Kong, Macau and Taiwan.

If a previously obtained identity document such as passport of a customer is expired, does the FI need to re-verify any aspect of customer identification by obtaining a current identity document?

FIs do not need to re-verify any aspect of customer identification just because of the expiry of a previously obtained identity document. According to paragraph 4.7.12 of the Guideline on Anti-Money Laundering and Counter-Terrorist Financing, once the identity of a customer has been satisfactorily verified, there is no obligation to re-verify identity unless in specified circumstances; however, FIs should take steps from time to time to ensure that the customer information that has been obtained for the purposes of complying with the requirements of sections 2 and 3 of Schedule 2 of the AMLO are up-to-date and relevant.

Do FIs need to carry out any applicable new CDD measures arising from the requirements under section 2 of Schedule 2 to the AMLO on accounts opened prior to 1 April 2012? If so, is there any required deadline for bringing all pre-existing accounts up to the AMLO requirement?

FIs are not required to perform the CDD measures prescribed in section 2 of Schedule 2 to the AMLO on pre-existing customers except in the circumstances specified in section 6(1) of Schedule 2 to the AMLO.

The arrangement for allowing FIs to rely on specified intermediaries under section 18(3)(a) of Schedule 2 to the AMLO to carry out CDD measures will expire 3 years after the implementation of the AMLO. Should FIs cease to use those intermediaries to carry out CDD measures?

The provision of a 3-year period for reliance on specified intermediaries under section 18(3)(a) of Schedule 2 of AMLO is to allow time for the establishment of a formal AML regulatory regime for non-financial businesses and professions. FIs may continue to rely on these intermediaries within the 3-year period up to 31 March 2015. FIs should review the reliance relationship concerned afterwards taking into account the development of the AML regulatory regime for these businesses and professions.

For cases of unsuccessful application for business, is the FI concerned required to retain the identification records and documents in relation to the unsuccessful applicants?

Under the AMLO, there is no requirement for the FI to maintain records and documents involving unsuccessful applicants. This, however, does not preclude the FI from retaining the relevant records and documents in order to meet its other statutory obligations.

With reference to section 22(1)(b) of Schedule 2, where a bank incorporated in Hong Kong has a subsidiary that carries on a securities or insurance business outside Hong Kong (or vice versa), will section 22 apply to such a subsidiary i.e. is the subsidiary regarded as carrying on the same business as a financial institution in a place outside Hong Kong?

It should be noted that section 22(1)(b) of Schedule 2 states the same business as an FI and not the same business as the FI. Therefore, so long as the overseas subsidiary carries out the business as any type of FI (not necessarily as the same type of the business of the parent company), then this provision will apply.

What is JFIU's SAFE Approach alluded to in paragraph 7.12 of the Guideline?

The SAFE Approach recommended by the Joint Financial Intelligence Unit is an effective systemic approach to identify suspicious financial activity which involves the following four steps: Screen the account for Recognition indicators of a suspicious indicators: indicator or (a) Step one: suspicious activity (b) Step two: Ask the customer appropriate questions Find out from the customers information already known when records: deciding (c) Step three: Review if the (d) Step four: apparently suspicious activity is to be expected Evaluate all the above information: Is the transaction suspicious? FIs should refer to JFIUs website for details, which may be updated from time to time. FIs are reminded to browse the website of the JFIU for the latest information.

Would the Guideline on Anti- Money Laundering and Counter-Terrorist Financing (Guideline) supersede the Guidance Note on Prevention of Money Laundering and Terrorist Financing?

The Guideline supersedes the current Guidance Note on Prevention of Money Laundering and Terrorist Financing effective from 1 April 2012.

Is address proof required for verification of the identity of a beneficiary?

Insurance institutions should obtain the residential address (and permanent address if different) and adopt a risk-based approach to determine the need to take reasonable measures to verify the address.

When an existing policyholder purchases a new insurance policy and if we have reasonable belief to trust that the identification information of the policyholder has not been changed, is it necessary for us to obtain the same set of verification proof again (e.g. ID card copy / address proof)?

Once the identity of a policyholder has been satisfactorily verified, there is no obligation to re-verify identity unless in specified circumstances; however, insurance institutions should take steps from time to time to ensure that the policyholder information that has been obtained for the purposes of complying with the requirements of sections 2 and 3, Schedule 2 of the AMLO are up-to-date and relevant

For a customer which is a company, do we need to identify and verify directors who purport to act on behalf of the company to operate the account?

Paragraph 4.4 of the Guideline specifies the identification and verification requirements for persons purporting to act on behalf of the customer. These requirements apply whether the persons purporting to act on behalf of the customer are directors of the company or not

When was the Anti-Money Laundering and Counter-Terrorist Financing (Financial Institutions) Ordinance, Chapter 615, implemented?

The Anti-Money Laundering and Counter-Terrorist Financing (Financial Institutions) Ordinance (“AMLO”), Chapter 615, was passed on 29 June 2011 and came into operation on 1 April 2012.

Do the special requirements under section 10 of Schedule 2 to the AMLO apply to PEPs from Hong Kong, Macau and Taiwan?

The special requirements under section 10 of Schedule 2 to the AMLO apply to PEPs in a place outside the People’s Republic of China. However, domestic PEPs may also present a high risk situation where EDD should be applied. FIs should apply a risk based approach to determine whether to apply EDD measures in respect of domestic PEPs. Domestic PEPs include those from Mainland China, Hong Kong, Macau and Taiwan.

Financial Action Task Force (FATF) website link

Financial Action Task Force (FATF)

Hong Kong Monetary Authority (HKMA) website link

Hong Kong Monetary Authority (HKMA)

Joint Financial Intelligence Unit (JFIU) website link

Joint Financial Intelligence Unit (JFIU)

What is Bitcoin ?

Understanding Bitcoin: Digital currencies or Virtual currencies such as Bitcoin are attracting greater attention and scrutiny as more and more interest is getting generated. Bitcoin was launched in 2009 by a person (or group of persons) known by the pseudonym of Satoshi Nakamoto. Bitcoin is a cryptocurrency and a payment system. The system is peer-to-peer and transactions take place between users directly, without an intermediary. These transactions are verified by network nodes and recorded in a public distributed ledger called the blockchain,which uses bitcoin as its unit of account. Since the system works without a central repository or single administrator, the U.S. Treasury categorizes bitcoin as a decentralized virtual currency. The idea behind the launch of Bitcoin was to have a digital currency that can be used for payments across various ecommerce platforms without the relying on financial intermediaries, and that will not be affected by supply-side problems—which is of printing more and more of such currencies—currently affecting fiat money. In essence, Bitcoin is a decentralized peer to peer payments network and a virtual currency that essentially operates as online cash. Unlike traditional currencies, which are issued by central banks, Bitcoin has no central monetary authority. The first question which comes to mind while using Bitcoin is why should one use Bitcoin when one can use fiat currencies such as rupee, dollar or euro? Bitcoin is still a new and fluctuating currency that is not accepted by many merchants, so the use of Bitcoin may seem mostly experimental. But using Bitcoins has advantages—it is a truly global currency, the transaction costs are lower and it provides liquidity in times of capital controls and high inflation. Like all digital currencies and platforms that try to keep transactions to be used across the Internet anonymous, Bitcoins, too, have disadvantages such as online theft and hacking, criminal uses and volatility. Historically, money has two functions—to act as a medium of exchange and a store of value. After the advent of banking and financial institutions in the medieval period, money added a third function as well—credit creation, i.e., the transfer of money from one who has it to one who needs it. This has been made possible by the evolution and innovations in banking, which include: In many countries, the use of debit/credit cards has become so widespread that their volume has overtaken or entirely replaced cheques and, in some instances, cash transactions. The development of debit cards, unlike credit cards and charge cards, has generally been country specific resulting in a number of different systems around the world, which were often incompatible. Since the mid-2000s, a number of initiatives have allowed debit cards issued in one country to be used in other countries and allowed their use for internet and phone purchases. i) Cashless intra-bank and inter-bank transactions, thus reducing the need for coins and other such resources. ii) Fractional reserve banking (the policy to hold a fraction of loans as reserves against loss-making provision). iii) Central bank monopoly on note creation, as this induced faith in the currency in use and imparted stability in the system and thus has made fractional reserve banking possible. In modern times, credit creation has become a very important aspect of monetary phenomenon, as is evident from the way Marshallian K is increasing (it is a ratio of monetary base to nominal gross domestic product). For any virtual currency like Bitcoin to establish itself as an alternative to fiat currencies, all three functions of money are equally important. Supply growth Bitcoins per block (approximately every ten minutes) until mid 2020, and then afterwards 6.25 bitcoins per block for 4 years until next halving. This halving continues until 2110–40, when 21 million bitcoins will have been issued. Regulatory concerns Regulators such as RBI cautions users of Virtual Currencies against Risks The Reserve Bank of India has today cautioned the user's, holders and traders of Virtual currencies (VCs), including Bitcoins, about the potential financial, operational, legal, customer protection and security related risks that they are exposing themselves to. The creation, trading or usage of VCs including Bitcoins, as a medium for payment are not authorised by any central bank or monetary authority. No regulatory approvals, registration or authorisation is stated to have been obtained by the entities concerned for carrying on such activities. The Reserve Bank has mentioned that it has been looking at the developments relating to certain electronic records claimed to be “Decentralised Digital Currency” or “Virtual Currency” (VCs), such as, Bitcoins, litecoins, etc,. This makes it impossible for regulators and other governing authorities to ignore virtual currencies such as Bitcoin, which, for the first time, make it possible to have a unified medium of exchange on Internet. Such virtual currencies can and will greatly influence people’s behaviour, both socially as well as economically, in the future in the same way as introduction of physical money had done in the past. Therefore, it is imperative for governments and policymakers to have a critical examination and study of virtual currencies, their impact on greater economy and society, and to be prepared for any eventuality brought by technological disruptions. This will be the first step in understanding and providing the stewardship for ushering the society into the next age. The idea of virtual currencies like Skrill, Neteller, AtwPay and Bitcoin is catching up. However, the legal status of Bitcoin is unclear, as is evident from the fact that recently big governments have started to warn people against the use of digital currencies, since money is an integral part of how a society operates and a stable monetary system is one of the pillars of functioning of a stable society. At the same time, given the technological evolution, the idea of a virtual currency that can be used in a virtual economy, in which the current human generation is moving, has also got a fundamental case in its favor. Bitcoin itself may go bust due to resistance from various governments and technological flaws but the chances are that some form of digital money will make a lasting impression on the financial landscape. Given the socioeconomic impact and implications, this calls for a greater understanding and development of necessary frameworks and institutions on part of policymakers and governments to deal with this phenomenon. Other side story, Bitcoin can valued as diamonds as their is limit for Bitcoin in circulation. As of now, Bitcoin has weathered quite a number of significant price adjustments since 2011. These adjustments resemble traditional speculative bubbles: over optimistic coverage of Bitcoin prompts waves of novice investors to pump up Bitcoin prices. The exuberance reaches a tipping point, and the value eventually plummets. The fluctuating value makes holding Bitcoins tough for people who want to use this particular virtual currency as a store of value. The value of Bitcoin. Due to a limit on production, there will only be a maximum of 21 million Bitcoins in circulation – and this allows them to retain a real value and maintain themselves as a legitimate currency. At the time of writing, one Bitcoin was worth around USD $575.

What Reserve Bank of India(RBI) says about Bitcoin.

RBI cautions users of Virtual Currencies against Risks, issued a circular Date : Dec 24, 2013.



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