Business Impact:
Inadequate and improper customer information may lead to non-compliance with the regulations for electronic payment business such as True Money’s proposal to BOT that requires customer to identify his/her ownership of the opened e-wallets by referring to the citizen ID.
Additionally, the business concept of reviewing and analyzing e-wallet accounts and transactions based on individual account may not comply with the regulatory requirements regarding monitoring and reporting of suspicious transactions to the Anti-Money Laundering Office. In case of suspicious transactions, True Money may not have adequate information for reporting according to the Forml-05-10.
Recommendations for Implementation Priorities: High
Recommendation:
Based on our review, we recommend that policy and/or procedures should be established to assess and classify True Money’s customers based on risks and adequate customer data of each customer class should be classified and collected accordingly.
Additionally, customer data collection procedures should be reviewed and formally established to ensure that adequate and accurate customer information are collected for supporting internal review and analysis, and for reporting to the Anti-Money Laundering Office in case of suspicious transactions (if any in the future).