New and Emerging Payment Platforms, Including Mobile,Virtual Currency and Cards and Cryptocurrencies, and the Roleof Prepaid in the Equation: Legal, Regulatory, and ComplianceConsiderations for New Technologies and Evolving Products
Vice President, Senior Associate General Counsel
Fellow – Berkman Center for Internet & Society
Chief Payments Counsel
Uber Technologies, Inc.
Chief Technology Officer
Joseph Vaughn Perling
Chief Security Officer
General Manager, Global Payments
Advisor – Ripple Labs
Co-Founder – Global ID Framework
Interim CEO, General Counsel & Chief Compliance Officer
Skrill USA, Inc.
Chief Compliance Officer
Christopher T. Brown
Christopher T. Brown, Attorney at Law, PLLC
Virtual Currency as a Whole
- The market and market expectations
- Development of virtual currency service providers
- FinCEN and virtual currency, and prepaid access
- Money Transmitter Risks
- Scope of BSA/AML compliance and banking requirements for virtual currency customers
- U.S. regulation and outreach including NY Dep’t of Financial Services (new licensing regime?)
- Recent enforcement actions
- Development in international regulation
- Are programs involving points, minutes, credits, miles, swords or in-game currencies subject to the prepaid access rule or money transmitter regulations?
- What does it mean to have virtual currency in prepaid world? Is it a bank account? Is it a prepaid account? Is it Bitcoin?
- What is the difference between Bitcoin wallet and prepaid wallet?
- Will there be a prepaid card specifi cally for Bitcoin?
- Linking Bitcoin into major payment networks like Visa and Mastercard
- Converting Bitcoin to cash
- Using the block chain model to validate and track Bitcoin: Monetizing transactions; How consumers can limit and control data
- Virtual prepaid cards?
- Who are the stakeholders and what are their incentives?
- Bank-based versus non-bank business models
- Preparing for the evolving state and federal regulatory paradigms and their impact on emerging payment systems
- AML, consumer protection, and safety & soundness issues of novel business models
- The CFPB, the Durbin Amendment, FCC involvement, state money transmitter licensing, and more compliance issues
- FinCEN, and federal prudential regulation
- Data security considerations: Determining if you must be PCI compliant
- Privacy and marketing considerations
Virtual Currency and the Intersection With Prepaid
Mobile and Other New and Emerging Payment Systems
Payment processing on mobile devices… Prepaid mobile… Facebook credits… Social media environments as payments platforms… the list goes on. This part of the session will feature analysis of what is currently real and could reasonably become mainstream, or at least commercially viable, what are the “Next Big Things”, and how to determine the regulation that applies to them given that technologies are developing quicker than regulation can adapt and compliance obligations and policies are overlapping and still evolving. Topics include: