Tuesday, March 24, 2009

BSP Circular 649: E-Money/E-Wallet Regulation

A few months ago I received a draft of the proposed BSP Circular on the regualtion of e-Money and was released last March 9 with effectivity 15 days later

Circular 649 provided the regulatory framework over the fast-growing electronic money business in the Philippines to provide protection for consumers and to promote innovations in fund transfer mechanisms that benefit Filipino consumers. The Circular prescribed the minimum requirements for each Electronic Money Issuer (EMI) category to ensure that the risks inherent in e-money business are mitigated and that EMIs adhere to prescribed levels of safety, security and soundness. Provisions include the following:

a. EMIs shall put in place a system to maintain accurate and complete record of e-money transactions and other pertinent information

b. E-money shall only be redeemed at face value. It is not considered a deposit, hence, it is not insured with the Philippine Deposit Insurance Corporation;

c. E-money instruments shall be subject to aggregate monthly load limit of PhP100k

d. EMIs shall ensure compliance with applicable requirements of the Anti-Money Laundering laws, rules and regulations (e.g. (Know Your Customer, KYC and Suspicious Transaction Reports (STR))

e. EMI's should be stock corporation with capitalization of PhP100M

Circular 649 is for the protection of the public against fly-by-night e-money companies.

Complete text of BSP Circular Number 649 can be downloaded from BSP official website.


  1. I wonder if EMI's are prevented by this law to put an average daily balance requirement since it is not considered a deposit?


  2. JB, nope. there's nothing in the circular about ADB. only maximum amount of P100k. it will depend on the company. I already received a few inquiries regarding this circular.