1、Rod FrancisLilian HeJacky TamCOMBATING DIGITAL-ERAPerspectives on digital payments and payment service providers Oliver Wyman2Combating Digital-era Money Laundering And Terrorism FinancingEXECUTIVE SUMMARYAs digital payment volumes and penetration rates continue to grow fast,digital payment service

2、providers(PSPs)have become important players in the global financial ecosystem.However,this sector is still considered to be a weak link in combating money laundering and terrorist financing.Digital PSPs face multi-fold challenges.On the one hand,they often have to deal with a more fragmented regula

3、tory landscape compared to traditional financial institutions(FIs),such as banks,for which regulators impose different licensing and regulatory oversight requirements.As a result,digital PSPs are more vulnerable targets for criminals who have the capabilities to exploit this“regulatory arbitrage”.On

4、 the other hand,compared to the business models of traditional FIs,the digital payment and banking model presents unique risks and challenges that require further attention.These include the following:the rising resource and customer experience challenge to handle high-volume,short-turnaround-time t

5、ransaction monitoring;the increasing challenge to detect and combat digitally savvy“money mules”;the evolving“merchant risks”associated with ecommerce payments;AML/CFT compliancy in the“white labeling”business model;and the risks associated with cryptocurrency-related payment transactions.In respons

6、e,regulators globally have collectively stepped up their scrutiny of the money laundering and terrorism financing risks of PSPs with various actions.These have added pressure not only to digital PSPs in terms of their financial and reputational risks,but also to players in the broader financial ecos