16:59 26.04.2011 - posted by
Most of the well-known proposals on this account are based on the idea of direct interaction with e-money payment systems (PS) for the purpose of monitoring of transactions carried out in the Internet and client identification.
In my opinion, this approach will lead to creation of an expensive and ineffective system of control:
* The number of transactions of e-money is great and diversified,
* Transactions of e-money are carried out as in the jurisdictions as outside them,
* PS and their clients are residents of any jurisdiction,
* PS has no motivation to cooperate.
For example, the most popular Russian system of e-money Webmoney is a resident of the offshore zone. The likelihood that we will be able to exert influence upon this largest of the operators and provide an acceptable level of cooperation with it in creating a system of control is practically equal to zero. In addition, the Russian customers use other PSs, which are also located outside the jurisdiction of the Russian Federation, in the framework of which we actually have to ensure control.
These factors lead to the conclusion about the utopianism of the idea of creating a control system, based on direct interaction with the companies - operators of PSs. At the same time, our task is to solve the problem cost-effectively and with the maximum efficiency.
So what to do?
As is well known, any business process is characterized by the presence of periods of the initial investment and fixation of profit, which in the annex to the e-money can be respectively defined as processes of input and output of funds into/from PS. I.e. any e-money that appears in the PS originates from the outside sphere of circulation and aims to come back in the external sphere.
At the same time the majority of the PSs abandoned the independent implementation of the input-output funds, and leased these operations to special sites - "gateways", "exchange offices", which have earned an authority and confidence in the Internet community and certain financial possibilities for a long time. In the Russian segment of the Internet the number of such authoritative resources is not so wide.
Thus, we see a significant concentration of cash flows to/from the Internet in a narrow stream of these “gateways» in the presence of client identification from their side, because the majority of transactions (almost 100%- withdrawal of funds) are made with the use of debit and credit card transactions connected with the accounts of clients.
In this connection one may assume, that in the case when "gateways" are appropriately licensed, i.e. taken under the effect of the Federal Law from 07.08.2001 N 115-FZ, the goal of achieving the necessary control of application connected with the e-money can generally be solved within the jurisdiction of the Russian Federation. At the same time business interests will also be taken into account, which is very important in order to ensure a sufficient level of regulation that will not damage the "virtual economy".
The issues of emissions of prepaid cards and the use of payment terminals for input of cash in PSs are still open.
However, in my opinion, the control of input of money resources in the PS (as well as input on the whole!) with the use of these methods is not so relevant at the initial stage, because the commission of PSs in these cases is quite high, which gives grounds to believe that such proposals have sense only for the retail market of micropayments. Though in this case the legal restrictions on the provision of such services are also possible.