Abracadabra, here’s Libra Calibra

As Facebook attempts to bounce back from some of the latest setbacks, it is interesting to hear about the launch of Libra and Calibra, in what seems to be more of an offensive, rather than defensive response.

What is Libra?

In describing their mission, Libra starts by touting the banked-unbanked statistics, as have most of the would-be disruptive services for the last couple of decades or so. The question this raised for me is whether all this has really been tailored to those currently shut out of the banking system. With that segment more pre-occupied by bread-and-butter services, schooling, healthcare and local spend, it seemed to me that this product, aimed at global money transfer and payments transactions may turn out to be more attractive to a different tribe. Facebook seems to have received similar feedback already, so perhaps there is more to this than currently meets the eye.

The service is underpinned by the Libra Blockchain, and a currency unit termed, not unexpectedly, Libra (LBR). Adoption has generally been the main sticking point in most of the services that failed to make it over the last decade. Knowing this, their proposed founding members list reads like a “Who’s Who” of the Payments ecosystem. We have though, seen such a line-up in many previous products that are no longer around today. Perhaps this time it will be different. It is still early days. With so much of industry learning available, succeeding this time should hopefully be simpler.

What is Calibra?

Calibra is the digital wallet service from Facebook, meant to be the wallet for Libra. It may be used as a standalone app or through the Facebook Messenger and WhatsApp platforms. A subsidiary of Facebook, it seems to be the main go-between into Libra, which Facebook seems to be keeping more at arm’s length, judging from the “Libra, 2 weeks in” blog from David Marcus.

The Libra Association has been set up as an independent organization in crypto-currency friendly Geneva, Switzerland. Arguably, as just one of the 28 initial Founding Members, Facebook is not the sole influencer. However with a charter yet to be put in place, the trust the market places in Facebook will still be a central issue for the success of this service.

How does all this connect into the Bitcoin ecosystem?

Libra appears to position itself as a peer of Bitcoin. It is built on Blockchain, as is Bitcoin. While Libra claims not to be as open as Bitcoin, it is designed to be open, as it is not restricted purely to members. Where exactly the “openness line” is drawn will probably be clearer in the coming days.

Unsurprisingly this has raised similar concerns for regulators and Central Banks as have crypto-currencies launched before, though given the reach of Facebook and recent events, concerns seem to be stronger. Chris Skinner who spent time looking at what’s been happening at the United Nations shares his views in “The Regulator’s View of Facebook’s Libra Currency”.

Future Outlook

India’s base of tech-savvy consumers became a leading adopter that decided the fate of WhatsApp as a communications platform. An earlier P2P payments service from Facebook termed the WhatsApp payments service recently completed a pilot in India, offered to a million users. It now aims to rollout across the country, and is also being introduced in London. It will be interesting to see how that service pans out, and what the connection is to the new services planned. What is the future direction Facebook has in payments, how will all their acquired products fit in, and whether they will at last make the break through they have sought for so long – these are just some of the many questions that remain unanswered. 

If any company is well aware of the network effect and how to use it, Facebook is. With experienced David Marcus involved there is undoubtedly a high degree of preparedness to be expected. So, they would well know how the closely-knit Indian community around the world could contribute to the success of these new products. At present though, Facebook claims to have ruled out plans for Calibra in India. The chosen markets and corridors will no doubt have an enormous impact on the success of these services.

For more on this, there is an infographic from MrBTC.org that aims to describe the crypto-currency in 5 minutes.

Apple Pay Cash and the matter of trust


Over more than a decade now we have seen the launch of mobile wallets and prepaid cards, the high hopes for them and an often lukewarm response from the customer, followed by a phased withdrawal. I have myself been involved in a number of launches, in roles at many different parts of the payments, banking and money transfer ecosystem. There have been clear benefits we could demonstrate for our customers, but inescapably, with each extra “pot of money” a customer creates, there is more to manage. So the benefit must be compelling.

The big question in my mind when Apple announced the launch of Apple Pay Cash in the US on December 5 was naturally, how will this product fare? Will the path we see look much like that of the Google payment card, which launched with great fanfare and soaring expectations, but just fizzled out? Apple has proven they can launch products that are accepted and can change customer behaviour, getting them to do things they never used a phone for before. So will the Apple track record be enough to carry through this new product to success and help Apple Pay Cash to succeed where others failed?

The new Apple Pay Cash card image, copyright Apple Inc.

With the growing threats from cyber security, from a myriad of digital players on a range from pesky to all out criminal, customers are increasingly on the look out for ways to transact securely while on the go. Could a prepaid card from Apple that can hold some money that you use to pay be of interest, by addressing the customers critical and growing need of trust? Apple Pay has been relatively successful in mobile payment, but research from PYMNTS.com “Apple Pay Stats” seems to indicate a plateau in uptake over the last few years.

The offer seems not too new, and by now customers should be familiar with what to do and how to do it, having used their mobile phones with PayPal, Square, Venmo and other payments and money transfer applications. The Apple Pay Cash debit card works “like a bank account”, allowing you to send and receive money on the go.

Apple has attempted to make it easy for customers to get started, but as they cross certain thresholds they are asked for more identity verification. For instance if you want to receive $500 or more your identity would be checked, but it may be checked even otherwise, based on the way Apple sets up its rules. You may choose to verify your identity upfront, for instance if you want to use it at your favourite retail store. The identity check is managed through Green Dot Bank, the Apple Pay Cash card service provider. You must provide name, address, last four digits of your Social Security number and date of birth, as of now.

If trust is to be the draw, launch timing seems really unfortunate.  We just found out that since 2016 Apple has been slowing down processes on older iPhones.  Whether this was meant to nudge customers towards buying a new phone before they planned to or was an error of judgement that lead the team to choose this as a “fix” for older batteries, trust in Apple has taken a beating. Apple has apologised,  but a clear statement on what customers may expect going forward may still be critical, to re-establish the kind of trust customers need to deepen a financial services relationship.

So the new Apple Pay Cash launches in a climate where trust in the Apple brand is not at an all-time high, while trust towards America and American brands has also taken a beating. The repeated high level data breaches in 2017 and use of our personal data as the price we pay for “free” services has left customers somewhat jaded.

Customers need brands they can trust and brands need customers, for which they must meet customer needs. As we enter 2018, for me success of every product and service will hinge on deepening trust. Trust is something customers often took for granted in the past. Now each breach is likely to cause a reaction that could take brands by surprise.

How people pay in the USA – Fed Reserve Payments study 2016


The Federal Reserve has just reported their estimates of the total number and value of all noncash payments made in 2015 in the United States, both by consumers and businesses. The study provides insights on adoption trends for new payment methods. Main findings of the study may be considered under 3 key areas:

(1) Differences between consumer and business payment choices in 2015 and changes over the 15-year period since 2000

No surprise, check payments are being replaced with card payments and ACH transfers. In number, check payments dropped from  57.8% of non cash payments to 13.4%. By value the drop was from 66.7% to 15.4%. However this still remains high in comparison to leading European economies that have considered altogether doing away with checks.

Total noncash payments by households increased by around 94.7% over the 15 year period, again no surprise as this period from 2000 to 2015 precisely marks the growth period for electronic payments worldwide.

New methods studied included payments initiated via a mobile device (for instance mobile wallet), payments through specialized services for person-to-person payments, and the use of online or Ecommerce payment authentication services to help verify the payer and secure payment information.

(2) Adoption and intensity of use of different types of general-purpose payment cards in 2015, along with more recent changes since 2012

Consumer and Business payments differed in terms of popularity of payment type. Top four consumer payment types were non-prepaid debit cards, general-purpose credit cards, checks, and ACH debit transfers, with the first two categories substantially in the lead. The top four business payment types were ACH credit transfers, checks, general purpose credit cards, and non-prepaid debit cards. The number of checks written is still alarmingly high as compared to that in many Western economies such as the UK, that have made the transition to instant electronic payments.


The figure above, drawn from the Federal Reserve report illustrates the way in which US consumers and businesses pay and how this differs in terms of payment type.

(3) Growth in selected alternative payment initiation methods and services

Over the 15 year period there was strong growth in the number of mobile wallet payments, but online bill payment through banks increased only marginally as payments can now be made directly to billers. The figure below, extracted from the report shows the change from 2012 to 2015.


Although P2P and money transfer payments increased over the period, they remain very low by number. Online payment authentication methods on the other hand grew from 1.8 billion in 2012 to 3.4 billion in 2015.

The full study report from the Federal Reserve may be downloaded at The Federal Reserve Payments Study 2016: Recent Developments in Consumer and Business Payment Choices, June 2017.

The Florin Awards Europe 2017



I am just back from chairing the Florin Award Jury at The European Payment Summit 2017.


We were pleased to see some highly innovative products and services from the finalists.

ThreatMetrix was the winner of the Florin Award in the category “Architecture for Secure Transactions”.

ThreatMetrix eCommerce protection provides real-time fraud prevention tools to online merchants worldwide, while also offering the potential for a less-intrusive consumer experience. The jury was impressed with the innovation demonstrated by the ThreatMetrix Digital Identity Network, claimed to be the world first Digital Identity Graph. This maps associations between people and their devices, locations, account credentials and behaviour. Such a mapping of anonymized user identities could play a key role in fighting cybercrime while also respecting consumer privacy. The strong European orientation is helpful for the roll-out of PSD2. Their Cybercrime Threat map provides a live stream of fraud attempts that was also something the jury found credit-worthy.

Iredeto was the winner of the Florin Award in the category “Omni-channel Payments Security“.

The jury was impressed by the way that Irdeto has transformed itself over the years with the visionary leadership of founder Pieter den Tooner who established the company back in 1969. Today the company continues to play an important role in Europe while boasting a client base that includes customers worldwide. The jury especially valued the breadth of security solutions that spanned multiple industries including media & entertainment, automotive and payments. Their solutions in the area of cloakware and whitebox cryptography have a key role to play thanks to the importance of protecting Open APIs and the critical need for security across multiple devices.




Do read more about it, and check out all the finalists at http://europeanpaymentsummit.com/florin-awards/.

The conference, held at the historic Louwman Museum was very interesting.

I shall share highlights from the conference as well as our latest research on Cyber Security and Payments over the next month.



A celebration of Republic Day in the land of miracles


Simply put, this is an important day for me.  I would not have been around but for India’s Independence followed 3 years on by our Republic Day, now in it’s 68th glorious year. My Dad wanted to bring free kids into the world and only married once this was assured. Although I will never truly understand what it meant to the generation who made this happen for us in 1950, every year we celebrate this day is one more year India proves itself to be a land of miracles.

The sense of pride this day invokes in a billion+ hearts is hard to describe. Let me just say I am certain it evokes a certain energy and a sense of fulfilment in every Indian around the world. The sheer diversity across so many dimensions, including language, religion, tradition, occupation puts the most glorious patchwork quilt to shame. So it is truly admirable that India has won and held the mantle of largest democracy in the world over all these years.

But the amazing story of India begins way before 1000BC, making the Constitution of India a relatively recent development. The river Indus after which our country was named was home to Harappan and Mohenjo-Daro civilisations and our two epics, the Mahabarata and the Ramayana relate to events of the Epic Age which was followed by the Maurya, Gupta, Moguls and other transitions, each leaving a unique legacy.

British Rule seems miniscule in comparison to all that went before. The date for India’ Republic Day was chosen to commemorate Purna Swaraj, the Declaration of Indian Independence on 26th January 1930. The Reserve Bank of India had already been established by 1935, and in 1938 we had the issue of the first Rupee banknotes shown below.


Thanks to the work of my father’s generation, the Rupee soon received a makeover. My generation and those to follow would enjoy the sailboat, dam, Asoka, the space craft (in 1976), the Parliament House, Mahatma Gandhi and many agricultural images. There is a nice site I found that shows a Currency Gallery of India, worth going through as it speaks volumes on how the country developed.



The Rupee had to wait until 2010 to gain it’s symbol ‘₹’. An historic demonetisation of ₹500 and ₹1,000 was achieved in November 2016, with redesigned ₹500 notes and the new ₹2000 banknote put in circulation. This and other measures are required in the rebalancing as the great country that is India asserts herself on the world stage.

India has arguably achieved one of the highest rates of progress towards digital payments over the last year. Let us not fool ourselves, working towards achieving all of this has been hard work and will continue to be so. What we have to be grateful for is that all that has been achieved has been within a democratic framework. This is nothing short of a miracle and on this Republic Day we look forward to money supporting the population so effectively that it ceases to occupy so much importance and becomes just the catalyst we can take for granted, to support over a billion livelihoods and the huge future India has ahead of her.


Jai Hind!

Openness versus Certainty of Regulations – What is more enabling?

Both openness and certainty are important to establishing what is termed as an “enabling” financial services(FS) regulatory environment.

Firstly, what is an enabling regulatory environment?

Just as plants would struggle to grow and survive without the right soil, climate and care, businesses too require the right mix to grow and thrive. For families and individuals to live full and happy lives it is important that the right kinds of businesses take root to help provide both the right kinds of products and services as well as gainful, fair employment.

This summer while caring for my Aloe Vera plant I learnt that over-watering could lead to disastrous consequences. My beautiful young plant lost it’s firm, upright disposition and adopted a slothful, “who cares” stance, until I realised all it needs is a few drops of water. Right beside it though, my Vietnamese Coriander wanted not just to be always very well-watered but also some “emergency rations” to be made available in a saucer below, to be drawn on as needed.

I had an important role as carer – I could not be over-zealous with one plant and had to force myself to leave it be, while providing the other a totally different level of care. Once I learnt my lesson peace reigned and, in the end, there was little to do to achieve happy plants.


Openness and Certainty

Regulators around the world have a considerably harder learning curve as there are a myriad of “do’s and don’ts” they must get right to do what we expect of them. So, forgive me for simplifying this but we tend to categorise regulatory stance on two main axes – Openness and Certainty.

Openne ss can spur or stifle innovation

Openness refers to the stance on who can offer financial services – just traditional players such as banks or also mobile operators, handset providers, global tech companies and others. Speaking of global companies, locality is another important aspect of openness. For the longest time, PayPal struggled to enter China, and global banks and money transfer operators had to create a complex set of partnerships to allow them to provide services across 200+ markets.

It is often critical for a regime to be relatively closed to protect fledgling local industries but there is always the danger of corrupt practices arising in an over-protected environment. The mix of products and services that become available to the population determine whether the next Facebook can be nurtured along or small enterprises are mercilessly squeezed out by providers enjoying dominant positions. In the UK, we enjoyed as open a regulatory environment as we could wish for, but the price has proved high – yet veering too far in the other direction can have equally disastrous consequences.

Certainty is established by each individual action

Certainty is something different but to my mind equally important. Every day that a company continues operations in a specific country, it is making an investment that it hopes will pay off. Investment is not one time only, but entering and leaving a country are often given more importance and we forget those who are simply making business as usual decisions on incremental investment.

If a country cannot create a level of trust in its institutions and governing bodies this can create levels of uncertainty that will destroy years of painstaking, rigorous work. Certainty makes the difference between whether a company can recoup the expenses on licensing and processes that it sets up. Certainty is also connected to fairness. If one company can get away with something, why should the next one not try? Certainty helps create level playing fields.

Charismatic regulators

Independence of regulators and cultivation of the highest calibre of professionals will ultimately, over a long period repay the people of a country.

Today digital trends facilitate an osmosis of innovation and services across jurisdictions that threaten traditional ways of protecting markets. How a country embraces and regulates the openness and certainty of their regulatory environment will impact on their position in the pecking order of tomorrow. Certainly, it will impact on GDP but more importantly it will impact on how that country is perceived by the world.

It is all too easy to find fault with our regulators. When things seem to be working it is easy for us to forget they exist. When the economy is playing up, they could be the first we turn on.

It is right and proper to be ever vigilant but we should never forget the critical role our regulators play and just how vulnerable they are. We must strive to educate ourselves to support and monitor them because the decisions they make each day do not just impact us – they determine the quality of lives of our children and grand-children.

A story of Malaysia and Singapore reflected by their coinage


Today is an important day for Malaysians, marking the creation of the Federation of Malaya back in 1957. Six years later, on this same day, North Borneo and Singapore would gain their freedom, leading to an Independent Malaysia on 16th September 1963. I therefore thought it a good time to reflect on how value transfer changed over time, to support the aspirations of its people. Life in this vibrant region dates back over 1.83 million years. As in other parts of the world barter prevailed, but as the southwest monsoon created important trade routes for the Archipelago, linking India and Arab lands of the West with China, barter and cowries soon gave way to the use of gold dust, silver and tin as payment.

Things changed soon after, with conversion to Islam in the 14th century. By the 15th century numerous states were issuing their own coins, generally conforming to Islamic standards. Thus the history of money for the people of what would come to be known as Malaysia and Singapore grew in sophistication centuries ago, with the octagonal gold kupangs, tin jokohs, silver tangas and other exotic, beautifully crafted coins.



Coins with “Malaysia” on them first made their appearance only in 1967. The smaller denomination sen coins (1,5,10, 20) were followed by the 50 sens, all featuring the parliament building and crescent and star emblem.


The 1 Ringgit coin was issued two years later, followed by the 5 Ringgitt coin in 1971, both made of copper-nickel. The term “ringgit” actually means “jagged”, and was probably inspired by the serrated edges of Spanish dollars that were in use during the Portugese colonial era. Sens and Ringgitts (100 sens) replaced the dollars and cents that previously carried images of Victoria in 1845 and George VI in 1939 – The new coins reflected the ambition and hope of new beginnings.



August 1965 also marks Singapore’s independence and by 1967 Singaporeans were using their own coinage, with the 1 cent and the $1 carrying an image of their mythical beast, the Merlion.

On the tenth anniversary of Singapore a bright new silver $10 coin bore the triumphant image of a ship, indicating the importance of the country to world trade.


South-East Asia

As the “centre of gravity” shifts towards Asia, South-East Asia continues to build thriving new communities and a unique culture. A bright new 5-dollar coin commemorates South-East Asia’s 4-yearly Games where Malaysia, Singapore, Indonesia and the Philippines participate.

Today both Singapore and Malaysia have a critical role to play in Southeast Asia, Asia and the world. Both are at the forefront of money going digital at the heart of Asia and are important Islamic banking centres. Their progress is synonymous with our progress in our complex, intertwined global economy. So we take time off today to wish our friends in each country congratulations and the very best for a bright and prosperous future, filled not just with money but with innovation, health and happiness.




Could new regulatory guidelines in Bangladesh turn MFS into “nobody’s baby”?

With the recent release of new draft guidelines for mobile financial services (MFS) in Bangladesh, I caught up with payments expert Raihan to get his views on the state of play of the market, possible outcomes from the guidelines and how we may see Bangladesh consumer financial needs better addressed over the next 5 years.


Raihan, to set the scene could you please share a bit about your role in the Bangladesh payments scene?

When I joined Grameenphone in 2006 on completing my studies in the US, these were early days for mCommerce in Bangladesh. We designed it all from scratch - processes for financial operations, reconciliation, the channel commission, payments, fund management and more. Seeing our BillPay service so popular in Bangladesh made it all worthwhile. I then moved to airtel where even in a bank led model we have built an award-winning mCommerce portfolio with specialized products such as micro credit disbursement together DBBL, our banking partner and 13 MFS partners including bKash.

What is the current state of play of the Bangladesh MFS market?

Bangladesh MFS market is now 5 years old. The top 2 operators bKash and DBBL together accounts for an estimated 74% of the market, with bKash leading since launch in 2011. A recent cGAP study estimates that 30% of Bangladeshi adults have used bKash while 4% have used the DBBL service. bKash users are more likely to be active, with 81% account holders active, compared with 67% for DBBL users. DBBL users are more likely to be registered users with 44% registered as compared to 23% for bKash.

As of June 2016, there are 36.2 million mobile banking registered accounts but only 13.3 million are active users. However, this data does not represent the number of unique users of MFS.

What’s behind this success of bKash?

I think this is due to the awareness that bKash was able to create ever since their launch and also their extensive retail reach. In terms of transactions, bKash still leads with over 80% market share although their annual growth in revenue has come down to 50% in 2015 from 81% in 2014.

What challenges do you face regarding user identification, AML and KYC?

OTC (Over-the-counter) continues to be hugely popular in Bangladesh, with 2.5 times more users than registered mobile wallet users. Retailers often transact on behalf of customers and this could create AML/KYC issues.

In 2016 we have started National ID verification process for mobile subscribers as Instructed by our regulators. Fortunately, as 90% or more of the active users of Telecom Services registered their SIMs, this may not impact the revenue and transaction volume of MFS.

Regarding usage pattern, I notice that unregistered users are more likely to use basic money transfer services while registered users also use advanced services including bill payment and mobile top-up. Today an estimated 8% to 15% of mobile top-up is done through MFS.

How is sticking with OTC a drawback to poorer users who only need basic services?

Today almost everyone has access to a mobile phone. Hence a poor person living in the remotest corner of the country can get registered through MFS and enjoy proper financial inclusion with the kind of services that are normally only available over a banking counter. Transacting through someone else’s wallet rather than your own is almost like a “Digital Hundi” or Sending money through the courier service which was actually one of the ways to send money in Bangladesh prior to the launch of MFS.

What was the motivation for new regulatory guidelines for MFS in Bangladesh?

MFS has always been a key focus for the regulators, specially Bangladesh Bank. Despite the rapid development of MFS and the huge potential to grow and reach the remotest corners of Bangladesh to boost financial inclusion, complete financial inclusion via mobile banking has yet to reach its full potential. OTC or unregistered use of MFS is one of the biggest drawbacks of the service.

This is why the Bangladesh Bank has been working towards a revised guideline that can encourage appropriate business models that help the market reach its potential and create a win-win situation for all the entities in terms of equity shareholding. I believe that with a few minor changes, this new guideline could help boost MFS growth and ensure financial inclusion in Bangladesh

So what are the new guidelines, and do they help address the issues?

Here I’d like to discuss two of the major clauses included in the new Draft Guideline:


Clause 4.1

BB shall permit delivery of the following broad categories of financial services by scheduled commercial bank-led Mobile phone based Financial Service (MFS) platforms in Bangladesh.


The scheduled commercial bank-led MFS platforms may have both banks and non-bank entities including Mobile Network Operators (MNOs) as equity holders, subject to banks holding majority beneficial ownership in total equity, no bank or non-bank entity holding more than fifteen percent beneficial ownership in equity, and Beneficial ownership of MNOs in an MFS platform not exceeding thirty percent of its total equity.


In Clause 4.1 we see that it remains a bank-led model as specified by the previous guidelines published in 2011. However, Clause 5.2 requires that no bank or non-bank entity hold equity share more than 15% individually. Banks must have majority ownership and Telcos may not collectively hold more than 30%. This means MFS projects will become nobody’s baby! This potentially creates a huge issue in regards to ownership.

What is the alternative you recommend?

In my view, we should first study what’s happening worldwide and learn from that. We should deploy a model which will be beneficial for the people of the country and will be owned by both Telecom and Banks. Telcos are good at things like branding, marketing campaigns, product management, agent management. Banks are expected to safeguard funds. Hence a model in which each of these players can execute to the best of their capability will be a successful one. My proposal would be that there should not be any restriction on the ownership of MNOs or any other equity holders. We should follow the good examples available across the globe.

Apart from equity participation, in what other ways are Telcos held back due to the guidelines?

There are several other areas where Telcos are not allowed to participate in the current MFS services. For example, Telcos are not allowed to promote the product, brand the product or launch different campaigns to promote MFS services. Telcos are only allowed to offer Telecom Data or talk time) for MFS promotions.

How do you see the market developing as we move towards 2020?

In the next 5 years, I expect the MFS market to be more mature and more compliant. SIM verification and re-registration will be imposed on MFS as well which will eventually limit the OTC usage and encourage use of mobile wallets. More advanced services will be launched so that people start to use MFS for services other than the basic money transfer.

Government already disburses payments (G2P) through MFS. In 5 years from now, I expect P2G to increase in a big way, so that payments including fees and taxes reach the government through MFS. Mobile Top Up usage will increase even more and may reach approximately 50% of total Telecom Top Up value.

MFS providers will further pursue Omni channel strategies, with some already providing the service through apps and the web. MFS services will be offered through other mediums such as NFC and it will not be only limited to USSD, apps or web and launch of 4G services will further boost usage.

Mobile Number Portability will be introduced in the country and, the need of having more than one MFS account with different Telecom operators will gradually decrease.

As stated by Bangladesh Bank, over the last couple of years, we have found that people at the “bottom of the pyramid” have been able to greatly increase their economic activities and that volume is increasing significantly each day. This contribution directly impacts the transactions volume in mobile banking.

Overall I look forward to MFS playing a major role in the growth of GDP of our country.



Ruhullah Raihan Alhusain is a payments professional with over 12 years of work experience in Mobile Banking Field. He graduated from the University of Texas at Arlington with Honors as Bachelor in Business Administration and led the Grameenphone mCommerce Operation Finance team before moving to airtel where he is Head of mCommerce Operations

The complexity of the gold ecosystem presents quandaries for regulators


With us since times immemorial, Gold has proved to be one currency that has remained relatively stable despite turmoil in global financial markets. Universally accepted, and prized as a medium of exchange from ancient times, today it offers renewed appeal in the face of conditions and requirements from customer segments of different kinds. Yet new challenges that the world faces may pose new requirements in the way regulators look at the gold market.


The many and varying uses and facets of gold present a quandary for governments around the world when it comes to dealing with the opportunities and threats it presents. On the one hand, safeguards are essential to detect and prevent the use of gold as a tool for money laundering and terrorist financing. On the other hand, all around the world gold is intricately woven into culture and tradition in a way that transcends the value of the metal itself.

A delicate balance must be maintained to recognise the complex requirements presented due to the highly differing users and use cases. A wrong move could prove detrimental to a country, while wise management could present new opportunities at multiple levels of the ecosystem.

Instinctively governments realise that appropriate management could be a game-changer. Yet how does one go about it? Recent efforts of the Modi government in India to get the gold of the population into government approved schemes face insurmountable issues when it comes to requiring gold to be melted down first. The associations and value a woman may place for instance, on a much-loved heirloom make certain trinkets priceless – so what approach would work?


While it is imperative to respect the cultural use of gold, there are however potential links between the gold market and terrorist financing. As gold can be traded anonymously and transactions are difficult to trace and verify, cases have been uncovered that show how it is being used to place, layer and integrate illegitimate funds into the formal financial sector. Loopholes are present and may be exploited in a number of markets due to the differences in the way the gold market is regulated, for instance in terms of how cash-for-gold businesses are licensed and overseen.

Gold is covered by the Financial Action Task Force (FATF) under Recommendation 23, treating the gold sector as DNFBPs (Designated Non-Financial Businesses and Professions), but national policies must work together to create the global network that allows people to continue to enjoy the benefits while weeding out the unsavoury aspects of the gold market.

Over the coming months I will share more about my research into this fascinating topic – approaches that are being taken in different parts of the world, the changing position of gold as a currency and how it relates to money going digital, both in traditional ways as well as in terms of virtual currencies such as bitcoin.

Amazon’s new Subscribe & Save Offer: Could prove sticky?


As I report that Amazon has been making further inroads into the UK online shopping market, I realise it is probably an under-statement. As it was our go-to provider long before the holiday season it is no wonder we got most of our gifts from them, availing of the great selection of offers during November/December. Free home delivery, the peace-of-mind from trouble-free returns and refunds and a most reliable service has made Amazon the darling of many Brits over the recent past, as can be seen from the volume of reviews pouring into the site.

I was interested therefore to notice today that their “Subscribe&Save” offer earlier launched in the US is now available in UK. The offer claims to provide regular users the ability to save up to 15% as well as gain free shipping on recurring deliveries. To me this seems to be yet another step in the evolution of Amazon from book supplier to online provider of the first resort. For UK shoppers who are now spoilt for choice of online retailer with most grocery stores offering great home delivery options, this appears to be designed to tempt us away, for purchases of a wide range of household shopping items, of which a vast array has now appeared on the site. With its legendary knack of mind-reading Amazon quickly suggested a few items that I had already bought on a number of occasions, while I was checking out the offer.


I must admit this looks promising but also from my past experience from launching digital content services in the UK, I recall the “Crazy Frog” incident where junior mobile subscribers unwittingly found themselves with costly subscriptions, I am sure there could be a number of issues that must be navigated by the marketing team to ensure that people don’t end up with deliveries they did not expect and suppliers don’t have to contend with higher levels of refund.

Within an overall great experience, I found one particularly irritating feature. Introduced over 2015, their “Add 0.01 p to get free home delivery” never fail to irritate our household, and probably a lot of UK online shoppers. A number of desirable products are priced at £19.99 (Why?). However, one needs £20 of “applicable items” for home delivery and finding out what is applicable is quite a chore. For people who would like to save around£4 delivery cost this means a thankless job of looking through “Add-on items”. The concept of Add-on is itself an admirable one as it is a way for sellers to offer small items online. However, believe me it can be most irritating to find an item that qualifies for the 0.01p required, heave a sigh of release and lug it into your online basket only to find that it’s not made your delivery cost go away.

Not to mention the additional time you are forced to spend trying to save money on Amazon must come with a health warning as one can end up buying so much more than one planned – the shopping experience is so slick that it can be quite addictive! I think the same will soon be said of a number of the online stores that are burgeoning in the UK market, and as a delighted consumer I am not complaining (yet?).

PS: For full disclosure, I am not connected with Amazon in any way, apart from being a shopper and a passionate observer of the way money is going digital, to power payments and commerce around the world.