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Digital Wallets and Stored Value Print

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Holding customer funds.

WHAT A WALLET IS

A balance held on behalf of a customer, usable for payments.

WHAT IT ENABLES

Instant payment without a rail per transaction Refunds returned immediately Transfers between users Lower transaction cost at volume

WHAT IT INTRODUCES

Holding customer money, which is a regulated activity in most forms.

WHAT THAT MEANS

Establish the licensing position before building.

WHAT SAFEGUARDING REQUIRES

Customer funds held separately from operating funds Held at a licensed institution Not used for business purposes

WHY THAT IS FUNDAMENTAL

Customer money is theirs, and using it is the failure mode that ends firms.

WHAT TO RECONCILE DAILY

Total customer balances against funds actually held.

WHAT A SHORTFALL MEANS

A serious problem requiring immediate attention.

WHAT TO BUILD

A ledger per customer, with every movement recorded.

WHAT LIMITS TO IMPOSE

Maximum balance Transaction limits Velocity limits

WHY

Wallets attract money laundering, and limits are frequently required.

WHAT TO PLAN

Dormancy and unclaimed balances, which have defined treatment.


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