03.21 – Electronic Money Issuers

The following table details some types of E-Money formats.

Product ‘Financial Account’ Under FATCA? Comments
E-voucher* No None
Pay card Yes Where cash is retained in credit, this causes the arrangement to fall within the scope of a financial account.

This is a depository account, and could only benefit from an exemption if the manufacturing FFI meets the qualified credit card issuers exemption.

prepaid credit card Yes Where cash is retained in credit, this causes the arrangement to fall within the scope of a financial account. This is a depository account, and could only benefit from an exemption if the manufacturing FFI meets the qualified credit card issuers exemption.
‘Merchant services’ account Possibly If cash is retained within a merchant ‘account’ then this is not a depository account, but may be a custodial account.

If merchant services payments simply flow through systems but are not retained in an account, such payments would not be financial accounts.

If in scope, the only comparable exemption in the US legislation is ‘escrow account’ exemption, but these are not “escrow” accounts.

In addition to the above, any account that would otherwise fall within the definition of a financial account (depository, investment, custodial, insurance) shall not fail to qualify as a financial account just because it is maintained in an e-Money format. For example, an online depository account (sometimes known as an ‘e-wallet’) is treated the same way as a traditional depository account.