E-MONEY ISSUERS or EMIs

The Central Bank of Trinidad & Tobago (CBTT) (Homepage | Central Bank of Trinidad and Tobago (central-bank.org.tt)) has overarching responsibility for payment systems in Trinidad and Tobago (T&T) including but not limited to, the authority to make regulations for the issuance of electronic money (e-money), the transfer of funds by electronic means and the oversight of payment systems.

Via Legal Notice 284, the E-Money Issuer Order, 2020 came into effect, in Trinidad & Tobago, to allow other categories of persons, other than licensed financial institutions, to be eligible to issue e-money. These persons are referred to as e-money issuers and they are allowed to issue e-money. At the time of writing this blog, the E-Money Issuer Order was amended by Legal Notice 391 of 2023 – Legal Notice: THE E-MONEY ISSUER (AMENDMENT) ORDER, 2023 – Ministry of Finance. These amendments relate to the transactional limits and capital requirements of EMIs.

According to Section 2 of the  Trinidad & Tobago, E-Money Issuer Order, 2020,  an “e-money issuer” means a person under clause 3 of the E-Money Issuer Order, 2020 who is registered or who has applied to be registered to issue e-money under this Order and has been granted a provisional registration under clause 6.

A general definition of e-money (or electronic money) is that it is as monetary value represented by a claim on the issuer which is stored on an electronic device, issued on receipt of funds of an amount equal to the monetary value issued and accepted as a means of payment by a person other than the issuer (see Section 2(1) of The Financial Institutions Act, 2008 (central-bank.org.tt) of Trinidad & Tobago for a more detailed definition of electronic money). Some examples of e-money are e-wallets (digital wallets, mobile wallets), pre-paid cards etc.

See https://www.youtube.com/shorts/UjdDPfXbQEA,  https://thelegalcornerpodcast.buzzsprout.com/1876478/13359516https://tenorequelegalandconsulting.com/what-is-fintech/ and  https://tenorequelegalandconsulting.com/fintech-at-work/ for more information and stay tuned for further fintech blogs.