Changes to debit card top ups

Why?

Because there is no way anyone can argue that any country in the Euro zone is a financial risk. Plus it ensures that I can top up from my accounts in countries that are not listed!

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Someone somewhere has made the argument that certain countries in the Euro Zone are a financial risk of some sort.

In as much as the Euro is a risk, sure. But to argue that any country with the Euro central bank behind them is a risk to monzo is ridiculous.

I think it’s clear that money laundering risk is behind certain countries being excluded, so the stability of the euro or the backing of the ECB is irrelevant. I also think that Monzo will have the data and financial crime experts to make this kind of decision. Making random assumptions about which countries should be supported because it would be convenient does not make much sense to me. I don’t think Monzo is excluding any countries out of spite, it’s based on an analysis of data and risk.

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But my money is clean, it has already been properly laundered :smiling_imp:

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Hi everyone,

I love that this is encouraging debate about financial crime risk! The more everyone talks about risks and how to mitigate them, the safer all of our money will be… but that aside, let me answer some questions.

@DaveTMG you bring up a great point. Why did we not just include all EU countries? It would perhaps be easier to explain, and what is the downside? Well, @jzw95 has hit the nail on the head; we looked at the data and did a risk assessment to work out which countries to include on this list.

To be more specific, let me tell you about how we assess country risk in general. We have taken research carried out by Transparency International and the Global Slavery Index, used data showing the amount of illicit financial flows going through a company and compared that to each country’s GDP, looked at high-risk and non-cooperative jurisdictions as defined by the Financial Action Task Force (FATF) and finally at countries that are sanctioned. Based on this information we came up with our own analysis of what a high risk country means to us.

When looking at this particular problem of Stripe top ups, the main concern is that one of our customers will receive a top up that comes from a sanctioned person. If we were to allow that to happen we would be in breach of the financial crime regulations in the UK. In order to mitigate this risk, we thought about our country risk assessment and what we deemed a high risk country. We also considered how certain countries regulate their banks, and how strict banks in different countries are about performing sanctions screening on their customers.

By thinking about these things, we concluded countries that were part of the EEA and FATF would be likely to have the best sanctions screening procedures in place. We did not include all European countries because there are certainly some that we deem to be higher risk from this perspective (Azerbaijan and Bosnia and Herzegovina to name just a few).

Finally, and of course, we thought about our customers. How would this list of countries impact you? We looked at the countries which top ups have come from in the past, and we decided that we should add Australia and New Zealand to the list. They are both the lowest rating on our country risk assessment, and would enable us to cover a greater percentage of top ups.

The list we ended up with covers about 99.7% of all top ups done so far at Monzo. We also think it mitigates our financial crime risk to a low level, and one that is within our risk appetite.

I hope this helps you understand where the list came from, and let me know if you have any other questions!

Thanks,
Natasha

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Thanks Natasha, but why not include all of the EEA countries? (To clarify, that’s what I meant rather than the geographical Europe)

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Hi @DaveTMG! That is because not all EEA countries are members of FATF, and FATF produce guidelines that their member countries follow. They also carry out on-site or in-country reviews to make sure the member countries are following the guidelines. Ensuring that the countries included were following FATF guidelines means we can be even more sure that they are sanctions screening properly.

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Thanks, is there a list of FATF countries available? Found it. Haha Russia is a member.

And Switzerland - so both EEA and FATF but not in the list?

http://bfy.tw/FJSI

:wink:

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Yep! http://www.fatf-gafi.org/countries/#FATF

Come on any list of ‘responsible’ financial countries that includes Russia has got to be dismissed surely?

They are not on our list :wink:

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Switzerland is not an EEA country: https://www.gov.uk/eu-eea

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So it isn’t. But I think they may have a history of reliable banking :wink:

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It’s not about the reliability of the banking in a country, it is how strict they are at verifying the individuals banking with them, and whether they are on the sanctioned persons list. Switzerland has a history of accepting money from anyone (not sure what the current situation is), so just because their banks are reliable, doesn’t mean they are suitably careful in who they allow to bank with them.

You keep trying to apply some sort of list-based rule to justify why a country should be included, but Natasha set out (excellently and in great detail) how it is more complicated than that, and the various data sets, risk analysis, and customer impact assessment that Monzo used to come up with the set of countries. Are you implying they didn’t do this, or that you don’t think they did a good job with it? And on what basis?

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Or maybe he has some Nazi gold? But you can’t use that to top up a Monzo account in-app anyway. You’d have to post it to their HQ like a cheque, obviously.

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Any plans on expanding the list into the future as I am planning to move and live in Japan but I don’t want to give up monzo

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While in theory this sounds great, in every situation where I’ve seen it utilised it’s ended with either disappointed community members, stressed developers or… Both. Prime examples being Star Citizen and a game I follow periodically that’s been in development for almost a decade, Star Trek: Excalibur.

Thinking about it logically, if we put up a sign tomorrow saying ‘Debit Card top ups, 95% complete’, most people who read that would think that it would be out in a day, a week. Tops two but the reality is is that development isn’t a straight line from 1 - 100%, it’s probably easier to think of it as a windows loading bar :wink:

While debit card top ups should be along soon, there could hypothetically be a major bug found just as we’re about to roll them out that could push the release back. I think personally that it’s better for everyone if features are announced as they’re completed!

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