However, we have come across instances where these local requirements were repeatedly violated due to poor internal controls in these organizations. For instance, we had come across instances where some entities have been leveraging the card network to extend payment and money transfer services across border domestic residents, without consideration of the local legal/regulatory requirements.
Their modus operandi include shipping prepaid cards denominated in foreign currency into the country, and facilitating the funding of these cards from other prepaid cards or any other international payments channel. Another instance is the proliferation of non-bank payment gateway service providers. These entities based across the globe acquire merchants in any country.