POST The war on cash, terrorism special

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“Most attacks require very little money, and terrorists tend to use a wide range of money-transfer and fundraising methods, many of which avoid the international financial system. Instead of continuing to look for needles in a haystack, governments should overhaul their approach to countering terrorist funding, shifting their focus”

The Problem With the War on Terrorist Financing | Foreign Affairs

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“Most attacks require very little money, and terrorists tend to use a wide range of money-transfer and fundraising methods, many of which avoid the international financial system. Instead of continuing to look for needles in a haystack, governments should overhaul their approach to countering terrorist funding, shifting their focus”

The Problem With the War on Terrorist Financing | Foreign Affairs

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The Problem With the War on Terrorist Financing | Foreign Affairs

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President George W. Bush signed Executive Order 13224 September 23, 2001… ‘Money is the lifeblood of terrorist operations,’ Bush said at the time. ‘We’re asking the world to stop payment.’ More than 15 years later, the war on terrorist financing has failed. Today, there are more terrorist organizations, with more money, than ever before”

The Problem With the War on Terrorist Financing | Foreign Affairs

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Bank of Ireland to have 100 branches ‘cash free’

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“According to a spokesman for Bank of Ireland, which operates the largest branch network in Ireland, just 3 per cent of customers’ total transactions are conducted over the counter today, with the rest taking place on mobile app, online banking and contact centres.”

Bank of Ireland to have 100 branches ‘cash free’

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Checking e-fraud in Nigerian banks – Nigeria Today

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“The Central Bank of Nigeria underscored the seriousness of this matter recently when it reported a N2.19 billion loss by the country’s commercial banks to e-fraud in the 2016 fiscal year. There were 19,531 recorded cases in 2016, compared with 10,743 in 2015. This is an 82 percent increase in e-fraud cases between 2015 and 2016. The figure may even be higher. The figure contained in the Nigeria Electronic Fraud Forum Annual Report unveiled last week by the CBN Governor, Godwin Emefiele, during a stakeholders’ workshop on cybercrime, showed different segments of the banks where the frauds were committed, and the value of losses recorded. A breakdown revealed that across the counter transactions accounted for the highest with a total value of N511.07 million. This was followed by Automated Teller Machine (ATM) transactions with N464.5m; Internet banking N320.66m and mobile banking transactions, N235.17m. Other losses came from e-commerce transactions, N132.25m; web transactions, N83.77m; cheques, N4.55m; kiosks, N10.19m; and others, N190.97m. The report noted that, ‘based on trend and human perception, it is believed that fraud rates increase towards the end of the year due to festivities…and the need for people to get more money.’ Nonetheless, the report stated that fraud can happen at any time, and therefore, called for ‘preventive and detective strategies’. From all indications, the extant preventive and detective strategies were not sufficient to prevent the e-fraud cases. For instance, between 2000 and 2014, Nigerian banks lost a hefty N199bn, largely due to inappropriate and reckless management of customers’ data”

Checking e-fraud in Nigerian banks – Nigeria Today

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Sorting out sorting

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“Almost 1 million UK bank customers will be forced to have to use new six-digit sort codes as the high street lenders implement rules intended to make the financial system safer, a Bank of England official has said… The change has been caused by the Vickers rules, which force banks to ringfence their high street operations from other banking activities.”

Almost 1m UK bank customers will be forced to use new sort codes | Business | The Guardian

It’s time to put a stop to this yonks old nonsense about sort codes and account numbers and I think I know just the woman to do it: Andrea Leadsom, now Leader of the House of Commons, but formerly City Minister. I have to admit to had a very soft spot for her when she was Minister. In a letter to The Daily Telegraph back in September 2013, she noted that — just as I had predicted — the Current Account Switching Service (CASS) which launched that month was (I paraphrase) a bit of a waste of time and money. She then went on to say that customers should have account number portability and be able to switch banks as easily as they can switch mobile phone operators. This was not new thinking. Six years ago the Independent Commission on Banking published an interim report on their Consultation on Reform Options. This report raised the subject of bank account number portability. Section 5.17, to be specific, says that:

Beyond improvements to the existing system, full account number portability would enable customers to change banking service providers without changing their bank account number. This would remove the need to transfer direct debits and standing orders, which remains the main area where problems may arise. In the past, portability has been rejected as overly costly, but if no other solutions appear effective and practicable, it should be reconsidered to see if this remains the case given improvements in IT and the payments system infrastructure.

It seemed reasonable for the Commission to wonder why customers cannot port their account number from one bank to another the way that they can port their mobile phone number from one network to another. That seems a plausible request for 2011, but phone numbers and account numbers aren’t quite the same thing. A phone number is an indirect reference to your phone (well, your SIM card actually) whereas the account number is the “target”. Thus, we shouldn’t really compare the account number to the phone number, but think of it more as the SIM. Each SIM card has a unique identifier, just as each bank account has an international bank account number (IBAN). When you turn on your phone, essentially, your SIM tells your mobile operator which phone it is in and then “registers” with a network. I am writing this in Singapore, where I just turned on my iPhone, so now my O2 SIM card is registered with Singtel. When you call my number, O2 will route the call to Singtel, who will then route it to my phone. But how does the call get to O2 in the first place?

In most developed nations there is what is called an “All Call Query” or ACQ system: there is a big database of mobile phone numbers that tells the operators which mobile network each number is routed by. In order to make call connections as fast as possible, each operator has their own copy of this database that is regularly updated. Note that for reasons that are too complicated (and boring) to go into there, in the UK there is a different scheme, known as indirect routing, whereby when you dial my phone number 07973 XXXXXX it is routed to Orange (because that’s where all 07973 numbers originated from) and then Orange looks XXXXXX number up in its own database to see where to route the call to (in this case to O2). This is why calls to ported numbers in the UK take longer to connect than they do in other countries.

It’s entirely possible to envisage a similar system working for banks, whereby we separate the equivalent of the mobile phone number — let’s call it the Current Account Number (CAN) — from the underlying bank account and have an industy database that maps CANs to IBANs. This database would be the equivalent of the ACQ database. (I rather like the branding too: if the banks decided to operate this cross-border, they could label it the international current account number, or iCan.) So the bank sends your salary via FPS to the iCan, and the database tells FPS which actual IBAN to route it to. No matter which bank accounts you use or change to throughout your employment, the employer always sends the salary to the iCan and thus reduces their own costs.

 

Thus I am not against the principle that the Minister espoused. On the contrary, I am very much in favour of making it easier for customers to move accounts. It’s the implementation that is the problem.  She formulated the problem as:

Ever since I was first elected I have been campaigning to ensure customers can change their bank accounts as easily as a customer can change their mobile phone provider.

Andrea Leadsom | Home

So what implementation should we have then? Well, in my opinion we should treat the bank account number as the SIM number (its conceptual equivalent) and find something else to be the equivalent of the mobile phone number. One option is to have virtual account numbers. I’ve previously put forward the “7-0” solution around this.

The 70 code is unused, so we can issue people with VANs of the form 70-ZX-XX 99999999. These would be compatible with all existing systems and with the IBAN scheme.

A suggestion for doing something about account switching in the UK

The idea here is that the customer gives billers, employers, counterparties the “70” account number that never changes but then chooses which bank account to map it to. They can change this at any time, there’s no need to go back to the billers, employers, counterparties and get them to change anything. The other way to approach it (and the better way in the long run) is to stopping messing about with 1960s sort codes and account numbers and just use names instead. I used to have a CompuServe number (100017,3342 if memory serves) but now I have a Facebook id, a Twitter id and a LinkedIn id. Why can’t I have an Account ID? As I said at the Payment Innovation conference a couple of years ago

This all links to the discussions about the idea of a financial service passport (or a “pay name”) at techUK last year. I really think that the idea of pseudonymous, strongly-authenticated CDD-inside identities is an idea whose time has come. 

Payment system regulation as barrier to payment system innovation

I think that what is need is a simple, portable, pointer to a person that can be used to index into their KYC’d persona. The easiest way to do this would be to assign a unique financial services identifier (FSI) to a persona or other legal entity the first time that they go through a KYC process. I might have the FSI “citizendave!barclays.co.uk”, for example. One someone has one of these FSIs, then there would be no need to drag them through “know your customer” (KYC) again. This would greatly reduce industry costs and make the process of obtaining a new financial service — a new bank account, a new credit card, a new insurance policy, a new accountant — much simpler. Imagine the simplicity of applying for in-store credit for that new sofa by just giving them your FSI and watching the application form magically populate by itself on screen.

It doesn’t matter if a person has multiple FSIs, because each FSI will have been obtained as the result of a KYC process. If the FSI Directory ends up with two “Dave Birch” entries, so what? It’s not an ID card scheme, it’s a “save money for the financial services sector and make life easier for consumers” scheme. And it wouldn’t matter either if both of my FSIs point to different iCans: I might, for example, have a personal persona and a small business persona—lets say citizendave!barclays.co.uk and citizendave!rbs.co.uk and that point to my personal and my small business accounts—and I want to use them for different purposes.

Picture this. You are fed up with the appalling service you get from your bank, so you walk into a branch of New Bank. You ask to open an account, and are directed to the ATM in the lobby and asked to request a balance from your existing current account. You put in the card and enter the PIN. While the ATM is carrying out the balance enquiry, the FSI (obtained from your card) is sent to the Directory and within a couple of seconds both your account balance (from your bank) and your picture (from the FSI Directory) are on the screen. The New Bank agent presses a button and a pre-filled application form is printed out for you to sign and, once you have, the existing system for transferring accounts is triggered.

There might be another useful spin-off from the FSI as well. Suppose you could designate a default account against the FSI: generally speaking, your iCan, but it could also be a prepaid account somewhere, or your PayPal account or whatever. Then someone could send you money by giving your FSI: no need to type in names, sort codes, account numbers. Anyone could pay anyone by entering the FSI into the ATM, or their internet banking screen, or (most likely) their mobile. Simple.

Woman sues casino that offered her steak dinner instead of $43 million jackpot – Jun. 15, 2017

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“‘You can’t claim a machine is broken because you want it to be broken. Does that mean it wasn’t inspected? Does it mean it wasn’t maintained?,’ Ripka told CNNMoney. ‘And if so, does that mean that people that played there before [Bookman] had zero chance of winning?'”

Woman sues casino that offered her steak dinner instead of $43 million jackpot – Jun. 15, 2017

This might actually be a genuine shared ledger use case. Think about it: the state of a gambling machine (the result of each “roll”) needs to be recorded. It needs to be recorded somewhere that is not under the control of the machine operator and it needs to be recorded somewhere that gambling regulators can access and than lawyers can discover. You could have every machine send its results into a big database somewhere, but then rival casinos would see how each others machines are doing.

Consider an alternative scenario. After each roll, the machine state is encrypted using the regulators public key 

Gambling is a feature of capitalism—not a bug | Prospect Magazine

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” Paulson used ‘synthetic collateralised debt obligations’—securities whose value depended on a package of subprime mortgages he had identified as particularly likely to fail. He then bought credit default swaps linked to these obligations.”

Gambling is a feature of capitalism—not a bug | Prospect Magazine

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Gambling is a feature of capitalism – not a bug – John Kay

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“when regulators perceive insurance when they should see wagering, their actions magnify a crisis rather than minimise it. Such destabilising speculation, mischaracterised by regulatory authorities as prudent risk assessment, is what caused the global financial crisis of 2008.”

Gambling is a feature of capitalism – not a bug – John Kay

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