Faisal KhanPayment Consultant to Banks & Startups
Bio

I'm a banking & payments expert. I specialize in cross-border, money transmitter licenses and E-money licenses. If it is difficult to get, or obtain, chances are, I do it. I help startups and incumbents overcome the licensing, regulatory, compliance, etc. hurdles can get going fast, How? because I have the license holders who are willing to rent their licenses.



Recent Answers


A local service provider who would be a switch operator "might" be able to provide this service (provided they operate Nostro accounts with all the banks). No international service provider would be able to provide this, as they usually connect with a single Financial Institution, who serve as their local settlement and processing bank. What you are trying to do may be possible if you have access to the ATM switch rails, but then, daily limits between transfers will apply.

Having said this, this comes under the purview of transaction banking and I know exactly what you are trying to do (have a local P2P payment model that settles instantly, by taking local payment from Sender in his bank account, and paying out to Receiver in their bank account - where you also have an account).

Until and unless each bank provides you APIs and rails to their internet banking, it would be a manual task pretty much trying to do this.


It is illegal if you are in "any" part of the money transmission space. There are three components to money transmission:

1. Sending Money (Load money, taking money to send from one country to another).
2. Receiving Money (Off-Loading money, paying money out to recipient)
3. Someone to Take money from #1 and convert it to money for number # (the market maker).

If you are involved in any portion of this without a license (assuming your country requires it to be a licensed operation), then it is clearly illegal.

Most people who function as "Human ATMs" are dispensing money out locally, based on a local (domestic) transaction.

It is not about invoicing. If you are aware that the transaction is one that by-passes regulations, then your involvement is deemed illegal.


Not knowing what type or vertical you are in, it is difficult to say how.

100,000 visitors a month is a decent size. Most people opt for placement of banner ads and affiliate links and it works for them. However, you might also look at other avenues of monetizing.

One of the most important aspect is to understand "why" they are visiting? What is their bounce rate? Are they looking for information? Are they downloading something? Building a better profile of your audience will pay you back ten folds over. Understand your audience and then cater to their needs. You surely have managed to get their attention, now get them to engage with you more. Proper placement of CTA (Call To Action) buttons could build your mailing list or have them fill out a form or even allow you to do A/B testing by asking people to give you a survey answer, right there on the website itself.

Data drives decisions!

The more data you have the more options you have as how to work with it.

Again, not knowing what your 20,000 App downloads is all about, it is very difficult to say how to monetize without the needed a prior information.

Pay attention to your visitors, build their profile as accurately as possible and use services like SomoMe to generate heat-maps of what they are doing, where they are clicking most, etc.

The more you know about their behavior, the more you can strategize towards monetization.


Considering that taxation would be your responsibility, this transaction would be deemed high-risk.

a. You would be liable for all deliveries, issues, with respect to the product (because YOU are getting paid).

b. If you're cool with that, and knowing that high-risk industries charge between 8%-12%, I think asking for something like 20% take is not off the mark.

Also be sure to read through the terms and conditions of the app store where you are selling. You're essentially acting as an aggregator for this friend of yours. Make sure you're on the right side of the law.


Possible yes. Will it sustain, will depend on what you bring to the table. You need to have a product &/or a service to sell.

Now, if you are selling a service (without having any experience) that may prove to be difficult, however, the same rule does not apply to selling products.

Though you may roll your eyes, one of the most fundamental things you should be looking at is a business plan. It doesn't have to be complex, but you must have one, to jot down your thoughts, be cognizant of the business environment around you.

Very few people make it - but that does not deter them from finding their own entrepreneurial goal which they aim to succeed.


Banks in the US are becoming increasingly sensitive to the type of businesses they associate themselves with. If you're a genuine business, it really is not your fault.

Licensed institutions like cash advance businesses or even the highly regulated money transmitters have a hard time opening a bank account.

You literally have no claim. If a bank refuses to do business with you, they can and there is not much you can do.

Do try to find out the reason (the Risk department is the one that provides reasoning).

See if your business is classified under high-risk as far as the bank is concerned.

This is a HUGE problem now in the US, so try to open as many bank accounts as you can.


Short & Long of it: You cannot.

The current rules BSA, et. al. stipulate that you would have to be physically present in the branch to open an account and present your ID and company credentials. Anyone telling you otherwise is not correct.


These companies usually subscribe to services by the likes of Mint (now Intuit) or Yodlee. These companies use the FIX protocol (usually) and receive obfuscated data from the credit card companies and banks. The data is non-transactional data, i.e. you cannot do any transaction with the data, but you can build a spending profile from it.


One of the most used techniques is to add people on LinkedIn (Junior or Mid-level Management) and ask them who the correct decision maker is in the company. Most of the time, people are indeed helpful and will provide you with the correct name.

You have to be polite and yet at the same time, subtle/diplomatic about it. People don't like being connected on LinkedIn only to find out the person was trying to jump elsewhere.


Banks like Bank of America, Wells-Fargo, JP Morgan Chase, etc. all have a merchant services application process that you can apply for. There is quite a bit of documentation that needs to be provided for to qualify as a master merchant, i.e. a PSP.

The main issue here would be to demonstrate your business model and how you will mitigate risk for the bank. This is not overly difficult if you're in the know-how/business, however, you might also want to consider that, as an option, you can also go to large-scale processors like First-Data, MIGS, Cybersource, Chase Payment Tech, et. al. to obtain the same. Many a times, these processors offer added layers, that a bank might not be able to offer (not always the case, but nonetheless an important differentiator).

One of the most important aspects on this is to understand that paperwork aside, you will need to negotiate your way into getting a better MDR, reduce your risk deposits and get better payout terms for yourself.


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