2018/2019 Edition of the Global Regulatory Update

Global Regulatory Update  | Corporates Edition 73 privacy compromises around Facebook’s users and possible influence on elections in the U.S. and elsewhere. Impacted foreign players will be subject to higher compliance and administrative costs and RBI’s unfettered access to all payment data for supervisory purposes could be a concern for industry. China China is moving towards the implementation of a wide-ranging cybersecurity law. The process has been delayed given the complexity of implementation. Restructuring of regulatory authorities has also delayed implementation. Industry has also raised a range of concerns. Key questions remain over which firms will be classified as a network operator and a key information infrastructure operator. Software and hardware from foreign providers may need to be substituted. Data on-shoring may also be required. 8) Payment Systems There are several initiatives in APAC relating to the establishment of National Payment Gateways - an ASEAN priority. Vietnam is considering routing payments through a domestic gateway run by a state owned entity (NAPAS) under the central bank. Indonesia is also considering routing payments through a domestic gateway run by a consortium of local banks and a state owned entity. A consultation was released in August 2017 which would require international cards companies like Visa/MasterCard to apply for new licenses to participate in domestic payments and to reduce from 100% ownership to a minority JV of around only 20%. There are concerns about privacy, security and operational risks as well as reduced efficiency and competitiveness and increased costs in the establishment of national gateways. International firms are calling for open, interoperable systems and the ability of foreign firms to participate in these new systems. Instant Payments via central banks are also being developed including by Thailand and Singapore. Standardized QR codes based on EMVCo standards are also being adopted in Asia by India, Thailand, Singapore and Hong Kong. The provision of mobile wallets (Apple Pay, Google Pay, Samsung Pay) are also increasing as Asia diversifies its payments systems. 9) ASEAN Initiatives Recent developments The annual Association of South East Asian Nation (ASEAN) Finance Minsters’ and Central Bank Governors’ Meetings (AFMGM) took place April 5-6, 2018, in Singapore, the host country of ASEAN in 2018. The event gathered senior ministers, central