This regulatory analysis will examine anti-money laundering (AML) measures with regard to e-wallets and is the second in a series that will compare the licensing regimes of e-money operators and banks. Specifically, this analysis will compare the AML requirements for politically exposed persons (PEPs), beneficial owners and enhanced due diligence (EDD) measures for both e-money operators and banks in three distinct jurisdictions: Singapore; the Philippines; and the United Kingdom.

This comparison will aim to determine whether there are any similarities between e-money and banking regulations both locally and between these jurisdictions, at least from an AML perspective, in light of the compliance requirements that these regulations impose. It will then lay out what these similarities (if any) could potentially mean for e-money operators, both in these jurisdictions and potentially further afield.