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talking about issues at an early stage doesn’t affect our ability
to regulate or enforce e-money properly.” But, she acknowledges, “Regulatory capture—getting
too close so you aren’t able to view risks objectively—is a per- ennial issue for all regulators in any jurisdiction, large or small. It’s something you must be aware of, but being straightforward
and open, even in a jurisdiction as small as Gibraltar, doesn’t need to equate to an unsafe
impact on our regulatory environment.”
Learning the E-Money Ropes
There have been a few bumps along the way as the FSC has worked to understand the EU’s e-money regulations and the business of e-money through the eyes of those who’ve established a beachhead in Gibraltar. Mostly, the bumps have slowed some pro- grams’ implementation schedules, causing short-term frustration.
Paschini believes the delays are expected in a startup situation. “What we’re talking about is a relatively new licensing regime,”
he comments. “The FSC didn’t walk into this with years of experience, because this payments ecosystem is evolving.”
Howitt attributes some of the challenges the FSC has faced as a regulator to the European Com- mission, the EU’s executive body, which proposes and manages
volume 7 • fall 2014
Churchill stamp: Olga Popova / Shutterstock.com
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