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author | Christian Grothoff <christian@grothoff.org> | 2023-07-02 14:33:59 +0200 |
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committer | Christian Grothoff <christian@grothoff.org> | 2023-07-02 14:48:27 +0200 |
commit | a8b3f0eb4ea6c7b438a4081fe9a91b38ac60b07d (patch) | |
tree | 5869febec2ab4ff4a561561d551b16fe8a356d19 /doc/flows/main.tex | |
parent | e961b29103028a8dae38eb6830cb11b1cbc0fab0 (diff) | |
download | exchange-a8b3f0eb4ea6c7b438a4081fe9a91b38ac60b07d.tar.xz |
work on regulator text
Diffstat (limited to 'doc/flows/main.tex')
-rw-r--r-- | doc/flows/main.tex | 53 |
1 files changed, 31 insertions, 22 deletions
diff --git a/doc/flows/main.tex b/doc/flows/main.tex index 2a10578bf..30d5fd3ae 100644 --- a/doc/flows/main.tex +++ b/doc/flows/main.tex @@ -37,6 +37,15 @@ The main interactions of the system are: \item[shutdown] the Taler payment system operator informs the customers that the system is being shut down for good \end{description} +In the analysis of the legal requirements, it is important to differenciate +between transactions between wallets (customer-to-customer) and transactions +where money flows from a wallet into a bank account (customer-to-merchant) as +these have different limits: When digital coins are deposited at a business in +Taler, the business never actually receives usable digital coins but instead +the amount is always directly credited to their bank account. Depending on +the transacted amounts, the business will nevertheless be subject to KYB +(Section~\ref{sec:proc:kyb}) and AML checks. + {\bf Customers} begin their business relationship with us when they withdraw digital cash. Taler has no accounts (this is digital cash) and thus there is no ``opening'' or ``closing'' of accounts for consumers. Given digital cash, @@ -51,33 +60,33 @@ fees (see Section~\ref{sec:fees:coin}) that apply to prevent the coins from expiring outright. For customers, we will categorically limit of digital cash withdrawn per month -to less than CHF 5000 per month and less than CHF 15000 per year, thus +to less than CHF 5'000 per month and less than CHF 25'000 per year, thus ensuring that consumers remain below the thresholds where most regulatory -processes become applicable. We will, however, ensure that customers are Swiss +processes become applicable. Payments between users will be limited +to receiving less than CHF 1'000 per month and less than CHF 5'000 per year. +We will ensure that customers are Swiss (see Section~\ref{sec:proc:domestic}) by requiring them to have a Swiss bank -account and/or Swiss phone number (+41-prefix). Furthermore, the wallet will -impose an upper limit of CHF 5000 on its balance at any point in time. +account and/or Swiss phone number (+41-prefix). +%Furthermore, the wallet will +%impose an upper limit of CHF 5000 on its balance at any point in time. For {\bf merchants}, the Taler equivalent of ``opening'' an account and thus establishing an ongoing business relationship is for a business to receive -payments (see Section~\ref{sec:deposit}) exceeding CHF 5000/month or CHF -15000/year. We will consider the account ``open'' (and require up-to-date KYB +payments (see Section~\ref{sec:deposit}) exceeding CHF 5'000/month or CHF +25'000/year. We will consider the account ``open'' (and require up-to-date KYB information and check sanction lists) as long as the business has made any transactions within the last 24 months. -In contrast to normal customers, merchants can in principle {\bf receive} -payments without limit. However, these transactions must go into the bank -account of the business: when digital coins are deposited at a business in -Taler, the business never actually receives usable digital coins but instead -the amount is always directly credited to their bank account. Depending on -the transacted amounts, the business will be subject to KYB -(Section~\ref{sec:proc:kyb}) and AML checks. As we will only transfer money -into the existing bank accounts of the merchants to compensate them for sales -made using the Taler payment system, we do not need to check the origin of -funds for those merchants as they will only receive funds from -us.\footnote{Should businesses want to use Taler for expenditures, they will -need to withdraw digital coins from their bank account just like customers, -and the limits for customers will continue to apply.} +As we will only transfer money into the existing bank accounts of the +merchants to compensate them for sales made using the Taler payment system, we +do not need to check the origin of funds for those merchants as they will only +receive funds from us.\footnote{Should businesses want to use Taler for +expenditures, they will need to withdraw digital coins from their bank account +just like customers, and the limits for customers will continue to apply.} + +For individual {\bf transactions}, we will impose a limit of CHF +1'000/transaction (even though our reading of the regulations would permit +individual transactions up to CHF 15'000). The following sections describe the respective processes for each of these interactions. @@ -111,7 +120,7 @@ There are five types if interactions that can trigger regulatory processes: \item[deposit] a merchant's {\bf bank account} is designated to receive a payment in digital cash \item[push] a {\bf wallet} accepts a payment from another wallet \item[pull] a {\bf wallet} requests a payment from another wallet - \item[balance] a withdraw or P2P payment causes the balance of a {\bf wallet} to exceed a given threshold +% \item[balance] a withdraw or P2P payment causes the balance of a {\bf wallet} to exceed a given threshold \end{description} We note in bold the {\bf anchor} for the regulator process. The anchor is used @@ -129,7 +138,7 @@ Chapter~\ref{chap:regproc}. \include{kyc-deposit} \include{kyc-push} \include{kyc-pull} -\include{kyc-balance} +%\include{kyc-balance} \chapter{Regulatory Processes} \label{chap:regproc} @@ -151,7 +160,7 @@ The three main regulatory processes are: \end{description} \include{proc-domestic} -%\include{proc-kyc} +\include{proc-kyc} \include{proc-kyb} \include{proc-aml} |