Protect consumers’ access to payment accounts

In view of the changing payment landscape in Sweden, the Swedish Ministry of Finance conducted a study on the current payment ecosystem and on the role of the Swedish state in such earlier this year. The results of the study triggered some proposed targeted amendments to numerous Swedish acts and regulations as outlined in the two enclosed statements.
The Swedish financial market regulator, Finansinspektionen (FI), has now published a response to the study and the proposed measures. The key views of FI are briefly summarized below:
1. Banking Services and Money Laundering: FI supports the proposal for banks to offer accounts with limited services instead of terminating accounts due to increased money laundering or terrorism financing risks. It emphasizes the need for individual risk assessment and the consideration of offering accounts with limited services instead of outright denying customers access to bank accounts.
2. Documentation of individual assessments: Finansinspektionen calls for clearer requirements for banks to document account decisions when faced with money laundering or terrorism financing risks. Additionally, FI would like institutions to be required to perform individual assessments of alternative measures when consumers are denied a payment account.
3. Flexibility in payment systems: FI supports the proposal for government agencies with significant payment volumes to have agreements with multiple banks to ensure sufficient flexibility in the event of disruptions. Likewise, it supports an expanded scope of collaboration and agreements to ensure a clear assignment of regulatory responsibilities particularly in cases of market disruptions and to ensure that each regulatory agency is aware of its responsibilities and able to live up to such responsibility, if so needed.
4. Acceptance of cash: While opposing a general obligation for businesses to accept cash, FI emphasizes the importance of supporting consumers who rely on cash payments and suggests that the state should focus on facilitating access to digital payment methods rather than imposing obligations on businesses to accept cash payments. The maintenance of cash payments is expensive and it is questionable if such requirement is worth consideration considering the current development in the payment sector.
5. Legal tender and cash handling: Finansinspektionen opposes the proposal to introduce a requirement for financial institutions to accept payment in Swedish kronor, as history has shown that the traditional currencies have remained strong in the past despite a lack of corresponding requirements of financial institutions. Also, FI simply does not see the practical implications for such a requirement.
6. Competition analysis in payment systems: FI strongly supports the proposal for a comprehensive analysis of competition in the payment ecosystem.