A good news article although slanted in the direction of bad. Good news due to the article generally identifying regulatory pressures forcing large banks to no longer offer Money Transmission Company accounts at their banks, who offer remittances to immigrants, or is it those banks who offer remittances directly to immigrants who have legal documentation such as the Matricula Consular? Banks can’t offer remittances to those immigrants without formal identification. In either case, some large financial institutions are unwilling to bear the risk of large fines due to their inability to strictly conform, or for their Money Transfer Companies that provide remittance services to their consumers, to strictly conform to regulations requiring formal identification of a remittance account holder and monitoring of remittance transactions sent, and therefore are willing to give up market share serving these consumers who provide services to the immigrant market, whether directly or indirectly. This is good news because it shows the regulators’ difficulties with attempting to force banks to conform to regulations preventing money being sent by illegal individuals to illegal individuals, with the negative impact of erroneously preventing money being sent by undocumented illegal and legal immigrants to legal individuals, and should provide the impetus necessary to change the remittance infrastructure as a whole. The regulators are not the problem; the regulations are the problem and the lack of ubiquity and access to the remittance market for the immigrant population is the problem. The regulators are just doing their job. The regulations are the problem. The regulations in the US market require strict identity requirements for individuals to send remittances cross-border using banks and other 3rd party remittance providers. Given these identity requirements, and the fact that many Mexican immigrants don’t reside in the US legally, banks can’t open accounts for these immigrants, therefore can’t reach the immigrant market. Immigrants, both legal and illegal, can use Western Union and Moneygram without strict identification requirements, within specific maximum dollar thresholds, given specific license requirements in each state where they offer remittances. 3rd party remittance providers can also provide remittances for immigrants in the same manner as Western Union and Moneygram, but are limited in market reach given their need to acquire remittance licenses in all 50 states, a challenge to acquire and maintain as a money transmission service provider. Other stipulations are required for money transfer licenses but let’s focus on the regulatory requirements, What’s needed in the remittance industry is not for banks to withdraw from the remittance market like some of the large banks are doing, but like Wells Fargo, who seems to have embraced the market with its remittance product, maintains its presence and push for market share, a good thing and commendable. Further, banks and 3rd party remittance providers should collaborate and effect change of the US remittance infrastructure by changing legislation to minimize “know your customer” regulations and allow cross border transfers by all banks and 3rd party remittance providers to offer minimal “customer identification” requirements for remittances under a specific maximum threshold per day, and a maximum across a 30 day period, and legislate to accumulate all remittance transactions sent from all remittance service providers nationwide at the end of each day and perform analysis using Big Data by a 3rd party government or remittance association entity for patterns of remittance transactions being sent to one or more individual or business globally to determine illegal activity, or other constructive money laundering algorithms, and remove or minimize fines levied against remittance service providers until intent to send unlawful remittances or conduct illegal activity is proven); in short, to move away from a preemptive remittance intervention strategy and move towards a remittance post intervention through analysis strategy, where proof of breaking the law is required. If the intent is to truly locate unlawful funds sent cross border, the best manner is to accomplish this is to accumulate all remittance activity from all remittances sent from all 3rd party remittance providers and banks and analyze cumulatively, not individually from each 3rd party remittance provider and bank sending remittances. It would be interesting to know whether existing regulations and monitoring by banks and 3rd party remittance providers have identified whether illegal remittances are being sent by illegal senders in the market, or if only those banks identified in publications such as banks like HSBC and its money laundering violation is the only one identified. Given the current reliance on the monitoring of each 3rd party remittance provider and bank by US regulators, it would seem difficult to determine if samples of patterns of remittances used for laundering funds are viable, and given the thresholds currently established, those money launderers who know the regulations could determine a means to circumvent. If the desire is to provide a lower priced remittance, which it should be, and if the desire is to monitor and identify funds being sent to places from the US from illegal immigrants when it probably need not be given the low dollar value of funds sent, and if the desire is to allow access to effect a remittance ubiquitously from most bank or 3rd party locations in the US, to most 3rd party locations globally, which it should be, than changes in the US remittance infrastructure needs to occur. Regulatory changes and discussions with remittance industry participants on a 3rd party remittance Big Data Company for transaction analysis are a start. All three, lower priced remittances, illegal cross border remittances sent by “undocumented” immigrants made legal, and the ability to send remittances from almost anywhere to anywhere, from any device to any device, from any currency to any currency; effects much accommodation and/or change in the corporate world and the public world, to the benefit of many, to the detriment of some. Regards, Randy