Canada    FinTech Guide    Chapter 1    Uruguay


1. Payment Services / Mobile Payment
Uruguay  Uruguay

Politically the government is committed to increasing the use of this type of payment services, in line with the recently enacted Law on Financial Inclusion.



Legal Affairs


In order to provide payment services or ancillary services, the service provider must register before the Central Bank of Uruguay (hereinafter the “CBU”) as Payment and Collection Service Provider (“Prestador de Servicios de Pago y Cobranza”), or have a wider license which comprises such services (e.g.: bank license). To obtain such registration/license, the service provider must submit, when filing for such registry, certain information to the CBU regarding the company, its structure and business cycle, including: (1) Company name, indicating type of company, fantasy name or trade mark if any, home and real domicile, N° of registry before the local tax and social security authorities, phone, fax, email address and web page, (2) Notarized copy of the Company’s Bylaws or corporate agreement, approved or in process of being approved, (3) Identification data regarding the legal representatives of the Company (full name, nationality, identification number and address), (4) List of all company shareholders or partners, and persons that have the effective control of the company, indicating name, personal address, identification number, participation percentage and contributed capital, (5) Superior staff roll, providing Curriculum Vitale, personal and working references in relation to the corporate purpose of the company and financial activity in general, (6) General Information of the Company, (7) Company staff, (8) Hierarchical structure, (9) Links to other related entities both local or foreign, (10) If applicable, accounting statements regarding the last financial year, issued according to the adequate accounting rules of Uruguay, (11) Business cycle description, with specific details of the operation, including the intended resources (information and fund flows), (12) List of external service providers., (13) Technological platform assessment (hardware and software). To such effects certain specific information must be provided, (14) In case it is deemed necessary, the CBU may require additional information.

Also, the information provided at the time of submitting the request for registration must be kept up to date, and any modification regarding it, must be communicated to the CBU within certain terms.



Economic Conditions


Total mobile payments amount to USD 100 billion per semester. The biggest payment providers are bank developed solutions, Paganza and Bit$.



Miscellaneous


This type of registration is relatively new in Uruguay. New regulations related to the same will most probably be issued in the near future (e.g. anti-money laundering regulations applicable to these type of entities).



Contributing Authors

Guyer & Regules

Federico Susena
Montevideo, Uruguay


John Leaman
Montevideo, Uruguay

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Chapter Index:


1. Payment Services / Mobile Payment

2. Asset and Portfolio Management

3. Consulting and Broking Services / Robo-advisory / Auto-trading

4. Trading Platforms / Social Trading Platforms / Signal Following

5. Crowdfunding / Crowdinvesting / Crowdlending

6. Virtual Currency - Bitcoin

7. Loan Services / Factoring / Loan Broking / Finetrading

8. Online Banking Services

9. Analytics and Research / Data Management / Risk Management

10. Accounting

11. Identification

12. Online-pawning

13. InsurTech

14. RegTech

15. Initial Coin Offerings (ICOs)

Disclaimer:
The information in this guide provides a general overview at the time of publication and is not intended to be a comprehensive review of all legal developments nor should it be taken as opinion or legal advice on the matters covered. It is for general information purposes only and readers should take legal advice from a Multilaw member firm.

Publication Date: 1 August 2019