Online banking services as described above are not specifically regulated. Therefore, if a service provider renders such type of services (including traditional banking services) it may need to obtain the license of a financial intermediation institution (e.g.: a bank). However, the regulations applicable to financial intermediation institutions will most probably need to be adjusted or re-interpreted in order to adjust to the online banking platform.
On the other hand, in case under the online banking services only e-wallet services and custody of funds services are rendered, the license that may apply to this type of entities would be that of Issuers of Electronic Money as above described in “6. / Uruguay / Legal affairs”.
Lastly, if the app or the online platform is a service rendered on behalf of an entity under the control of the CBU it may be deemed that the same is an outsourcing of services of such entity and therefore an authorization of the CBU would be necessary. Please refer to “9. / Uruguay / Legal affairs” below.
This market is mainly catered by banks which have developed their own mobile apps and digital platform.
Even though there are banking institutions in our country which provide different services online via webs and apps, the concept of a full online bank has yet to appear in our country. Therefore, no actual regulation has been approved to apply 100% to online banks, which results in the application of the regulations regarding regular banks.