Canada    FinTech Guide    Chapter 8    Uruguay


8. Online Banking Services
Uruguay  Uruguay


Legal Affairs


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.



Economic Conditions


This market is mainly catered by banks which have developed their own mobile apps and digital platform.



Miscellaneous


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.



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 May 2018