Body
FinTechs belonging to this area offer traditional banking services in a modern way, usually through online services or mobile applications as well as ancillary services – e.g. enabling customers to manage their giro- or custody-accounts online and in real time or offering e-wallet services. Keywords in this context are also API-Banking or Banking as a Service (BaaS)/ Bank as a Platform (BaaP).
API-Banking:
API stands for application programming interface and is offered to access data banks and to extract and insert information. API-Banking consequently means the access to data banks of banks to offer new and innovative banking applications.
Through these services FinTechs offer services with new functions, e.g. enabling customers to manage their accounts online and in real time.
BaaS – Bank as a Service/BaaP – Bank as a Platform:
The API-based Bank as a Service platform has a full banking licence, but merely serves as the back end for standalone independent FinTechs, which “use” the licence and the back end of the bank to offer new financial services, launch additional financial products or expand into additional markets.
Introduction
Attitude of the country towards online-banking services
Currently, in the Russian Federation, the provision of banking services using specialized Internet services is one of the most dynamically developing areas of providing financial services to both legal entities and individuals. Internet banking is one of the fastest growing areas today.
The implementation of API-Banking (open software interfaces) is indicated in the Strategy for the Development of the Financial Market of the Russian Federation until 2030, approved by Order of the Government of the Russian Federation No. 4355-r dated December 29, 2022, among the priority tasks within the framework of the development of the financial market in the Russian Federation.
According to the Concept for the Implementation of Open APIs in the Financial Market, developed by the Bank of Russia, published in 2022, two models for the use of open interfaces are considered: open finance (in the financial market) and open data, when data exchange requirements also apply to non-financial organizations – telecommunications, social networks, retail trade, including e-commerce, travel services, search engines, and transport services.
According to the plan of the Bank of Russia, the introduction of mandatory use of open APIs for financial market participants will begin in 2026.
Legal affairs
Obligations and requirements to provide online-banking services described above
First of all, it should be noted that banking activities in general and online banking in particular are subject to licensing in accordance with Russian law.
The main law regulating the activities of banking organizations in the Russian Federation is the Federal Law of December 2, 1990 No. 395-1 "On Banks and Banking Activities". At the same time, there is no regulation of remote banking services at the level of federal laws.