Switchpoint Payments Business Plan — Regulatory, Compliance and Licensing
The licensing pathway, sponsorship arrangements, FICA and anti-money-laundering obligations governing a payments business.
Regulatory, Compliance and Licensing
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- Overview & contents
- i. Important Notice and Basis of Preparation
- 1. Executive Summary
- 2. The Opportunity
- 3. Market and Regulatory Context
- 4. Product, Technology and Security
- 5. Go-to-Market and Unit Economics
- 6. SWOT and Competitive Position
- 7. Financial Projections
- 8. Cash, Funding and the Balance Sheet
- 9. Sensitivity and Scenario Analysis
- 10. Risk Analysis
- 11. Regulatory, Compliance and Licensing
- 12. Organisation and Management
- 13. Implementation Roadmap
- 14. Key Performance Indicators
- 15. The Offer, Returns and Recommendation
- 16. Assumption Register
- A. Appendix A: Consolidated Financial Summary
- B. Appendix B: Volume, Pricing and Unit Economic Schedules
- C. Appendix C: Funding, Cash and Balance Sheet Schedules
- D. Appendix D: Risk Register
- E. Appendix E: Glossary
|
Requirement |
Instrument |
Status in plan |
|---|---|---|
|
Participation in the National Payment System |
National Payment System Act 78 of 1998; Reserve Bank directives |
Via sponsor bank. Condition precedent |
|
Third-party payment provider arrangements |
Directives issued under the Act, as amended from time to time |
To be confirmed with sponsor bank and counsel at diligence |
|
Card scheme registration |
Visa and Mastercard operating regulations |
Registered service provider status via sponsor. Months 1 to 6 |
|
Cardholder data security |
PCI DSS Level 1 |
Qualified security assessor engaged. Attestation before first live transaction |
|
Anti-money laundering and counter-terrorist financing |
Financial Intelligence Centre Act 38 of 2001 |
Accountable institution obligations via sponsor arrangement. Programme adopted before launch |
|
Personal information |
Protection of Personal Information Act 4 of 2013 |
Information officer appointed; operator agreements with all partners |
|
Consumer and merchant contracting |
Consumer Protection Act 68 of 2008; Electronic Communications and Transactions Act 25 of 2002 |
Merchant agreement reviewed by external counsel before first signing |
|
Company and tax |
Companies Act 71 of 2008; Income Tax Act 58 of 1962 |
Annual audit from FY2027. Corporate rate of 27% with assessed loss carry-forward |
No credit is extended and no insurance is underwritten in the plan as modelled, so National Credit Act and Financial Advisory and Intermediary Services Act obligations do not arise. Any subsequent extension into merchant cash advance or embedded insurance would change that position materially and is outside the scope of this plan.