Launching a payment aggregator or e-wallet: features of Russian legislation and success secrets

Continuing the cycle of materials devoted to the services of the payments industry, we talked to the founders of the SimplePay project Ivan Pritula and Dmitry Agapitov at Web-Payment.ru. SimplePay offers its users two solutions: a payment aggregator and an e-wallet. Ivan and Dmitry spoke about the difficulties that they had to face in the development of their services, shared the secrets of effective work with NNCO , taking into account the relatively recent history of ROBOKASSA, and also shed light on their own methods of combating fraud.

Based on the data published on your research site, most users pay for goods and services with bank cards, which in turn take a certain share from alternative payment instruments, such as e-wallets. Does this mean that bank cards will form the basis of the next stage in the development of payment solutions?

Ivan : No, it does not mean. Bank cards are the oldest of electronic payment solutions. They appeared long before all other electronic payment tools: e-wallets, gadgets with NFC technology support, as well as payment accessories, such as payment rings , chips and bracelets .

It so happened that the overwhelming majority of citizens have bank cards - everyone gets paid for a bank card, many Russian citizens have a loan and, as a result, a credit card. In other words, a map is an affordable tool that every person has. Hence, such a large percentage of card users, and not because cards are the most convenient payment method. It is not the most convenient, it just happened historically.
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Dmitry : Now there is an interesting trend: relatively recently in Russia, the law “On bankruptcy of individuals” was passed, and this very “successfully” coincided with the currency mortgage, with the dollar, which doubled. As a result, we have a lot of bankrupt individuals, and they use electronic wallets, because they cannot keep money on the card, since funds are immediately written off from the card to pay off the loan. Therefore, people open quite legal wallets and use them instead of a card.

In general, I see the future for some joint products, such as an electronic wallet and a plastic card attached to it, both as a replenishment method and as a payment method, primarily offline, so that you can pay for purchases from the wallet.

Is the wallet tied to a bank account?

I .: No, it is a separate payment instrument that is not tied to a bank account. By law, an electronic wallet is a payment without opening a bank account. Also, if the e-wallet is identified, that is, the person has provided the necessary data, he can withdraw the balance from the wallet to his bank account. Accordingly, the user can replenish the wallet from a bank account by transfer. However, the e-wallet does not have a specific bank account attached to it, that is, it is simply an electronic means of payment.

D .: Within the same electronic wallet, for example, within the bank servicing our service, there is a special account - 40903 ... - and it simultaneously accounts for all users. These individuals do not have separate accounts.

Do I understand correctly that this account will play the role of a certain depository of funds?

I .: Exactly. Customer funds are not stored with us in SimplePay, they are stored in our settlement bank, where there is a special account that opens up for electronic means of payment. In turn, the wallet operator gets arbitrary internal identifiers. For example, Yandex.Money has numeric identifiers, in our case these are email addresses, in the case of QIWI they have phone numbers. What exactly the identifiers will be, each wallet decides on its own. And the money is kept on a special account in a credit institution, in our case - NNCO.

What mechanisms of dealing with frauds and one-day businesses do you use?

I .: We have a lot of different means, the good is that now our tax agency has implemented several electronic services, posting lists of nominal directors, addresses of mass registration. We are constantly loading this whole thing.

D .: In fact, it all starts with technology. For example, there is a security standard for working with plastic cards, developed jointly by the international payment system Visa and Mastercard.

It all begins with basic things, because ensuring compliance with all these standards is a rather complicated, expensive and lengthy procedure. This is technical safety. It does not allow theft of card data, leakage of customer information, personal data. There are certain criteria that we look at, there is a certain “black” list of companies and activities that we do not work with.

All this came from practice. Some of this knowledge, information, technology, and how to work with it, we get from our acquiring banks. Why? Because we are in the same boat with them.

Have you personally encountered scammers? Give examples from your practice.

D .: Yes, there are examples. Here is one of them. A man writes us a ticket and begins to tell a tearful story: “I make a website for a client, I need bills. I have several of my sites, but they are a bit risky, I received refusals from other payment services. But let us get to know you, talk, you look at me. I will immediately connect a couple of my own and third-party projects to you, I made websites for people. Immediately I can connect them. Look at me, I will give you the documents. ” In general, absolutely normal, human conversation.

When we met with him, he told an absolutely serious look that he was going to open an online antiques shop, that the payers would be Americans, and that they would pay on cards without 3DS. In America, a really high percentage of payments without 3DS. It is for this reason that American cards are most often stolen. Therefore, rogues like this go and tell how they will buy 500,000 antiques for an item from the Internet for Americans without 3D-Secure. It may, and so, only we did not check this fantastic story at our own expense.

When you understand all this background, especially when it is not the first time you communicate with such a “client”, in most cases you already understand everything on the early approaches as soon as the conversation begins.

What market trends have influenced your decision to launch an e-wallet?

I .: Payments are moving towards online, towards non-cash transfers. From my personal experience, I can say that I used to not go out without cash. Now I can not go to an ATM for two or three days, because it doesn’t bother me at all. When we created our service, we took into account that there are payment services - payment aggregators in their pure form, but not electronic wallets, this is a big difference both in terms of functionality, and in terms of development, and in terms of a number of parameters.

From the point of view of the wallets offhand, you can call Yandex, QIWI, and, perhaps, WebMoney, although they now have some difficulties. Our difference from these wallets is that the aforementioned solutions, in fact, are “monocoslets”, that is, they can be replenished with a plastic card, withdraw funds to a plastic card, although they are recognized market leaders. Our wallet can be replenished in various ways (for example, it can be replenished from a QIWI account, and withdrawn to a WebMoney account). That is, it contains the function of electronic currency exchange.

There are certain client niches, for example, freelancers - people who work remotely, sit in different cities, work on the same project. At the same time, the leaders of such groups often complain that they receive money in one electronic currency, and they have to pay, for example, to some remote employee in another electronic currency. This, of course, is a solvable problem, but not quite simple. Our wallet, for example, allows you to do all this. With it, you can conveniently issue and receive bills.

Besides freelancers, what other client niches can you name?

I .: Speaking of freelancers, I mean that we have the opportunity to accept money with a fairly wide range of electronic currencies, including using a plastic card and other popular methods. For payments, there is also a whole range of options that cover all user needs. There are certain niches - customers who may be interested. The beauty of an electronic wallet is that its niche is, in general, all legally capable and capable individuals.

In fact, we did not immediately realize that we were an electronic wallet. For a while, we thought that we are a payment service exclusively for e-commerce and online stores, but then we realized that we are an electronic wallet, if only because we have more individuals than companies and online stores.

The need for electronic wallets is formed as follows: nobody needs them until they have the opportunity to pay for something, receive money on them, pay inside the system. This becomes convenient, and more and more people are involved in the process.

You have such directions as payment acceptance, mass payments, wallet for personal p2p payments and payment for services. What difficulties did you encounter when implementing the above areas?

D .: Initially, we wanted to make a payment service specifically for online stores - a payment aggregator in its classical sense, as at the time when No. 161- “On the national payment system” was not adopted. Then we just realized that this is not optimal. We had to spend some time to realize this and develop a new plan, to understand how we will develop our e-wallet.

If we talk about specific difficulties, then banks, for example, do not like payment aggregators. What is a bank aggregator? This is an opaque project. On the one hand, it attracts customers to the bank, which is good. On the other hand, for a bank, working with an aggregator is a constant challenge. For example, banks offer differentiated commission rates directly to their customers: small - high rates, large - low. When the aggregator arrives at the bank, it requires a single low rate for all its customers, the bank responds with a squeak. There are many banks that, in principle, do not work with payment services.

We managed to reorient ourselves in time and direct our efforts in the right direction. Some of our competitors-competitors, whom we, of course, will not name, in our opinion still are moving not quite in that direction. Although No. 161-FZ has already been adopted, there are many nuances that should have made them think, but they do not do this, but continue to work as they worked, go to offshore jurisdictions. We work completely in the legal field.

I .: The main difficulty we encountered was not with us, but with our settlement bank, which at that time was our only one. This happened at the end of April of this year. We worked with the settlement bank RNKO RIB.

The regulator issued an order to RNKO RIB, which also served other payment services, to restrict payments in favor of individual entrepreneurs and individuals, as a result of which our wallet was almost completely blocked. We could not make payments to individuals, and payment acceptance was badly damaged.

Could you indicate in a few words the bottleneck of the Russian payment market?

D .: Not so long ago, the law “On the National Payment System” was passed. If earlier the aggregator could take money into its current account and settle with merchants directly, now, according to the existing legislation, namely No. 161-, the aggregator cannot make calculations in favor of third parties. Those. within the framework of the law, the aggregator as a payment agent is not entitled to make settlements with online stores (including with other suppliers of goods, works, services), since the legal structure, including No. 161-, regulates the relations of entities related to the acceptance of payments and accepting cash and does not provide for banking operations using electronic means of payment.

Speaking of the aggregator, I mean not a licensed company. Calculations in favor of third parties have the right to conduct only organizations with a license of the Central Bank of the Russian Federation: this can be either a bank or NNCO.

When they accepted No. 161-, the services that worked without a license began to think what to do. Some have collected the necessary amount and obtained a license, in fact, having turned into NNKO - the bank itself for its payment service. The rest in this situation were forced to either close or invent something else.

I .: What is a NNCO and where did they come from? Initially, when the banking system of the Russian Federation was just being formed, licenses were distributed, we will call things by their names, everyone in a row. The requirements were minimal: in fact, anyone who had a small amount of money could register their bank. Next, the regulator began to tighten the nuts. At one point, the Central Bank took the next new requirements in order to consolidate the banks.

D .: This process continues to this day, now it is especially obvious, banks simply close one by one.

I .: Many banks faced a choice - either to cease to exist, or to get a curtailed license of the RNKO, the settlement non-bank credit organization. This license allows you to open accounts and carry out services for legal entities and individual entrepreneurs. NNKO can also make money transfers of individuals without opening an account, that is, they can be operators of electronic money.

One of these banks, which was before this difficult choice, was a small Moscow bank called RIB. They did not dare to close themselves and became NNCO. Literally after a year or two, they adopted the Federal Law No. 161, according to which all aggregators should come up with something, and most of the currently known payment services without their own license began to work with RNKO RIB as a settlement bank.

You said that after the adoption of the Federal Law No. 161, payment services had to take decisive actions, and cited as an example some of your colleagues who act unproductively, going offshore, for example. And what is your approach?

D .: We concluded that we would either have to work with one NSCA and bear enormous risks, or form a pool of several credit organizations. So that in case of problems with one NCO, we can direct the financial flows of our clients to other credit organizations.

I .: To begin with, remember the situation with the payment service ROBOKASSA, which was part of Ocean Bank. In April, he was left without a license. At the end of last year, ROBOKASSA service began working with RNKO RIB. Less than a month later, the regulator came with the instruction to limit payments in favor of individual entrepreneurs and individuals. Since ROBOKASSA had a lot of payments in favor of IP, the Central Bank considered this a dubious scheme, and all payment services that worked with RIB (there were a dozen of them, including us) were in a difficult situation.

D .: All services are faced with a difficult choice in this situation. Some simply stopped payments. For clients, this has become a real shock therapy.

And how do you implement a mechanism that allows your customers to not interrupt the process of accepting payments in the event of a sudden problem with a RNCO?

D .: As soon as there was a problem with RIB, we immediately ran through the banks, quickly found alternative options, understanding that if you have an online business and there are no payments, then this is death-like. So we did not turn off our customers, but offered possible options so that our customers could decide which of them suits them better. I do not give assessments to the actions of my colleagues, it’s not for me to judge them, but in our understanding, disconnecting clients and putting them before the fact is the simplest solution, we did not do that.

When the problems were over, we realized that we could not depend 100% on a specific NSC. We respect RIB. Of course, emotionally this situation has knocked us out of the rut a bit, but we understand that their guilt is not here, in the end, they defended the whole story and continue to work.

We did not want to shut ourselves off, to go offshore too, and we decided to differentiate these risks and set a goal for ourselves that we should have at least three settlement banks in order for us to balance the flows between them. What problem are we doing this way? Our business, and consequently, the payments of our customers will not suddenly stop. The likelihood that there will be a check of the Central Bank in three banks at once, of course, exists. Still, it is somewhat lower than the likelihood that a check on some basis will come to one of the banks, as it came to RIB.

You have several NNCOs. How did you organize the distribution of financial flows between them? You said that if something happens to one NNCO, you immediately switch to another. How did you implement it from a technical point of view?

D .: We have certain requirements before we start working with a specific bank. We understand that a bank cannot enter into a contract and provide everything that is in the “RIB” in a week. Nevertheless, we have agreed a plan, and the bank is obliged to provide us with a service at the same level. I mean specific things, for example, the availability of all the same payment methods as our other banks. In order for all our banks to be interchangeable, we have a number of specific requirements for them.

AND.: Settlement bank must have a wide range of contracts. How many payment systems we have, payment methods, there should be contracts with a settlement bank. Since the financial flows go between the bank-operator of this payment system and our settlement bank, the bank, which becomes our settlement bank, has a difficult task - to walk through all the payment methods that we have, to all the banks that are behind these payment systems , enter into contractual relations with them and start working with them in order to receive money from them and to pay money through them. This is a long way, a lot of work, the need to have an adequate staff. Not any bank is able to quickly implement it.

D.: We have found people who have enough resources, have a desire, have the opportunity to develop in this direction. They pledged to bring their structure in line with our requirements. Naturally, we told about the “bottleneck” in the market that emerged due to problems with the Central Bank at some NSCs, explained what prospects this may have for the bank, and we found several like-minded people who gave us great human, temporary and financial resources.

You are talking more about your strategic task. It would also be interesting to hear how you implemented the process of switching from one NCO to another from a technical point of view. Does this happen automatically or in manual mode?

D.: If there are two interchangeable NCO systems with a certain set of contracts and, as a result, with a certain set of opportunities and services that another settlement bank with the same set of payment methods can provide, the issue of switching shifts a little to the creative plane. For example, for mobile operators that organize mobile payments, several settlement banks are listed in the offer at once, simply separated by commas. We are considering both this option and the option when we divide the NNCO by payment method, we consider the option when we transfer certain customers to one bank, others to the second. That is, this process is creative. The main thing is to solve the problem so that they are truly interchangeable, so that there is no situation in which, roughly speaking, only plastic cards are processed in one bank,and in the other - all possible options for admission and payment. Of course, this is problematic, but it is still better than having one bank, because in principle approximately 90% of payers are satisfied with a plastic card agreement. But still I would like to have a full-fledged service, so first of all we worked on it. When the main issue is resolved, it is not so difficult to technically implement the separation.

I .: We have implemented several payment models, i.e. there are parallel payment methods, for example, by credit cards. There are two parallel payment methods and there is an auto selection. There we decide which bank is more important, where it is cheaper for us, where our payments are faster.

D .: If a person does not specify his choice, for example, “I want to pay through the PSB”, but simply says that he wants to pay with a plastic card, then we choose the bank at our discretion, taking into account the client’s requests and our prioritization. All this happens in automatic mode by a specific internal algorithm.

I .: Through different payment systems, the user can select different algorithms manually, depending on the situation.

D.: We are one of the first to do this, so we are in a lively dialogue with banks. Our ideas are transformed. Initially, we solved the issue of security and sustainability of our own business and guarantee our customers, since we are responsible to them. We have solved this crucial question.

Now that you have already drawn conclusions and expanded the NNCO pool, you can transfer the financial flow from one NNCO to another so that the client does not have problems. Does it take time or does it happen instantly?

D.: The work goes in parallel. Clients are connected to two banks: at a particular time, payments are made either through one RNKO or through another. The bottom line is that all our customers can be serviced simultaneously in all banks. We had a certain scheme of work, we found banks that agreed to implement it for us.

Many of our clients, understanding that we are working with several banks, did not abandon us, but refused, for example, from RIB. They simply say they do not want to be served in this NNCO. Accordingly, we transfer them from “RIB” to another bank. But, in fact, each of our clients can work with all our banks. The idea itself is not complicated, it was more difficult to find banks that are willing to cooperate.

How does the regulatory framework in the industry correspond to the pace of development and market demand?

D.: We, like any normal people, are not very fond of when they are trying to regulate us. But I must say that now the legislation allows you to work and build quite comfortable schemes. Despite the fact that, in addition to №161-, there is also №115- “On counteracting the legalization (laundering) of incomes”, which all banks fear and in which all identification requirements are spelled out. The law allows to work and under the contract of the offer. There is also an opportunity to take a compact and convenient for our customers - online stores a set of documents. We can take scans from them, work with them on the offer. In general, all this is fully within the scope of the legislation. In my opinion, our current legislation is generally in keeping with the spirit of the times and meets the needs of the market.

That is, everything suits you?

I .: Of course, I would like the state to finally define new technologies, for example, cryptocurrency, and define interaction within the CIS, because many of our customers complain that they want to transfer money from electronic wallets across the CIS, and the current identification requirements do not allow to do this.

D.: Another place where I would like the situation to change a bit is massive payments. This is a very popular service. There are microfinance organizations. It is clear that there are also fraudulent MFIs, but most of them are normal. They want to work online, issue loans to a plastic card and accept payments through the site. Unfortunately, our regulator perceives such operations as doubtful. And the banks, respectively, do not want to work with them. In practice, of course, those who need it can connect mass payments, but it is difficult - the client must provide a whole pile of documents, his financial statements so that the bank or payment service can penetrate into all financial flows. We are doing this because we do not want to lose a client. But if this mechanism were thought out more perfectly, both to the people and to us,it would be much easier. Now we have our own methods of checking such clients, as well as our own rules for setting limits and interaction in general.

Your comment is interesting regarding the news about the launch of the simplified identification process by the LEADER payment system. From the text of the material, it follows that thanks to the informational interaction with the FTS, the LEADER clients have the opportunity to identify themselves when transferring funds online in a simplified manner - by entering only the TIN. How this method of identification can be effective in your opinion?

I .: With one of our settlement banks, we implemented an identification service through the ESIA . What it is?If a user has an account on the portal gosuslugi.ru, that is, he enters his personal account through the portal of public services, the ESIA system sends us his passport data, this allows you to go through the process of full identification in the electronic wallet without personal presence.

D .: There are several levels of identification. There are unidentified users of the wallet ( ESP of the first type), for them the limit per transaction is 15 thousand rubles. There is a simplified identification (ESP of the second type), which allows transactions of up to 60 thousand rubles at a time and up to 200 thousand per month. In order to pass it, the user needs to provide his mobile phone, e-mail address, passport data and provide one of three documents to choose from: it can be TIN, CHI or SNILS .

ESP-3 is a complete identification, within which you need to provide a copy of your passport, address and other data. There are more limits - up to 200 thousand rubles per transaction and 600 thousand per month. But the full identification in the e-wallet pass units. These are those who need to get a higher limit: they come to the bank, are identified, but there are very few such customers.

In my opinion, such a scale is quite reasonable. Of course, I would like a little more freedom, but in general, all needs overlap.

Share your experience, what promotion tools can you use when developing a payment system, while at the same time attracting the attention of your target audience?

D.: We beat from all guns. Like any commercial structure, we balance between the resources and the goals that we face. There are different types of advertising and ways to reach out to customers. We have developed what we are doing well.

I .: We have open affiliate programs, various automated ways to attract users, a partner office in which our partner can see all of his connected clients. Depending on the turnover, the partner receives his remuneration, which is paid either to the wallet or to the legal entity, if it is a legal entity.

D .: We do a lot of integrations. We have SEO, context, distribution of press releases. In general, everything is like at all.

It is also important for the payment system to have its own button in the terminal. We did it only after the lapse of time. At the start it was more difficult, because nobody knew us, the infrastructure was not fully implemented, the incoming rates were high, nobody wanted to work with us, a vicious circle. Clients do not know you, you cannot connect clients, without clients there is no turnover, without turnover you cannot receive normal incoming conditions, without normal conditions you cannot interest and connect clients.

When you go out of this vicious circle through super efforts, everything becomes much simpler. When there is a stable volume, the very same people who didn’t want to talk to us at all a year or two ago are now much more open.