Reminder Note to Circular 114-2 to money transfer houses
Summary: Reminder Note to Circular 114-2 to money transfer houses of the Bank of the Republic of Haiti — an instrument published alongside circular 114-2 to money transfer houses, not the circular itself. Circulars are the operative prudential rules for supervised institutions, covering matters such as capital and liquidity requirements, credit-risk and governance standards, reserve requirements and foreign-exchange rules.
Key Findings
- The reminder makes banks and transfer houses answerable for their sub-agents, not merely for their own conduct: they are required to have their sub-agents apply Circular 114-2 in international transfers without counterpart.
- Two concrete duties are named. Sub-agents must display the BRH reference rate and the average acquisition rate in a place visible to all at every service point, and those rates must actually be used to settle transfers. Display without use is treated as non-compliance.
- Enforcement is delegated upward with a reporting obligation: banks and transfer houses must send the BRH a quarterly list of the sub-agents that breach the circular and the measures taken against them.
- The sanction is aimed at the principal, not only the sub-agent. If banks and transfer houses fail to carry out that monitoring, they are themselves subject to the sanctions set out in section 5 of Circular 114-2.
- The note is dated 20 April 2022 and signed by the Deputy Governor, which places it between the entry into force of 114-2 and the later 114-3 sequence, and indicates that rate display at the point of service was not being observed.
How to cite
Bank of the Republic of Haiti (BRH), 2022, Reminder Note to Circular 114-2 to money transfer houses, https://www.brh.ht/wp-content/uploads/note-de-rappel-circulaire-114-2.pdf