Notice to Circular 121 to electronic payment service providers
Summary: Notice to Circular 121 to electronic payment service providers of the Bank of the Republic of Haiti — an instrument published alongside circular 121 to electronic payment service providers, 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 notice grants a nine-month penalty exemption, expiring 31 May 2025, to electronic payment service providers for clients not yet identified, and states the reason: a relatively large number of clients remain unidentified because of the difficulty of obtaining the official identity document required.
- The exemption is conditional on reporting. Providers must send the BRH a quarterly report on the progress of the identification process, explicitly comparing planning against achievement.
- The forward-looking rule is not suspended. Providers remain bound to identify clients at account opening under point 8 of Circular 121, and any violation of that provision is penalized under the circular. The relief covers the existing backlog, not new accounts.
- The underlying constraint is a national one rather than a compliance failure: identification depends on official identity documents that a large share of clients cannot obtain, which links payment-system inclusion to civil registration capacity.
- The notice is dated 21 August 2024 and signed by Ronald Gabriel.
How to cite
Bank of the Republic of Haiti (BRH), 2025, Notice to Circular 121 to electronic payment service providers, https://www.brh.ht/wp-content/uploads/Avis-aux-FSP-circulaire-121-aout-2024.pdf