Analysing a system of settlements under a loyalty programme of a settlement non-banking credit institution

23 June 2022

Analysing a loyalty programme of a non-bank credit institution

A company decided to launch a loyalty programme to increase the total number of payments through a non-bank credit institution using bank cards of third party banks and own e-wallets. Points are given for each purchase through payment forms and for certain actions (registration of a wallet, identification, adding a bank card etc.). The amount of points is determined by the organiser of the loyalty programme, the payer may spend points when making a purchase and select the number of points to be used.

Analysing and reviewing the loyalty programme for compliance with the legislation.

Checking the loyalty programme for compliance with the banking legislation in respect of the settlement procedure and use of points by participants of the loyalty programme.

Evaluating loyalty points from the perspective of their legal nature, correlation to digital money in accordance with the Federal Law on National Payment System (Law No. 161-FZ dated 27 June 2011).

Analysing requirements to tax and financial accounting for accrual of loyalty points, checking the cash flow scheme for compliance with the Russian banking legislation and identifying related risks.

Advising on adjustment and implementation of the loyalty programme fully compliant with the legislation.
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