PhonepayPlus Discussion Paper on Due Diligence and Risk Assessment

September 3, 2012

One year on from the implementation of the twelfth edition of its Code of Practice on 1 September 2011, PhonepayPlus  has decided to take stock of this changed approach and to set out some thoughts for discussion about due diligence and risk assessment and control, based on the regulator’s experiences over the last 12 months.

When the Board of PhonepayPlus devised its new approach to regulation, its aim was to offer the sector a new compact:

  • outcomes-based Code with fewer rules
  • lighter level of intrusion for minor breaches through an informal resolution process
  • targeted regulation bearing down more heavily on the ‘polluters’ rather than the intermediaries.

All of this was intended to be in return for tighter standards of due diligence and risk assessment amongst networks and aggregators to keep the most persistent and obvious offenders out of the market.

The discussion paper points to some positive signs and PhonepayPlus is encouraged by the responses taken by a number of networks and providers to changing their practices. But, as the paper concludes by stating, more will need to be done lest those who have made that shift believe that they suffer at the hands of those who continue as before. PhonepayPlus believes it is therefore ‘at a critical point in [its] journey towards implementing the new regulatory framework’ and has ‘the clear chance of working with industry to engender a step change in compliance and trust’. The alternative it contemplates would be a continued ratcheting-up of investigations, sanctions, fines and the overall cost of regulation.

If you are interested in commenting on the discussion paper, follow the directions in the paper to get in touch.

Link to the PhonepayPlus’ discussion paper on due diligence.