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I've monitored several threads concerning alternatives to e-Passporte. I believe that all of the alternatives represent a certain amount of risk. Many of them are following the same or similar business models to e-Passporte.
Specifically, you have wallets that allow affiliate programs to load funds into their wallets and transfer those funds to wallets owned by the recipients for withdrawal from a card product.
Until a company comes along that provides assurances that their internal transfer systems operate in compliance with regulatory best practices (AML, SAR, OFAC, et al) and ensure that their services aren't used for Gambling or other proscribed business models there will continue to be a significant risk of loss to both program operators and affiliates.
These assurances could be provided by conducting regularly scheduled independent audits of the company's internal operations, controls and risk management that are published to wallet holders. Further, regular financial disclosure would allow users to feel more secure about the company holding their walleted funds.
These disclosures are required of banks in the U.S. and almost every international jurisdiction has regulatory oversight requirements established by their respective central banks. As private companies, these wallets are operating in a shadowy area that requires no regular review or disclosure other than the PCI compliance and basic compliance required by the card associations to issue a branded card product.
Until such a company comes along, it's a case of buyer beware. The benefits of having a means of providing instant funds access may well out-weigh the risks, but that remains to be seen.
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