The Central Bank of the Philippines issued a memorandum reminding BSP-supervised financial institutions authorized to offer electronic money services that the authority applies only to the entity approved by the BSP. Institutions must not enter into arrangements that allow another person or entity to conduct, or appear to conduct, regulated e-money activities without BSP authorization. The reminder covers technology service, platform access, co-branding, partnership, wallet provisioning, outsourcing and similar arrangements. These structures must comply with the National Payment Systems Act, payment system rules and other applicable licensing, registration, prudential, consumer protection and risk management requirements. In assessing arrangements, the BSP may look at the functions actually performed, how responsibilities and risks are allocated, customer-facing representations, control over funds or accounts, and whether another party is effectively carrying out activities that require BSP authority. The authorized entity remains fully responsible for its regulated activities and for compliance with governance, risk management, safeguarding of customer funds, liquidity, disclosure, consumer protection and regulatory accountability requirements. Violations may lead to supervisory or enforcement action against the institution and responsible directors, officers or persons, including applicable sanctions under the National Payment Systems Act and other BSP rules.