Visa 2015 Annual Report Download - page 29

succeed. This could adversely affect our ability to operate our business, maintain or increase our
revenues globally and extend our global brands.
We are subject to regulation in the areas of consumer privacy and data use and security.
Privacy, data use and security continue to receive heightened legislative and regulatory focus in
the U.S. and elsewhere. For example, in many jurisdictions consumers must be notified in the event of
a data breach and those jurisdictions that have these laws are continuing to increase the
circumstances and the breadth of these notices. These laws and regulations can impact the way we
use and handle data, operate our products and services, and even impact our ability to offer a product
or service. Our failure or the failure of our clients to comply with these laws and regulations could result
in fines, sanctions, litigation and damage to our global reputation and our brands. These laws and
regulations may increase Visa’s and our clients’ costs, decrease the number of Visa-branded cards our
clients issue and decrease our payments volume and revenue.
Evolving and increased global regulatory focus on the payments industry may result in costly
new compliance burdens on our clients and on us.
Regulation of the payments industry has evolved and increased significantly. Examples include:
•Data protection and information security. Aspects of our operations and business are subject
to privacy and data protection regulation in the U.S. and elsewhere. Our financial institution
clients around the globe are subject to similar requirements under privacy laws and bank
regulatory regimes. For example, as of September 1, 2015, Russia amended its personal
data law to require personal “data operators” to store personal information of Russian
citizens in databases located in Russia. In addition, many U.S. states have enacted
legislation requiring consumer notification in the event of a security breach.
•Regulatory and sanctions compliance. We are subject to anti-money laundering laws and
regulations, including the U.S. Bank Secrecy Act and the Patriot Act. In addition, we are
subject to economic and trade sanctions programs administered by OFAC. An increase in
the number of OFAC sanctions may affect the issuance, acceptance, reputation, and
revenues associated with Visa-branded cards. Some of our clients located outside of the
U.S. may not be subject to these same laws, regulations and sanctions, and, as a result,
may initiate transactions that are permissible in their countries but that may not be
permissible were the transaction to take place in the U.S.
•Regulation of the price of credit. Many jurisdictions in which Visa-branded cards are used
have regulations that could increase the costs of card issuance or decrease the flexibility of
issuers to charge market-based interest rates and fees on credit card accounts. In the U.S.,
these include regulations issued under the Truth in Lending Act of 1968, as amended by the
Credit CARD Act of 2009.
•Increased U.S. Consumer Financial Protection Bureau scrutiny. Regulatory changes by the
CFPB that impose new requirements on or restrict the terms under which financial products
can be offered could increase our clients’ costs and decrease the number of Visa-branded
payment cards our clients issue. The CFPB also has supervisory and independent
examination authority as well as enforcement authority over certain financial institutions,their
service providers and other entities,which could include us due to our processing of credit,
debit and prepaid transactions.
•Increased central bank oversight. Several central banks and similar regulatory bodies around
the world have increased, or are seeking to increase, their formal oversight of the electronic
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