Medical tourism is a $100+ billion global industry that’s growing rapidly as patients seek care across borders for better quality, affordability, or access to treatments unavailable at home. But behind the impressive growth and innovation lies one of the least understood and most dangerous risks facing facilitators, hospitals, and clinics: how patient payments are handled.
Across the world, governments are tightening financial regulations, banks are scrutinizing cross-border transactions more closely, and consumers are demanding stronger protections. Yet, many medical tourism businesses still rely on outdated and illegal payment practices — often without realizing it.
The most common mistake? Accepting or transferring patient money without the proper financial licenses or compliance systems in place.
This isn’t a U.S.-only problem. Laws regulating money transmission, remittance, and cross-border payments exist across virtually every region. And if you’re operating internationally, chances are you’re already subject to several of them.
This article breaks down the global legal landscape and explains why compliance with payment regulations is no longer optional for anyone involved in medical tourism.
Why Payment Compliance Is Now a Global Imperative
Medical tourism used to be a largely unregulated sector. Facilitators would collect patient funds and forward them to hospitals abroad. Hospitals would accept money from intermediaries with little thought about how it was collected. Everyone assumed this was harmless — until regulators started paying attention.
Today, governments worldwide view the handling of customer funds as a regulated financial activity. In most jurisdictions, if you:
- Accept money from a patient
- Hold, manage, or control that money
- Transfer it to a hospital, clinic, or third party
…you are engaging in money transmission, remittance, or payment services — activities that require licenses, registration, compliance programs, and reporting.
Failure to comply can result in fines, frozen accounts, criminal charges, and reputational damage — and these risks exist in every major region of the world.
Europe and the United Kingdom: Payment Services Under Strict Supervision
The European Union and the United Kingdom are among the strictest regions in the world when it comes to payment regulation. Under the EU’s Payment Services Directive 2 (PSD2) and the UK’s Payment Services Regulations 2017, any company that receives funds from a customer and transmits them to a third party must be authorized or registered as a payment institution or electronic money institution.
This includes businesses in healthcare and medical tourism — even if payment handling is not their primary activity.
Key points:
- A facilitator in London who accepts money from a patient and sends it to a clinic in Turkey is likely considered a “money remittance business” and must register with the Financial Conduct Authority (FCA) or HM Revenue & Customs (HMRC).
- Similar obligations apply in EU countries under PSD2, with supervision by national financial authorities (e.g., BaFin in Germany, ACPR in France, CNMV in Spain).
- Violating these regulations can lead to criminal penalties, business shutdowns, and confiscation of funds.
Even hospitals and clinics that knowingly accept money from unlicensed intermediaries can face liability for aiding and abetting financial violations or receiving proceeds of unregulated activity.
Canada: Strict Rules for Money Services Businesses (MSBs)
Canada’s approach to cross-border payments is governed by the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and enforced by FINTRAC, the national financial intelligence unit.
Any business that receives funds from clients and transmits them domestically or internationally may be considered a Money Services Business (MSB) and must:
- Register with FINTRAC
- Implement robust anti–money laundering (AML) and know-your-customer (KYC) procedures
- Maintain transaction records and report suspicious activity
If a Canadian facilitator accepts $8,000 from a patient and wires it to a hospital in Colombia, they are almost certainly performing a regulated activity. Operating without registration is a criminal offense, punishable by:
- Fines of up to C$500,000 per violation
- Imprisonment for up to 5 years
- Freezing or forfeiture of accounts and assets
Canadian regulators have already fined and shut down businesses in sectors like immigration, education, and travel for unlicensed money transmission — medical tourism is next.
The Gulf Region: Rapidly Strengthening Financial Oversight
The Gulf Cooperation Council (GCC) — including Saudi Arabia, the UAE, and Qatar — is rapidly strengthening its financial regulatory frameworks. These countries are pushing to become global financial hubs and are applying strict AML and payment compliance standards.
- In Saudi Arabia, the Saudi Central Bank (SAMA) oversees payment services and money transmission under the Anti-Money Laundering Law. Businesses that collect or remit funds must hold a SAMA license.
- In the UAE, the Central Bank regulates all payment service providers under the Retail Payment Services and Card Schemes Regulation.
- Qatar enforces similar rules through the Qatar Central Bank, requiring licensing for payment services and imposing strict penalties for unlicensed activity.
Medical tourism facilitators or agencies based in GCC countries that accept patient money and send it abroad without authorization risk severe consequences, including license revocation, bank account closures, fines, and criminal liability.
Latin America: Different Laws, Same Principles
Latin America is increasingly aligning with global financial compliance norms, even though laws vary from country to country.
- In Colombia, the Superintendencia Financiera de Colombia regulates financial services. Any entity involved in the transfer of funds must comply with licensing and AML requirements.
- Panama’s Superintendency of Banks and Superintendency of Non-Financial Entities regulate cross-border payment activities, requiring registration and reporting.
- In Mexico, payment services and remittance activities are regulated by the National Banking and Securities Commission (CNBV) under the Financial Technology Institutions Law.
For facilitators operating in or sending money to these countries, ignorance of the law is no defense. Even if the facilitator is based elsewhere, the moment funds enter or leave a regulated financial system, local laws may apply.
Asia: Expanding AML and Payment Compliance
Asia is home to some of the fastest-growing medical tourism markets — and increasingly stringent financial regulations.
- Singapore requires remittance businesses to hold a Major Payment Institution (MPI) or Standard Payment Institution (SPI) license under the Payment Services Act 2019.
- Malaysia and Thailand regulate cross-border money transfer services under their central bank frameworks.
- India’s Reserve Bank imposes strict licensing on payment service providers and money transfer operators.
- Even Turkey, a major destination for medical travel, requires authorization from the Central Bank for anyone facilitating payments under Law No. 6493.
In all these countries, the underlying principle remains the same: handling client money is a regulated activity, no matter your industry.
“We Didn’t Know” Is Not a Defense Anywhere
A common misconception among medical tourism businesses is that ignorance protects them. It doesn’t. Across nearly all jurisdictions, willful blindness — deliberately avoiding knowledge of the law — is treated as equivalent to actual knowledge.
If you:
- Regularly receive patient money in your account
- Forward it to hospitals overseas
- Fail to verify whether licensing or registration is required
…you cannot claim ignorance as a defense. Regulators and courts will argue that you “should have known” the activity was regulated.
Hospitals are not exempt either. If they knowingly accept funds collected through unlicensed facilitators, they risk aiding and abetting violations, facing civil lawsuits, and suffering reputational harm if patient funds are lost or misused.
Global Risks, Real Consequences
The consequences of non-compliance can be devastating:
- Fines and penalties: Regulators around the world regularly impose six- and seven-figure fines on unlicensed money services businesses.
- Account freezes: Banks can freeze accounts they suspect are being used for unlicensed payment activity, cutting off access to critical funds.
- Criminal charges: In many jurisdictions, unlicensed money transmission is a criminal offense punishable by imprisonment.
- Civil liability: Patients or hospitals can sue for negligence, fraud, or breach of fiduciary duty if funds are lost.
- Reputational damage: A single high-profile incident can destroy trust and partnerships across the industry.
These risks aren’t hypothetical — they’ve already happened in sectors like immigration, education, real estate, and online marketplaces. Medical tourism is now firmly in regulators’ sights.
The Solution: Compliant Payment Infrastructure Built for Medical Tourism
The safest and smartest path forward is to eliminate the risk at its source: stop handling patient money directly and instead use licensed, regulated payment platforms designed for cross-border healthcare.
That’s why solutions like Better by MTA, created in partnership with Mastercard, are so important. They provide the medical tourism industry with a compliant, transparent, and secure way to manage patient payments globally.
With Better by MTA:
- Patients pay through a regulated payment system, not through a facilitator’s personal or business account.
- Funds are handled in full compliance with financial regulations in both the sending and receiving countries.
- Hospitals receive payments securely and legally, without exposing themselves to legal or reputational risk.
- Facilitators remain central to the patient journey without crossing into regulated financial territory.
This model protects every stakeholder — patients, facilitators, and hospitals — and ensures that the medical tourism industry can grow sustainably without fear of legal challenges or financial enforcement.
Payment compliance is no longer a “nice-to-have” in medical tourism — it’s a necessity. Laws regulating how money moves across borders exist in nearly every country in the world, and they apply to medical tourism just as they do to banks, fintech companies, and payment processors.
Facilitators, hospitals, and clinics that ignore these laws do so at their peril. Those that adapt, embrace compliant infrastructure, and put patient protection at the heart of their payment systems will be the ones that thrive in the next era of global healthcare.
The future of medical travel depends not just on delivering excellent care but on building trust from the moment a patient makes a payment. With solutions like Better by MTA and Mastercard, the industry finally has the tools to do exactly that — legally, securely, and globally.
Better by MTA was designed in partnership with Mastercard to bring trust, compliance, and security into every payment. It allows patients to pay with confidence, knowing their money is protected and handled through regulated channels. Hospitals receive funds directly and securely, without exposure to legal or reputational risk. Facilitators can focus on care coordination without stepping into regulated financial territory.
By integrating Better by MTA into your patient payment process, you transform a major source of risk into a powerful advantage. You’ll close more patients because they trust the process. You’ll build stronger partnerships because providers and payers know you’re compliant. And you’ll future-proof your business as regulations tighten around the world.
If your business still relies on outdated payment practices, now is the time to evolve. Visit https://better.medicaltourism.com to learn how Better by MTA can protect your patients, your reputation, and your future.
