Medical tourism is booming worldwide as patients cross borders for specialized treatments, better quality care, or more affordable options. Facilitators — the intermediaries who help patients plan and manage these journeys — are a vital part of this ecosystem. They coordinate care, arrange travel, communicate with providers, and often guide patients through complex decisions.
But many facilitators are unknowingly putting themselves — and their hospital partners — at serious legal and financial risk by doing one thing they often don’t think twice about: collecting patient money and forwarding it to providers.
It may sound harmless, even helpful. But across most jurisdictions worldwide, accepting funds from a patient and sending them to a hospital is not a simple business transaction — it’s a regulated financial activity. And if it’s done without proper licensing, oversight, and consumer protection mechanisms in place, it can violate financial laws in multiple countries at once.
This is one of the biggest blind spots in the global medical tourism industry — and one that facilitators, hospitals, and even patients can no longer afford to ignore.
The Hidden Legal Risk in a Common Practice
Let’s look at a very typical example:
A facilitator in the United Kingdom helps a patient arrange bariatric surgery in Turkey. The patient wires £7,000 directly to the facilitator’s business account. The facilitator later transfers the funds to the Turkish hospital.
This is standard practice for thousands of companies around the world. But under UK law, that facilitator is almost certainly acting as a “money remittance business” — a type of financial services company that must be registered with the Financial Conduct Authority (FCA) or HM Revenue & Customs (HMRC) and comply with anti–money laundering (AML) and financial reporting laws.
Without the proper authorization, the facilitator is operating illegally, even if they have no intention of wrong doing.
The same principle applies in many other jurisdictions:
- A facilitator in Canada collecting payments from patients and wiring them to a clinic in Colombia could be considered an unregistered Money Services Business (MSB) under Canadian federal law.
- A facilitator in Saudi Arabia receiving funds from patients and forwarding them to a hospital in Germany could trigger scrutiny under the Kingdom’s strict Anti-Money Laundering Law and Saudi Central Bank (SAMA) regulations.
- A company in Mexico handling patient funds destined for a provider in Thailand could face penalties under Mexican financial laws for operating as an unlicensed remittance business.
In all these cases, intent is irrelevant. Even if the facilitator’s only goal was to help the patient, they are performing a regulated financial service without authorization — and that is often a criminal offense.
Why “We’re Not a Bank” Isn’t a Defense
Many facilitators believe they’re not subject to financial laws because they are “just a healthcare company,” not a bank or payment processor. But regulators around the world define money transmission broadly.
If your business:
- Receives money from a client,
- Holds or controls that money, and
- Sends it to a third party (such as a hospital or clinic),
then you are almost certainly engaging in regulated financial activity.
It doesn’t matter if this is only a small part of your business. It doesn’t matter if you never describe yourself as a payment company. And it doesn’t matter if you only serve a few patients a year. What matters is what you are doing with the money.
Operating without the necessary registration, licensing, and compliance systems can lead to:
- Heavy fines and regulatory sanctions.
- Freezing of bank accounts and seizure of funds.
- Civil lawsuits from patients.
- Criminal prosecution in serious cases.
Cross-Border Transactions Multiply the Risk
The risk doesn’t stop at the facilitator’s home country. Because most medical travel payments involve funds moving across borders, multiple jurisdictions’ laws may apply simultaneously.
For example, a facilitator in Canada who accepts payment from a Canadian patient and sends it to a hospital in Colombia could trigger:
- Canadian MSB and AML laws (because the money originated in Canada).
- Colombian financial regulations (because the money is received there).
- International AML reporting requirements under treaties both countries have signed.
Similarly, a UK facilitator sending funds to Turkey could fall under:
- UK payment services regulations.
- Turkish banking and remittance laws.
- European AML directives if EU financial institutions are involved.
Violating even one of these regimes can have severe consequences. Violating multiple at once can lead to coordinated investigations, multi-jurisdictional fines, and even bans on operating.
“Knowingly” Benefiting from Violations Expands Liability
Some facilitators assume that if they “don’t know” the specific law, they can’t be held responsible. Unfortunately, that’s not how most legal systems work.
Authorities often apply the concept of “willful blindness” — if a business should reasonably have known that what they were doing was regulated, they cannot escape liability by claiming ignorance.
For example:
- If your bank warns you about receiving large client deposits and you ignore it.
- If you consistently receive patient payments and forward them abroad but never check licensing requirements.
- If you market yourself as “handling patient payments” but fail to put legal protections in place.
In these cases, regulators often treat you as though you had actual knowledge of the violations.
Even worse, your hospital partners could also face liability if they knowingly accept funds routed through an unlicensed facilitator. That’s why more hospitals are starting to refuse payments that don’t come through compliant, regulated channels.
Civil Lawsuits: A Hidden Danger for Facilitators
Even if regulators never get involved, facilitators still face major exposure from civil lawsuits.
If patient money is lost, stolen, or misdirected — or if the facilitator goes out of business before paying the hospital — patients (and sometimes providers) can sue. Courts in many jurisdictions allow plaintiffs to claim:
- Breach of fiduciary duty – because the facilitator was entrusted with funds for a specific purpose.
- Negligence – for failing to safeguard those funds properly.
- Conversion or fraud – if the money was misused.
Facilitators often underestimate how devastating these lawsuits can be. Even a single high-value claim can bankrupt a small or mid-sized business — and the reputational damage can end its future.
Real-World Consequences: Bank Account Freezes and More
Even before regulators act or lawsuits are filed, facilitators frequently run into another problem: their banks.
Financial institutions are required by law to monitor accounts for signs of unlicensed money services activity. If they see regular deposits from consumers followed by outbound international transfers, they may flag your account as suspicious.
Banks can and do:
- Freeze accounts without warning.
- Terminate banking relationships with unlicensed businesses.
- Report activity to financial intelligence units, triggering investigations.
Once a facilitator is on a bank’s internal watchlist, it becomes extremely difficult — sometimes impossible — to open new accounts elsewhere.
Hospitals Are Watching Too
Hospitals and clinics are increasingly aware of the risks associated with unregulated payments — and they’re starting to protect themselves.
If a hospital knowingly accepts funds collected illegally, it could face legal exposure for aiding and abetting financial violations. Even if it never intended to break the law, the fact that it benefited from those funds may be enough for regulators or courts to take action.
This means facilitators who rely on direct patient payments may find themselves losing partnerships as hospitals shift toward compliant payment platforms that protect both sides.
The Compliance Landscape Is Global — Not Just Local
Some facilitators assume that financial laws only apply in major markets like the U.S. or EU. But in reality, most countries now regulate payment services and money transmission.
- Canada requires all businesses engaged in transferring funds to register with FINTRAC and follow strict reporting rules.
- The UK and EU classify payment handling as a regulated financial service under the Payment Services Regulations and PSD2 directive.
- Gulf countries like Saudi Arabia, the UAE, and Qatar have robust AML frameworks and require licenses for any entity facilitating cross-border transfers.
- Latin American nations such as Colombia, Panama, and Mexico all have financial supervision laws that can apply to facilitators moving patient funds.
- Turkey regulates payment and electronic money institutions under Law No. 6493, requiring authorization from the Central Bank.
In nearly every jurisdiction, the pattern is the same: if you take money from one person and send it to another, you are entering regulated territory.
The Future of Medical Tourism Depends on Payment Trust
Medical tourism is built on trust. Patients trust facilitators to guide them safely through life-changing healthcare decisions. Hospitals trust facilitators to represent them professionally and deliver paying patients. And regulators trust that companies moving money across borders will do so legally and transparently.
When facilitators mishandle funds — even unintentionally — that trust collapses. Patients lose confidence. Providers distance themselves. Regulators crack down.
The result isn’t just legal risk — it’s a threat to the credibility and growth of the entire industry.
A Safer Way Forward: How Better by MTA and Mastercard Solve the Problem
Fortunately, the industry doesn’t have to keep operating in the legal gray zone. New payment solutions are emerging that allow facilitators, hospitals, and patients to operate confidently and compliantly — without risking violations of financial law.
One example is Better by MTA, built in partnership with Mastercard. It was designed from the ground up to solve the payment problem at the heart of medical tourism.
Here’s how it works:
- Patients pay directly through a secure, regulated platform rather than sending money to a facilitator’s personal or company bank account.
- The funds are safeguarded, tracked, and transmitted in compliance with financial regulations in both the originating and destination countries.
- Hospitals receive payment reliably, without exposing themselves to the risk of working with unlicensed intermediaries.
- Facilitators remain an essential part of the process — but without taking on the legal and financial risks of handling money directly.
This approach benefits everyone:
- Patients gain peace of mind that their money is protected.
- Hospitals avoid legal exposure and build trust with partners.
- Facilitators can continue focusing on service and patient care without crossing into regulated financial territory.
Most importantly, it allows the industry to evolve into a more professional, transparent, and trustworthy ecosystem — one where growth isn’t threatened by legal uncertainty.
The Time to Act Is Now
The era of “business as usual” in medical tourism payments is ending. Around the world, regulators are tightening financial laws, banks are increasing scrutiny, and patients are demanding stronger protections.
Facilitators who continue collecting and transmitting patient payments without proper authorization are taking enormous risks — not only for themselves but for their hospital partners and the patients they serve.
But those who adapt now, embrace compliant payment solutions, and educate their partners will not only stay on the right side of the law — they’ll also build stronger trust, deeper partnerships, and a more sustainable business.
The global medical tourism industry is evolving. How payments are handled will shape its future. The choice for facilitators is clear: continue walking a dangerous legal tightrope, or step confidently into a safer, compliant future with solutions like Better by MTA and Mastercard.
The safest and smartest way to restore trust and eliminate risk is to modernize how you handle payments. That’s exactly why leading hospitals, clinics, and facilitators around the world are adopting Better by MTA — the only medical tourism payment platform built from the ground up to solve these challenges.
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.
