The white label solution describes a constellation in which, for example, a FinTech that offers banking products for the self-employed and freelancers, but is not itself regulated, cooperates with a bank that provides the regulatory umbrella (e.g. Solaris, Varengold, Banking Circle). The bank then has a direct contractual relationship with the FinTech’s customer because the FinTech cannot provide a banking service. The bank must then carry out the KYC process; if the FinTech then issues a card, for example, and the card is e-money (credit card or debit card), the FinTech is to be regarded as an e-money agent, so that the KYC process only has to be carried out once by the bank.