The instructions for the interpretation and application (IIA) of the German Federal Financial Supervisory Authority (BaFin) on the German Anti-Money Laundering Act are still quite new. BaFin published them at the end of last year, on 11 December. Peter already took a detailed look at the so-called IIA on PayTechLaw in January. During the […]
Recently I looked into the topic of licence types for payment service providers on PayTechLaw. In my blog post “May I or may I not? The licence types for payment service providers” I introduced the various licence types – and also created an infographic for those of you who prefer looking at visuals than […]
From 14 September 2019, strong customer authentication will be required for certain payment transactions. The EBA has now provided some commentary on what this means for SEPA mandates that are issued via remote access. In short, if the EBA were to prevail with its legal opinion, this would have a huge impact on online direct […]
Perhaps you’ve experienced this before? When talking to different people about what licence is required for payment services, you get a multitude of different answers: some will tell you something about an e-money licence that you need. Others think that a “small PSD licence” is entirely sufficient. And others are of the opinion that you […]
Do you know the type of questions where the answer depends on who you ask? An example of such a question is what constitutes a payment service. If you ask the legislator, the answer will be a more or less comprehensible but rather abstract catalogue of activities. If you ask a lawyer, he or she […]
Since the implementation of PSD2, or most likely even before, many companies have been preoccupied with one question: How, as a payment institution, do I get a BaFin licence? In this episode of PayTechTalk, we deal with all the important questions concerning permission applications. This is how the approval for a BaFin licence for payment […]
The German legislator transposed the requirements of the 4th EU Anti-Money Laundering Directive (AMLD 4) into German law on 23 June 2017. At that time, many market participants (including ourselves) were full of hope. The parties concerned wanted practical rules and, above all, more clarity. A good year later, many have become disillusioned. This certainly […]
On 28 March 2018, the European Commission presented a proposal for an amendment to Regulation (EC) No. 924/2009 on cross-border payments within the EU (EU Fees Regulation). With the amendment, the Commission wants to create new information obligations regarding currency conversions. One of the Commission’s aims is to address some of the problems related to […]
On 25 January 2018 the European Commission published its report on the implementation and impact of the 2nd E-Money Directive (2009/110/EC; EMD2). In its report, the Commission, inter alia, looks at the implementation of EMD2 and its impacts. Additionally, it deals with the effects of PSD2 on the e-money business and the interrelationship between EMD2 […]
On 29 November, BaFin published the long-awaited, newly amended guidance note on the German Payment Supervisory Act (PayTechLaw already reported on the BaFin guidance). In its note, BaFin not only addresses the changes that are made due to the transposition of PSD2. It also deals with payment transactions on online platforms and marketplaces that bring […]