On 16 August 2019 the German Federal Financial Supervisory Authority (BaFin) published a new guidance note regarding crypto tokens (GZ: WA 51-Wp 7100-2019/0011 and IF 1-AZB 1505-2019/0003). The guidance note dealt with prospectus and licence requirements in connection with crypto tokens and is intended to complement the BaFin’s explanatory letter regarding the supervisory classification of […]
Just as the excitement around strong customer authentication for online SEPA direct debits was beginning to settle, direct debits are under attack again: In a recent case before the CJEU, the Advocate General stated in his Opinion that it also constitutes undue IBAN discrimination if a merchant accepts SEPA direct debit payments only from customers […]
On 20 May 2019, the German Federal Ministry of Finance (BMF) presented its draft bill on the implementation of the 5th Anti-Money Laundering Directive. The legislator has taken the new anti-money laundering requirements from the 5th Anti-Money Laundering Directive regarding trading platforms for virtual currencies and wallet providers as an opportunity to further regulate crypto […]
Credit cards are becoming a popular method of payment in Germany. Approximately five percent of the turnover from all payments in Germany is processed via credit cards. Yet despite this, most people only have a very faint idea – if at all – of how a credit card payment works from a legal perspective. In […]
From 3 December 2018, the so-called Geo-blocking Regulation will enter into force in the European Union and therefore also in Germany. It is intended to prevent discrimination in cross-border transactions within the European Union, including geo-blocking. Who is affected by the Geo-blocking Regulation? The Geo-blocking Regulation affects traders, i.e. business persons who offer goods or […]
If you talk to insiders from the payment industry about prepaid card systems, they inevitably use terms such as closed loop, open loop and restricted open loop or semi-closed loop. What does closed loop, open loop, restricted open loop and semi-closed loop mean? In practice, the terms closed loop, open loop, restricted open loop and […]
5th Anti Money Laundering Directive (AML5) tightens requirements for anonymous e-money and makes cryptocurrency platforms and wallet providers subject to money laundering law Now it’s official: The 5th Anti-Money Laundering Directive (AML5) was published in the EU’s Official Journal on the 19 June 2018. The new directive will come into force on 9 July 2018 […]