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Virtual IBANs have become an established component of modern payment models. With Supervisory Notice 06/2026, BaFin now clarifies its expectations for credit institutions and payment service providers regarding transparency, anti-money laundering compliance and risk management in complex virtual IBAN structures.
ECJ Clarifies the Scope of PSD2: Not Every Transfer of Third-Party Funds Constitutes a Payment Service
- byPeter Frey
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The ECJ has further clarified the distinction between payment services and other business models. The judgment confirms that merely receiving and forwarding third-party funds does not automatically trigger licensing requirements under PSD2. The decision provides greater legal certainty for FinTechs, platform operators and other businesses handling payment flows, while emphasising that the specific business model remains decisive.
Remote Selling Law 2026: The Changes Banks and FinTechs Must Implement Now | ALLES LEGAL #143
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The new withdrawal function, enhanced consumer information requirements, chatbot regulation and the ban on dark patterns are reshaping digital financial services. Kemal Ahmedi discusses the practical implications for banks and FinTechs with Dana Wondra.
BRUBEG: What is changing for ESG, M&A and capital requirements | ALLES LEGAL #142
- byRenate Prinz
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BRUBEG places greater supervisory focus on ESG risks, M&A transactions and capital planning. Renate Prinz explains the new regulatory requirements for banks and why proactive planning will become increasingly important under the evolving supervisory framework.


