Anonymous e-money describes e-money products for which the buyer of the e-money does not have to be identified under applicable anti-money laundering law. This is usually the case if the requirements of S. 25i para. 2 German Banking Act (KWG) are met and the e-money issuer as well as the distribution points are not subject to identification requirements under applicable anti-money laundering law.
It is unclear whether corporate cards also constitute anonymous e-money. In the case of corporate cards, the company as the buyer is identified but the employees actually using the card – as authorised by the company – are not.