According to Section 1 para. 10 ZAG, an e-money agent is an independent trader who acts on behalf of an e-money institution with regard to the sale and redemption of e-money. Companies that sell or redeem e-money of a CRR credit institution are not e-money agents. However, just like e-money agents, they are obligated persons under Section 2 para. 1 No. 5 of the German Anti-Money Laundering Act (GwG).
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