Subject to any exceptions, money remittance business is a payment service which requires a licence.
Pursuant to Section 1 para. 1 sentence 2 no. 6 of the German Payment Services Supervision Act (ZAG), this refers to services where, without opening a payment account in the name of the payer or the payee, an amount of money is received from the payer for the sole purpose of transmitting a corresponding amount to a payee or to another payment service provider acting on behalf of the payee, or where the amount of money is received on behalf of and made available to the payee.
Money remittance business acts as a catch-all provision for services which transfer funds in accordance with the instructions received and which do not fall under any of Section 1 para. 2 sentence 2 nos. 1 to 5 ZAG. Money remittance business is described in more detail in BaFin’s guidance note (Hinweise zum Zahlungsdiensteaufsichtsgesetz (ZAG) dated 22/12/2011, as amended on 29/11/2017 under item 2. e)).