Information obligations under the Payment Accounts Act. Well intended. Not well implemented
The German Payment Accounts Act (Zahlungskontengesetz, ZKG) already entered into force in 2016. The key part of the…
„Bitcoin decision“: trading Bitcoin is not a crime – the end of crypto regulation?
In its “Bitcoin decision” of 25 September 2018, the Berlin Court of Appeal (case no.: (4) 161 Ss…
PayTechTalk 30: BaFin licence for payment institutions – this is how it works
Since the implementation of PSD2, or most likely even before, many companies have been preoccupied with one question:…
Prepaid cards: closed loop, open loop, restricted open loop or semi-closed loop?
If you talk to insiders from the payment industry about prepaid card systems, they inevitably use terms such…
PayTechTalk 29: KYC by Third Parties? This is how it works!
In PayTechTalk 28 haben wir uns intensiv mit dem Thema Geldwäscheprävention befasst und versucht, die wesentlichen Grundlagen zu vermitteln.…
KYC and the distribution of e-money: Do I have to or not? Section 25i para. 2 German Banking Act (KWG)
The German legislator transposed the requirements of the 4th EU Anti-Money Laundering Directive (AMLD 4) into German law…
PayTechTalk 28: KYC, AML and CTF. Fanta 4? Prevention of money laundering!
In PayTechTalk 28 I will be discussing an issue that is of great importance for our advisory practice…
Interchange Fee Regulation: gender-specific universal cards
The current debate concerning gender-political correctness would appear to suggest that there are not just women and men…
PayTechTalk 27: Grow out of its niche! “Sustainable Finance” with Tomorrow
We buy organic vegetables, use green energy, are considering purchasing an electric car and always take our cloth…
PayTechTalk 26 – PayPal and Simple Language
Simple Language is important. Many people need Simple Language in order to understand everything. Only if you understand…
On a Secret Mission: Payment Agents and E-money Agents in German Regulatory Law
As is often the case with people like James Bond, agents in payments law are difficult to come…
Virtual currencies deciphered (2) – Identity crisis: VC versus e-money
In my last blog post “Virtual currencies deciphered (1): the new legal definition and AMLD5” I discussed the…
Update re intra-group exemption
The German regulator BaFin lately issued a very narrow interpretation of the BaFin intra-group exemption. However, if group…
Is nobody expecting the Spanish Inquisition? The scope of the right to information under Art. 15 GDPR
Art. 15 GDPR (EU General Data Protection Regulation) stipulates in detail which rights of information a data subject can…