Checklist / PayTechLaw view of section 25i para. 2 KWG

Persons who distribute e-money (distributors) are generally obliged to identify their customers. In addition, distributors must check whether a customer is a so-called politically exposed person (PEP-check). However, it is often difficult or even impossible to fulfil these obligations at the point of sale. There are exceptions: The identification and the PEP-check are not necessary if the conditions set out in Section 25i para. 2 KWG are met. In practice, it is unfortunately often not quite clear whether the requirements for the exception are met. We also do not know how the courts will decide one day. But we do have an opinion on how we interpret the conditions for the exception. We are happy to share this opinion with you – in detail in the corresponding blog entry on Section 25i para 2 KWG – as well as in the overview here in our checklist.