Payment services supervisory law

We comprehensively advise our clients on all matters relating to payment services supervisory law. They are active in all areas involved in payment transactions (in particular banks, payment institutions, e-money institutions, FinTechs, telecommunications companies, retailers, intra-group payment factors, processors and other technical service providers, industrial companies, marketplaces, loyalty systems, central regulators).

We particularly specialise in advising on the following areas in payment services supervision law:

  • Development and structuring of business models to avoid the need for a licence under the respective payment services and/or banking regulations
  • Support for licensing and registration procedures as a payment institution or e-money institution
  • Passporting procedure
  • Activation of agents and e-money agents
  • Clarification of any issues involving the Federal Financial Supervisory Authority (BaFin), the Luxembourg Supervisory Authority of the Financial Sector (CSSF) and other supervisory authorities
  • Advice on the fulfilment of regulatory requirements in payment transactions (e.g. PSD2, EMD2, SCA-RTS, ZAG and accompanying regulations, SEPA, interchange regulation, anti-money laundering, announcements of the European Banking Authority (EBA), BaFin and the CSSF)
  • Creation of process descriptions, work instructions and manuals (e.g. anti-money laundering manuals, risk manuals and risk analyses)
  • Card-based payment methods (issuing & acquiring)
  • E-money products
  • Invoice and hire purchase products
  • Marketplace systems and other platform-based payment solutions
  • Loyalty systems, vouchers and customer cards and other prepaid products
  • Mobile payments and other alternative payment methods
  • Account information and payment initiation services
  • Intercompany payments, centralized cash management systems
  • Central regulators