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Proceedings for entry into the register of small payment institutions

We represented our client, an innovative utility provider in the proceeding for entry into the register of small payment institutions to enable the client to accept payments for e-commerce services provided. The client already provides its services through a mobile app and intended to enable users of the app direct payment for utility services.

As part of the project, we prepared the necessary documentation in accordance with the requirements of the Payment Services Act in force on the date of the application.

During the processing of the application by the Financial Supervision Commission, the rules for small payment institutions to obtain an entry in the register changed, due to the amendments to Act on Payment Services, which came into force. Those amendments required preparing and attaching to the application:

• a business plan and financial plan;
• a risk management procedurę;
• a procedure for preventing money laundering and terrorist financing (AML)
• as well as a number of other documents and statements, such as principles of protection of users’ funds or a description of organizational arrangements for calculating the total monthly amount of payment transactions.

The client was informed that, in order to obtain registration, it is necessary to develop this additional documentation, and consequently it was developed by the firm’s team in consultation with the client and submitted to the Financial Supervision Commission (acting without such permission is
punishable by a fine of over 1 million EUR).