MACURA | Unikalna wiedza ekspercka

Kancelaria MACURA.
ul. Odyńca 7/13
02-606 Warszawa

T: (+48) 696-011-713
M: monika.macura@kancelariamacura.pl

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Representation in proceedings to obtain a license to provide payment services as a national payment institution (NPI)

As part of our ongoing cooperation with a client, a small payment institution, providing payment services including issuing of credit cards and providing payment credit to consumers, we represent the client in the proceedings for obtaining a license to provide payment services as a national payment institution.

The decision to apply for a license was dictated by the fact that the value of payment services provided by the client was approaching the level at which it was necessary to decide on further development of the business by obtaining for this purpose a license to provide payment services as a national payment institution.

The other solution was to limit the scope of business, so that the volume of transactions does not exceed the limit allowed for a small payment institution.

When the client approached the firm we provided a legal opinion stating that obtaining license of national payment institution will enable the company to increase the size of its payment services business and enable to provide payment services also across borders.

Subsequently, the firm prepared the necessary documentation for the application for a license to provide services as a national payment institution and carried out the necessary modifications to internal procedures as well as the creation of new ones dedicated to the national payment institution.

Due to the complexity of the work on the documentation, the firm formed project teams with the client, in which the work on the documentation was carried out. One of the teams, under the direction of attorney-at-law Michał Barwicki, prepared amendments to the financial plan and business plan, demonstrating interdisciplinary knowledge and practice in creating such documents.

In the course of providing the service, the firm also advised the client on the modification of the template of the agreement for the issuance of a credit card and the granting of a payment credit for consumers. The modifications were made in connection with the issuance of an interpretation by the Financial Supervision Commission regarding the rules for charging customers for issuing a credit card and granting payment credit.

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Documentation of the anti-money laundering and anti-terrorist financing (AML) system

For our client, during regular legal advice, we developed documentation for an anti-money laundering and counter-terrorist financing system (hereinafter “AML/TF system”, maximum penalty for violating those laws may result in financial penalty up to 5 million EUR).

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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.

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