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Central contact points under PSD2 and 4AMLD in Germany

The second payment services directive (Directive (EU) 2015/2366, “PSD2”) as well as well as the fourth anti-money laundering directive (Directive (EU) 2015/849, “4AMLD”) gives EU member states’ (“Host Member State”) authorities the competence to require those payment service providers or e-money issuers having its head office in another EU member state and acting in the territory of that Host Member State in forms other than a branch to appoint a central contact point in the territory of that Host Member State. The appointment of such central contact point and the obligations connected with such appointment might have a significant impact on the provision of payment services or e-money business under the provisions of the European Passport.

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