Articles

BaFin circular on virtual currencies
A new circular by BaFin addresses BaFin’s concerns to financial institutions regarding AML-Compliance in connection with virtual currencies. The circular also indicates BaFin’s view regarding a license requirement for cryptoexchange platforms upon the „Bitcoin-ruling“.

New Rules for Outsourcing by Banks, Payment Institutions and other institutions
The European Banking Authority (EBA) published a draft of the EBA Guidelines on Outsourcing and launched a public consultation. The consultation period closed on 24 September 2018. The new Guidelines are planned to enter into force on 30 June 2019 and will add further provisions and regulations with regard to outsourcing arrangements.

European Commission - enhancing European AML supervision by strengthening EBA?
The European Commission envisages to fight money laundering terrorist financing more effectively by implementing an overall European strategy. EBA shall be strenghtened and able to supervise the EU member states and financial institutions in the EU.

Opinion of EBA on the interpretation of RTS on strong customer authentication published
On 13 June 2018 EBA has published an opinion on the interpretation of regulatory technical standards (RTS) on strong customer authentication (SCA) and common and secure communication. The opinion clarifies some open questions on the interpretation of the RTS.

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...

PSD2 RTS for strong customer authentication and common and secure open standards of communication published
What are the practical implications? What does it mean that the RTS are now in force? And isn’t PSD2 already in force since 13 January 2018?