EBA Issues Opinion on Nature of Passport Notifications for Agents and Distributors under PSD2, EMD2 and 4th AMLD

On April 24, 2019, the European Banking Authority (EBA) published an opinion on the nature of passport notifications of payment institutions and electronic money institutions using agents and distributors in other member states under the revised Payment Services Directive (PSD2), the 2nd Electronic Money Directive (EMD2) and the 4th Anti-Money Laundering Directive (4th AMLD).

The EBA has issued its opinion with a view to clarifying the criteria for competent authorities to take into account when assessing whether or not an activity carried out by a payment institution (PI) or e-money institution (EMI) using agents or distributors in a host member state amounts to an establishment of that PI/EMI in the host member state.

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