On May 27, 2024, the German Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht – “BaFin“) published the final version of the Circular on the Minimum Requirements for Risk Management of Payment Institutions (“ZAG-MaRisk“). As a result, payment institutions are subject to payment specific minimum requirements for the first time and may not rely on the Minimum Requirements for Risk Management for Credit Institutions (“MaRisk (BA)“) anymore. The ZAG-MaRisk specifies the requirements for the proper business organization of institutions on the basis of Section 27 (1) of the German Payment Services Supervision Act (Zahlungsdiensteaufsichtsgesetz – “ZAG“). In addition, it [...]

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