FIN-FSA is assessing the need for licensing for companies providing payment services

The Financial Supervisory Authority has recently announced that a number of companies offering platform services related to employment and invoicing may need to register as payment service providers. This is based on observations indicating that unregistered companies might be offering payment services subject to authorisation, such as payment intermediation and safeguarding of client funds, under the Payment Institutions Act (297/2010).

The provision of payment services requires either registration or authorisation from the FIN-FSA. The application process is extensive and requires detailed descriptions of the company's activities and organisation, as well as documentation and risk assessments relating to:

• KYC: Companies must establish and implement adequate processes for identification, due diligence and continuous monitoring of customers.
• Preventing money laundering and terrorist financing: A company’s risk assessments and risk management must comply with anti-money laundering regulations. 
• Safeguarding client funds: Processes must be implemented to ensure that client funds are securely stored and properly separated from the company's own funds.
• Operational risk management: Careful assessment and management of operational risks is required to ensure continuity and security of services.
• Sanctions: Companies must comply with international and national sanctions.
• Reporting obligations: Companies must establish internal procedures for regulatory reporting.
• Outsourcing: When companies outsource parts of their activities to third parties, for example to meet anti-money laundering obligations, this must be done in accordance with applicable legislation.

The application process includes careful consideration of legal and operational requirements under both national and international law and regulatory guidelines. In addition, the application must take into account the company's size, the nature of its business, and the scope of its operations. The processing time for an application is usually around 4-6 months, as it may vary depending on the quality and scope of the application and any additional requests from the FIN-FSA. If your company needs assistance in identifying the need for registration or authorisation, the application process, preparing the necessary documentation or ensuring compliance, please feel free to contact us.