(Prepared based on page 23 of reference document No. 1 entitled "Payment of wages into accounts with Funds Transfer Service Providers" for the meeting of Ministry of Health, Labour and Welfare, Labour Policy Council, Labour Conditions Sub-Council on October 26, 2022) of which different regulations have been provided according to the functions of and risks associated with each of them Registration as a Funds Transfer Service Provider is easier than obtaining a banking license. Exchange transactions: An exchange transaction means accepting a request from a customer to transfer funds using a mechanism to transfer funds without directly transporting cash between parties separated by distance, and to transfer funds in response to such request (Article 2(2) of PSA, Article 2(2)(ii) of the Banking Act, and Supreme Court Petty Bench Decision of March 12, 2001). For Type 1 Funds Transfer Services, there is no set maximum amount of remittance per transaction. For Type 2 Funds Transfer Services, the maximum amount of remittance per transaction is set at 1 million yen (Article 12-2(1) of the Order for Enforcement of the Payment Services Act (“the PSA Enforcement Order”)). Lastly, for Type 3 Funds Transfer Services, the maximum amount of remittance per transaction is set at 50,000 yen (Article 12-2(2) of the PSA Enforcement Order), and the maximum amount that a user is allowed to receive is also set at 50,000 yen (Article 51-3 of PSA, and Article 17-2 of the PSA Enforcement Order). A provider of Type 1 Funds Transfer Services which is allowed to handle larger value remittances will be required to formulate a business implementation plan and receive authorization in addition to registering as a Funds Transfer Service Provider and will be required to have a more substantial internal control system than existing Funds Transfer Service Providers (Article 40-2 of PSA). Conversely, a provider of Type 3 Funds Transfer Services is subject to relaxed restrictions on holding user funds, and will be permitted to manage deposits separately from its own assets (Article 45-2 of PSA). This is intended to ease the burden of cash-flow management and reduce costs. For the main regulations for each service type, please refer to the diagram below. 42
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