Asset Managers & FinTech Companies Registration Guidebook
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Prepaid payment instrument for third-party business (limited to those which are recorded on an 18 Prepared based on page 22 of the Explanatory Material of the Financial Services Agency (https://www.fsa.go.jp/common/diet/208/03/setsumei.pdf) of March 2022. Prepaid payment services are regulated by PSA, and are categorized either as a prepaid payment instrument for own business or a prepaid payment instrument for third-party business (Articles 3, 5 and 7 of PSA). Prepaid payment services include IC cards, server-based prepaid cards, server-based electronic money, and virtual currencies used in online games. Note that there are some payment services to which PSA does not apply (Article 4 of PSA), so it is necessary to confirm on a case-by-case basis whether the law applies to a given prepaid payment service or not. The issuer of a prepaid payment instrument for its own business is required to submit a notification if the unused balance is over 10 million yen as of the record date (Article 5 of PSA). The notification is due within two months from the day after the record date. The issuer of a prepaid payment instrument for third-party business is required to register in advance (Article 7 of PSA). Only a registered issuer is allowed to issue a prepaid payment instrument for third-party business. Prepaid payment instrument for own business: Prepaid payment service that can only be used for products and services provided by the issuer of the prepaid payment instrument. Prepaid payment instrument for third-party business: Prepaid payment service that can also be used with merchants other than the issuer. Amendments to PSA are scheduled to come into force in 2023 and as amended PSA will cover prepaid payment instruments for third-party business, which have a higher risk of being used for money laundering so new regulations will come into effect regarding "large-amount electronically transferable prepaid payment instruments" where the balance can be topped-up and transferred in large amounts (Article 3(8) of the amended PSA). Issuers of large-amount electronically transferable prepaid payment instruments will be required to submit a business implementation plan describing statutorily specified matters (Article 11-2(1) of the amended PSA), in addition to the requirement to carry out verification at the time of transactions under the Act on Prevention of Transfer of Criminal Proceeds (Article 2(2)(xxx)-2 of the amended Act on Prevention of Transfer of Criminal Proceeds). Large-amount electronically transferable prepaid payment instrument means a prepaid payment instrument which satisfies all of the requirements (1) through (2) below (Article 3(8) of the amended PSA) 18. (1) electronic device or any other object by electronic means); (2) Prepaid payment instrument that can be transferred using an electronic data processing system; (3) Prepaid payment instrument that is managed by accounts (meaning accounts in which the issuer specifies or records the unused balance of the prepaid payment instrument); (4) When the accounts in (3) are limited to those that can be topped-up repeatedly; and (5) For each of the types listed in (a) through (c) below, a prepaid payment instrument that satisfies each of the following requirements for the relevant type: a) Balance transfer type (one that enables transfer of prepaid payment instrument balance between accounts through a mechanism managed by the issuer) b. Prepaid Payment Instruments (for Own Business/for Third-Party Business) 43

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