Intermediary Merchant

Payment Service Provider Agent (PSP Agent) or Electronic Money Distributor (EMD)

Certain projects require a specific regulatory framework that allows intermediaries to act in the name and on behalf of CentralPay, an institution authorized and supervised by the ACPR. Two main legal statuses can be utilized in France:

• Payment Service Provider (PSP) Agent, for projects requiring active management of payment flows (collections, transfers, Payouts), strictly within the scope of a mandate and under the responsibility of CentralPay
• The Electronic Money Distributor (EMD), for projects based on stored-value/Electronic money mechanisms (C2C platforms, prepaid cards, closed networks, etc.), under a distribution agreement

These models can provide the intermediary with a high degree of operational autonomy, but they come with strict regulatory constraints and ongoing supervision, under the responsibility of CentralPay.

1. Payment Service Provider Agent (PSP Agent)

1.1. Typical Use Cases

• B2B platforms with complex financial flows
• Financial or cash management tools for third parties
• SaaS solutions that integrate payment collection and the distribution of funds to beneficiaries

1.2. Role of the Agent

The PSP Agent acts as CentralPay’s regulatory representative for the provision of payment services, in the name and on behalf of CentralPay, within the limits of the configured mandate and technical rights.

Features (depending on the scope of the contract and user permissions):

• Business development and promotion of CentralPay services to end users (the “Participants”)
• Assisting participants in opening CentralPay accounts (via the CentralPay process and/or the agent-guided process, depending on the selected model)
• Opening, on behalf of the Agent, special accounts dedicated to segregating cash flows (e.g., a Collection Account and a Commission Account), without the Agent becoming the owner of the Participants’ funds
• Submission to CentralPay of the requests/instructions necessary for the proper performance of services (e.g., allocation of funds, payout requests, refund requests), with CentralPay acting as the sole executor
• First-level (L1) support management and operational processing provided as an outsourced service, with escalation to CentralPay as needed

1.3. The 3 options in the Agent model (KYC/KYB delegation)

CentralPay’s Agent model provides for three levels of delegation regarding registration and KYC/KYB checks. Only one option may be applied at a time, and the selected level is formalized in a contract:

• Option A – Basic Agent (no delegation of control): The Agent acts as a registered PSP Agent but without KYC/KYB delegation. The Agent is limited to establishing business connections and directs Participants to the processes and tools provided by CentralPay. The Agent is not authorized to collect supporting documents or perform any checks.
• Option B – Collection Agent (delegation of administrative completeness verification): The Agent is authorized to compile the Participant’s administrative file on behalf of CentralPay. The Agent collects the documents and performs strictly formal checks for completeness (legibility, apparent validity, and consistency of the documents). The Agent does not conduct risk analysis, sanctions/PPE screening, or in-depth analysis; the decision for onboarding remains with CentralPay.
• Option C – Delegated Compliance Officer (Level 1 delegation): This option is reserved for Agents with a dedicated compliance organization that has been expressly approved by CentralPay. The Agent may collect KYC/KYB documents, verify their completeness and consistency, and perform Level 1 due diligence that is exclusively formal and administrative in nature. The Agent may also participate in the handling of Level 1 alerts (collection, administrative assessment, and transmission) in accordance with strict procedures. CentralPay retains the final decision-making authority and may revoke this option at any time in the event of non-compliance.

1.4. CentralPay remains responsible

• CentralPay remains fully responsible for the services provided to Participants
• The Agent acts strictly within the scope of the mandate entrusted to him or her and in accordance with the technical authorizations that have been established
• Every activity carried out through the platform is auditable, traceable, and documented

1.5. Regulatory Requirements

• Signing an Agent Agreement and Related Documents
• Official registration as an Agent in the ACPR registry (via CentralPay)
• Assessment of the intermediary’s organizational capacity and enhanced requirements (compliance, security, confidentiality, business continuity, internal control)
• Periodic reporting to CentralPay (business volume, incidents, service quality) and the option for document-based or on-site audits
• Mandatory training for operational teams, based on the scope of delegation

2. Electronic Money Distributor (EMD)

2.1. Typical Use Cases

• Peer-to-Peer (C2C) Sales Platforms
• Prepaid card or gift card networks
• Stored-Value Loyalty Programs

2.2. Role of the EMD

The EMD acts on behalf of CentralPay in the provision and operational management of Electronic money, within the limits set forth in the distribution agreement and the rules established by CentralPay.

Features:

• Connecting CentralPay with end users (the “Sub-merchants” / Electronic money users)
• Transmission of payment instructions (amount, Beneficiary, fee) to CentralPay, with CentralPay acting as the sole issuer and executor
• Viewing and tracking transactions through a dedicated monitoring system (e.g., consolidated view/centralized account based on the model), without the right to dispose of the funds
• Transmission of requests/instructions enabling the transfer of Electronic money between users within a defined framework (closed network, contractual rules), under CentralPay’s control
• Submission of requests for refund of electronic money at the user’s request, in accordance with applicable rules
• Maintenance of a Commission Account to collect the fees specified in its Terms of Service

2.3. Functional Limitations

• The EMD never holds the funds: it acts as an intermediary and cannot retain, store, or use the funds collected
• It is not permitted to create or issue Electronic money on its own
• It may not offer payment services that are not explicitly authorized under the contractual framework established by CentralPay
• He may not subcontract his business activities unless expressly authorized by CentralPay

2.4. Regulatory Requirements

• Signing of a Distribution Agreement with CentralPay
• Declaration / compliance procedures carried out on the initiative and under the responsibility of CentralPay, in accordance with applicable regulations
• Organizational Compliance: Internal Security Measures, Confidentiality, Incident Management, Business Continuity
• Continuous monitoring by CentralPay, including:
  • Monitoring API Usage / Permissions
  • Regular reports on business activity
  • Mandatory Training for EMD Teams
  • Validation of the Terms of Service provided to users