ME Distributor Declaration (ACPR)

Electronic money issuers such as CentralPay may authorize Electronic Money Distributors (EMDs) to collect funds and facilitate transactions for the purchase and refund of electronic money within a defined network of Sub-merchants.

The registration process for an Electronic Money Distributor consists of two steps:

• Preparation of the tax return: handled by CentralPay with the assistance of its future EMD
• Processing of the application by the ACPR: handled by CentralPay. It does not require any specific approval from the ACPR.

1. Responsibilities of the EMD Intermediary

CentralPay handles all complex processes or those requiring specialized expertise. However, you remain responsible for ensuring a high standard of compliance with AML/CFT (Anti-Money Laundering and Counter-Terrorist Financing) rules. As such, you must provide CentralPay with assurance regarding the conditions under which transactions processed through you are carried out, including:

• The Economic Reality of the Transaction
• The Fight Against Fraud

Regulated institutions that use distributors remain responsible for the transactions carried out by those distributors. A clear legal framework has therefore been established.

To qualify as an Electronic money Distributor, the following requirements must be met:

• The execution of an Electronic money Distribution Framework Agreement that defines the relationship between the parties
• Terms of Use for Electronic Money

In the event that an EMD internalizes certain functions assigned to CentralPay as part of its regulatory obligations, a contract for Outsourced Essential Services must be signed. This is the case, for example, if the agent handles KYC management in-house or develops management interfaces that would prevent CentralPay from providing the service without the assistance of the PSEE.

2. Become an EMD Intermediary

Becoming a CentralPay distributor involves following a series of steps that take several weeks to complete.

Here is a guide to help you better understand the issues related to the acceptance and subsequent processing of distributors’ filing documents.

2.1. Summary of the Steps

1. Understanding the Model
   • Explanation of the services provided by the intermediary
   • Defining Its Business Model
   • Approval by CentralPay’s Risk & Compliance Department
2. Sales Offer
   • Overview
3. Validation
   • Approval of the intermediary by CentralPay’s Risk & Compliance Department
   • Approval of the commercial proposal and pricing terms by the intermediary
4. Test & Intégration
   • Setting Up the Sandbox
   • Project Kickoff Meeting with the Technical Team
   • Technical Integration Phase
5. Review of the ACPR File
   • Gathering the information needed to compile the file
   • Preparing the Application
   • Overview of the Case
6. Go-Live
   • Acceptance Testing
   • Go-Live

2.2. Documents to Submit to CentralPay

Coming Soon