With our online account-based business model, we provide payment services to approximately 5,000 members. Our members load money into their online accounts by credit or debit card and send the price of the goods they buy from these accounts to the online account of the member selling the goods. Our members can convert the amounts in their online accounts into funds whenever they wish. Since transactions take place only among our members, can it be said that the prepaid instrument we offer is used “only within a limited network of service providers”?
For a prepaid instrument to be claimed as being used “only within a limited network of service providers”, the boundaries of that network must be defined. In this context, since your number of members is constantly increasing and its scope is not defined, the prepaid instrument you offer is not considered an instrument used “only within a limited network of service providers”. However, the position of each business model under the Law must be assessed separately, taking into account the principles of how that business model operates.
