Penalties for unlicensed payment services

The Law provides for judicial fines and prison sentences for people who operate like a payment institution or electronic money institution without obtaining the licenses required under the Law, and the Law also stipulates that:

  • if this crime is committed within a business, the business may be closed for two to six months,
  • in case of repetition, it may be decided that the business be closed permanently.

In addition, the Law provides for judicial fines and prison sentences for people who, without obtaining the licenses required under the Law, use words and expressions in their trade names, any documents, announcements and advertisements, or public statements that create the impression that they operate like a payment institution or electronic money institution, and the Law also stipulates that:

  • if this crime is committed within a business, the business may be closed for two to six months,
  • in case of repetition, it may be decided that the business be closed permanently.

Takeaways for entrepreneurs

Before launching a product or service, it should be legally clarified whether the activity counts as a payment service. When in doubt, it is safer to get an opinion from the competent authority or to work with a licensed institution.

In addition, expressions that make you look licensed (for example, saying “payment institution” in the trade name or in advertising) can also be subject to sanctions. For this reason, marketing texts should also go through a legal review.

For details of the sanctions, the relevant articles of the Law should be consulted.