Transfer of Wirecard Prepaid Card Programmes

Ominous news that the UK e-money subsidiary of scandal-ridden Wirecard AG is “intending to wind-down its FCA-regulated business” and that “the business will continue to trade while alternative arrangements are being made with its card providers.” 

Having advised on the set up and transition of various prepaid card programmes and customers, I’m aware this is highly technical from an e-money and payments regulation standpoint, and will involve intensive ‘customer due diligence’ under the anti-money laundering regime, as well as a careful approach to the processing of personal data. 

The FCA claims to be “working closely with Wirecard throughout this process to ensure that its customers are treated fairly,” and doubtless EU national regulators will also be watchful, so programme managers any e-money issuer(s) taking them and their programmes on will need to tread carefully.

Needless to say, we are here to help the transferring programme managers or their new e-money service providers in relation to any Irish or EEA programmes. 

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Contributing Advisors