Regulatory Changes for the National Payment System


Legal Update No 696

Bryan Cave Leighton Paisner (Russia) LLP (formerly Goltsblat BLP in Russia) advises that Federal Laws:

  • No. 173-FZ of 3 July 2019 “Amending the Federal Law “On the National Payment System” and Certain Legislative Acts of the Russian Federation” (Law No. 173-FZ) and

  • No. 264-FZ of 2 August 2019 “Amending the Federal Laws “On the National Payment System” and “On the Central Bank of the Russian Federation (Bank of Russia)” (Law No.264-FZ)

have been signed by the Russian President.

Law No. 173-FZ highlights:

  1. The rules are now in place for interaction between money transfer operators and payment app suppliers (such as ApplePay, SamsungPay and MirPay).

  2. From 1 January 2021, companies and individual entrepreneurs may transfer money electronically not only for B2C but also B2B payments.

  3. Payment aggregators are now also subject to regulation.

  4. Funds held on an insolvent payment aggregator’s special bank account have been excluded from its bankruptcy estate.

  5. The rules for engaging bank payment agents have changed.

  6. The Bank of Russia may cap fees charged by credit institutions to clients for money transfers and other services within its payment system.

Law No. 173-FZ, apart from certain provisions, came into force on 3 July 2019.

The requirements on engaging bank payment agents and payment aggregators will take effect on 31 December 2019. From 1 July 2020, credit institutions will be required to provide the Bank of Russia with information on payment app suppliers and bank payment agents acting as payment aggregators.

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Law No. 264-FZ regulates foreign payment system (FPS) operators’ activities in Russia by:

  1. defining the terms “foreign payment service provider” and “information exchange service operator”;

  2. setting the requirements on:

    • electronic payment facilities acceptance on Russian territory and client service;

    • the functioning of FPSs in Russia;

  3. entitling the Bank of Russia to interact with national payment system entities by granting them access to personal accounts maintained under the Bank’s standards and rules;

  4. specifying the fine charged by the Bank of Russia on information exchange service operators should they unilaterally suspend or terminate their information exchange services to credit institutions and their clients.

Law No. 264-FZ came into force on 2 August 2019, except for provisions for which other effective dates are prescribed.

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