Swift Institute –  The Evolution of Third Party Payment Providers and Cryptocurrencies Under the EU’s Upcoming PSD2 and AMLD4, Peggy Valcke, Niels Vandezande and Nathan van de Velde, September 23, 2015.

“…THIRD PARTY PAYMENT SERVICES – Despite the rising popularity of third party payment providers and the sensitivity of their activities through the data they process, they are not covered by the scope of the current Payment Services Directive. As a result, these entities are presently not regulated at the level of the EU. The European Commission has therefore proposed a new set of rules – in the form of a Second Payment Services Directive (PSD2) – to cover what is referred to as “third party payment providers”, “payment initiation services” and “account information services”. This initiative would essentially bring such third party payment providers under the same standards of regulation and supervision as existing payment service providers. Moreover, the Commission’s proposal also includes a number of requirements relating to stronger security measures, emphasizing the need for strong authentication mechanisms. LEGISLATIVE PROPOSAL – However, as the legislative procedure regarding this proposal is still ongoing, the precise scope of the eventual directive – if adopted – remains unclear. It is therefore as of yet uncertain whether this proposal will succeed in bringing the wide range of different third party payment providers under the fold of regulatory scrutiny. Moreover, it is unclear what the precise relation will be for third party payment providers under the PSD2 and the recently adopted Fourth Anti-Money Laundering Directive (AMLD4)…”