VMP advised foreign provider of payment services on its operations in Belarus

We have been requested by a foreign payment services provider to advise on applicability of regulatory requirements set by the new Law on Payment Systems and Payment Services dated 19 April 2022, No.164-Z (the Law).

Our main conclusion is that the foreign payment services provider carries out its operations in Belarus on a cross-border basis. Pursuant to Article 2 of the Law, payment services are deemed to be carried out cross-border if their providers and users reside, or are registered, or carry out payment operations, or receive payment services, in different countries.  

If a foreign payment services provider carries out operations on a cross-border basis, it is not obliged to be recorded in the Register of payment services providers and services provided (by and after 27 August 2023) and to ensure a full-scope compliance with other regulatory requirements of the Law.