JAPAN Trends and Developments Contributed by: Takaharu Totsuka, Keisuke Hatano and Tomoki Kashimura, Anderson Mori & Tomotsune
Collection Services” as there are cases where multiple payment service providers are involved in domestic “Payment Collection Services”; • why the complexity of the flow of funds increases the likelihood of it being classified as a “Fund Transfer Service”; and • why the same argument (ie, complexity of the flow of funds increases the likelihood of it being classified as a “Fund Transfer Service”) is not applicable for domestic “Payment Col - lection Services.” In September 2024, a new Financial System Council Working Group started discussing the appropriate regulations for cross-border “Pay - ment Collection Services”. According to the minutes of the meeting held on 25 September 2024 by the Financial System Council, there were comments from members stating that cross-border “Payment Collection Services” fall under “Fund Transfer Services” and cross- border “Payment Collection Services” should be regulated as “Fund Transfer Services”, given the associated risks of money laundering and terror - ist financing.
As this issue has a significant impact on cross- border payment practices, it will be necessary to pay attention to how cross-border “Payment Collection Services” will be regulated based on the results of the discussions at the Financial System Council Working Group.
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