On June 6, 2025, a law to partially amend the Payment Services Act was enacted.
Under this amendment, cross-border payment collection agents—those who conduct international remittances for settling transactions in which they are not directly involved—will now be subject to the regulations applicable to Funds Transfer Service Providers.
Examples:
- Transaction intermediation platforms:
Receiving payments for goods or services traded on one’s own platform (e.g., accommodation booking platforms) on behalf of sellers or service providers. - Purchase agency services for overseas e-commerce:
Receiving payments for various goods and services—such as clothing, miscellaneous goods, or online games—on behalf of the seller or service provider. - Payment processing services:
Receiving merchant settlement funds relating to various payment methods.
However, the amendment also provides an exclusion: even if the activity meets the above requirements, cross-border payment collection may be designated as not constituting a funds transfer transaction when, considering the manner of the activity and other relevant circumstances, the risk to user protection is deemed low.
Examples expected to be excluded under forthcoming subordinate regulations include:
Activities or entities in fields regulated under other laws where cross-border payment collection is already contemplated (e.g., clearing operations between credit card issuers and acquirers).
Cross-border payment collection conducted by entities that have a capital relationship or other form of economic unity with the recipient.