I would like to disable payments through revolut.me.
Finland has very strict money collection laws, when nothing is given in return as it always needs a permit that cannot be granted to private individuals so I think the feature is illegal and the Revolut tags may be easy to guess.
I am not a lawyer, and I also don’t know anything in particular about the law in Finland. But I am going to share my thoughts nevertheless. I think it’s an interesting question.
First, the T&Cs of Revolut make it clear that any business transaction is a violation of the T&Cs.
I don’t see the payment link feature as a fundraising feature. Sure, fundraising is a plausible use case, but any account number can be used for fundraising. If I am reading the Finnish website correctly, the fundraising itself is the problem, not the method. If I would publish my account no. and ask for donations, I would violate the law.
I think of the payment link as a P2P payment method. Similar to Paypal. You’re going on a trip with friends, you’re splitting the bill for the house or a dinner. And then you’ve got a couple of options with Revolut to settle this. Regular bank transfer, or a direct P2P transfer if the other person also uses Revolut, or the link. The link basically facilitates a personal money transfer, not necessarily a fundraising effort or donation.
Paypal has a very similar feature called Paypal Me.
Just like money laundering: doing money transfers is not the illegal bit, its the source of the money and the purpose of the transfer. From a legal perspective, I would argue that Revolut’s payment link feature is not a fundraising platform, it’s a P2P payment method. Using it for personal transfers would be legal, and using it for fundraising is not.
Do you know if Paypal is under scrutiny in Finland for its various P2P methods that could be used similarly to Revolut’s feature?
Thank you for answering, I tried to dig out for links (all in Finnish due to the subject, sorry, but Google Translate or DeepL may amuse you exist), and I think I may be a bit more confused than before I did this
This is a paid article that I don’t have access to, but the title is that “When Riku Rantala wanted to donate Finnish state a plastic bag full of money, the state thought to inform citizens on donations. This was not OK to the Police Board.” The end result of this case was that the Treasury of Finland is not allowed to report their IBAN on their website, because they don’t have a money collection permit and the link in my original post may have implied that the state cannot get one.
You can donate money to the State, but the account number cannot be told publicly
is an article on the same subject, with less details and no paywall.
Here a lawyer has encountered phenomenon of Tinder profiles including the IBAN number and analyzes it tongue in cheek. The result is that this is illegal, as Tinder restricts it geographically to Finland and you aren’t guaranteed to get anything in return. (So I guess if I was using Tinder and had my Revolut link there visibly, that would be illegal).
These two are about Wikipedia being investigated for breaking the money gathering law, the second written by an internet police.
Another lawyer is pondering about gamestreaming and the law in 2021. If something is available online without having to pay for it, donations are illegal. Tip jar features and similar are also illegal, but apparently subscribing to a channel and being a Twitch affiliate work differently.
The desire to help is hard - many illegal money collections to a family who lost their baby
Apparently there are many ways people have been avoiding the law, but to quote a quote
Se menee niin, että sinä voit kertoa ystävillesi tilinumeron, minä omilleni, mutta jos vetoan muihin ja tuntemattomiin, niin siitä voi tulla ongelmia…
It goes so that you can tell your friends your account number, I can tell mine to mine, but if I petition others and unknowns, that may become a problem…
So at least in 2015 (I think the law was changed since then, but I didn’t note the year), I could have told my friends my Revolut link, but they couldn’t tell it to more or that would be illegal, but what if it can be guessed is another question?
And last, but not least, Electronic Frontier Foundation has been having a saga with this law since 2005 which is still ongoing in 2022, apparently they have once had the PayPal button on their website until 2011, but the case began from their website mentioning donation option and having their IBAN on their website. They seem to have contacted other parties such as UN and it has been noted in
but this however leaves the topic of private individual using Revolut.
The username changing has limited times on when it can be used, so I am a bit unsure on that.
I discussed this in a Finnish IRC channel, which I should probably have begun with instead of worrying and coming here. We have Pivo and Mobile Pay Finland which allow transferring money by phone number and it probably depends on whether you share your phone number around simultaneously telling people to send money or publicly advertise that option.
I didn’t initially think of them and upon asking what if a cyberbully or similar started sharing the phone number around and telling people to donate, then it was them doing the money collection and not the owners responsibility although such money should be put aside should it be asked for.
However the law is confusing and I think the safest option would be allowing disabling the link as it seems too easy without even requiring an app.
Is the submit feedback button different from talking with support? (Thank you again, you have been far more helpful than they were). I thought this Ideas category was also a place for feature requests?
With Paypal, it’s very easy to guess and check if you know someone’s mail address or phone number.
You might know my mobile number because I called you. I did disclose my number to you willingly, but not for money transfer purposes. But as soon as you’re trying to send money via PayPal (or any other P2P transfer service that uses mobile numbers), you would get a positive confirmation that I have a PayPal account.
It makes sense that I am then not liable under the Finish law. It also makes sense that I can’t ignore random people sending me money. That’s a money laundering red flag.
I’d use the „Send feedback“ option for feature requests.
Revolut Ltd (No. 08804411) is authorised by the Financial Conduct Authority under the Electronic Money Regulations 2011 (Firm Reference 900562)..
Registered address: 7 Westferry Circus, Canary Wharf, London, England, E14 4HD.
Insurance related-products are provided by Revolut Travel Ltd which is authorised by the Financial Conduct Authority to undertake insurance distribution activities (FCA No: 780586) and by Revolut Ltd, an Appointed Representative of Revolut Travel Ltd in relation to insurance distribution activities. Revolut Ltd is an Appointed Representative of Lending Works Ltd for the activity of “operating an electronic system for lending”. Trading and investment services are provided by Revolut Trading Ltd (No. 832790). Revolut Trading Ltd is an appointed representative of Sapia Partners LLP (No 550103) which is authorised and regulated by the Financial Conduct Authority. Revolut Trading Ltd is a wholly owned subsidiary of Revolut Ltd.