Do you collect payments from customers and pass them on to suppliers? Two positions issued by the Israel Securities Authority (ISA) staff, concerning Pango and the Hever club, illustrate why the underlying business model warrants closer examination. The question is not merely how long you hold the funds, but the capacity in which you act: an independent commercial party or a link in the payment chain. This distinction may directly affect licensing requirements.
1. Pango: Commercial Substance Is Key
Pango sought the ISA’s position that its “blue-and-white” curbside parking service does not require a license under the Regulation of Payment Services and Payment Initiation Law, 2023. Under the arrangement reviewed, users pay Pango for parking, and Pango pays the local authorities under its agreements with them.