In 2017, Wirecard AG was classified by BaFin as a technology company and not as a financial holding group after an "extensive, joint examination together with the Deutsche Bundesbank" and "in accordance with a subsequent statement by the ECB [European Central Bank] (...)" (cf. Deutscher Bundestag Finanzausschusssdrucksache 19/7 - 548, p. 6).
Due to this classification, the BaFin only dealt with Wirecard AG within the scope of securities supervision and delegated audits of the balance sheets in accordance with the two-stage procedure to the German Financial Reporting Enforcement Panel (FREP) under private law. From this classification it followed that, in the opinion of BaFin, the Free State of Bavaria or the district government of Lower Bavaria was entrusted with the task of supervising the global Group with regard to money laundering.
This responsibility was later disputed by the district government and the state government of Bavaria (cf. Committee Printed Paper 19/7 – 548, “Overview of Significant Events”, as well as FAZ of July 1, 2020, “Gaps in Money Laundering Supervision at Wirecard”). In its „kleine Anfrage” of July 29, 2020 (BT-Drs. 19/21488 of August 5, 2020), the party DIE LINKE ties in with this problem and the question of the classification of Wirecard AG as a technology company and its connection to the Payment Services Supervision Act (Zahlungsdiensteaufsichtsgesetz, ZAG). As far as can be seen, the Federal Government has not yet provided an answer.