This reminds me of how practically all BaFin license requirements have this personnel requirement i.e. management must have three years of academic experience a

This reminds me of how practically all BaFin license requirements have this personnel requirement i.e. management must have three years of academic experience and three years practical experience. In other words, the only people who get to start a new payment service provider (PSP) must have already worked in management at an existing PSP, essentially pulling up the ladder.