DECLARATION ON NON-ENGAGEMENT IN PAYMENT AGENT ACTIVITIES
We hereby declare that the activities of LLC "Blob Solutions" are not subject to licensing, as they do not fall under the types of activities listed in Part 2 of Article 43 of the Law of the Republic of Armenia "On Licensing."
LLC "Blob Solutions" operates as a mini-marketplace, organizing a public offer for the purchase of goods, services, privileges, and other benefits through the website https://tun.market/p/public-offer. To confirm each transaction, we issue digital certificates (PDF files) to buyers, which record the contractual right to receive the purchased goods or services.
According to the legislation of the Republic of Armenia and official explanations from the Board of the Central Bank:
- Licensing is required for organizations engaged in money transfer services as payment agents (i.e., when all actions are limited solely to accepting and transferring money from the payer to the beneficiary).
- No license is required for those who, in addition to accepting payments, provide buyers with specific goods, services, property rights, or documents confirming their right to receive them.
Thus, LLC "Blob Solutions" is not a payment agent because:
- We do not limit our activities to merely transferring money to third parties.
- We provide buyers with digital certificates (PDFs) that guarantee the right to receive specific goods, services, or privileges—in other words, we issue a document confirming the obligation to deliver the goods/services.
- The purpose of our activity is not to facilitate money transfers from one person to another, but to create a convenient marketplace where users can make purchases and sellers can sell goods and services.
Under these conditions, LLC "Blob Solutions" is not engaged in activities requiring a license, does not violate the law, and does not contradict any established regulatory requirements.
Thus, LLC "Blob Solutions" has the legal right to operate without the need for a license and is not considered a payment agent.