TSMP Law Corporation joint managing partner Stefanie Yuen Thio commented in a story published by the Straits Times on 1 July 2020 on the possible disruption faced by merchants and customers using Wirecard’s products.

She noted: “A merchant may use a Wirecard terminal and its ability to offer credit card payments to its customers will be impacted if it does not have a back-up terminal from another service provider. As a consumer with a Visa or Mastercard, I may not be aware that Wirecard might be processing backend payments on my card.”

But she understands that Wirecard’s penetration rate here is not very high. Wirecard is also in the prepaid cards business. “But we do not know which are the issuers that use their services in the backend and what the extent of the impact is,” Ms Yuen Thio said.

Ms Yuen Thio noted: “The question will be whether any of the Singapore operations were illegal, for example, if any funds remitted or received in pursuance of fraud or money-laundering passed through Singapore. If so, there may be criminal charges.

“If Wirecard breaches its contractual obligations to merchants, it will be liable in damages. But given its low penetration here, I don’t think that is the most significant issue it faces.”