How to launch a marketplace in accordance with Federal Law 161?

Question

Startups

We are developing a marketplace. We plan to provide users with the following. services:

• Agency . Realization of goods of sellers on behalf of the company;
  
• SaaS . Add. opportunities for sellers by subscription (for a month, two, etc.).
  

To buy goods, the buyer just needs to enter the card number or pay for the goods through one of the payment systems. The money will go to us, the goods - to the buyer. It is more difficult with sellers - it is planned to introduce wallets for them.
You can replenish your wallet in two ways:
1. With a bank card or through one of the payment systems;
2. Post a product on the site and sell it.
All funds on the seller's wallet can be used to buy additional. opportunities, but only the money earned can be withdrawn by the seller to his account in one of the payment systems (the transfer is carried out at the request of the seller within the agreed time).
Problem: all payment at the time of purchase of the goods goes to the company's account in the payment system. Part of these funds are the company's commission - we keep them for ourselves, and part is our obligation to the seller. For this amount, we undertake to either provide him with additional opportunities, or make a transfer using the details of his account in the payment system.
Are we not violating the Federal Law “On the National Payment System” with such a settlement scheme, partially taking over the activities of the payment clearing center and/or electronic money operator?

Answer 1

We don't violate.
For details, contact a lawyer for advice. It's not as expensive as you think.