Online foreign exchange

Does the business of foreign currency exchange-Forex require an authorisation as payment institution under PSD2, provided that: (a) the currency exchange takes place via online exchange platform; and (b) the client deposits certain base in cash or sends it by bank transfer to a bank account of the Forex company; and (c) the client receives the quote (exchanged) currency in an online client account in the platform from where the exchanged amount may be sent to a client's bank account or may be withdrawn in cash at the Forex company's offices?

A Forex company is intending to provide an online foreign currency exchange platform with the following features: (a) clients will be able to register on a website and open an online client account (analytical account) in the online platform. This account will NOT be a payment account because the client will NOT be able to execute payment transactions directly with this client account (the payment transactions will be executed only via payment services provider - a credit institution as noted below); (b) clients will be able to exchange foreign currency online by taking the following steps: Step 1: The client deposits certain base currency in cash or by bank transfer to a bank account of the Forex company. The Forex company keeps all funds transferred to its bank accounts with a licensed credit institution and does not itself maintain or hold payment accounts; Step 2: The Forex company reflects the deposit/transfer done by the client under Step 1 in the client's online account (analytical account); Step 3: The client submits an order via the online platform for currency exchange; Step 4: The Forex company provides a quote for the exchange and, if the client agrees, the foreign exchange occurs and it is reflected in the online client account (analytical account); Step 5: The client decides how and when to receive the exchanged amount - the receipt may be done in cash in one of the Forex company's offices or the client may indicate a bank account to which the exchanged funds are to be sent by the Forex company.