E‑Money Institution Licence Authorisation Solutions | Pre-licensing Support | EMI Licence Application Management | Post-Licensing Risk and Compliance Solutions

We offer a comprehensive set of solutions to help you obtain and maintain an e‑money institution licence, tailored to:

• Your business goals and objectives
• Your client demographics
• Your countries of operation
• The size of your business
• The available human and technology resources
• Your risk appetite
• Your governance structure
• The products that you offer
• Regulated Payment Institutions’ obligations covering risk and compliance management under financial laws and regulations, the applicable financial licensing requirements, AML/CFT laws, privacy laws, consumer protection laws, and more

We have designed our regulatory licensing solutions to help you navigate the complexities of the EMI licensing regime in a commercially oriented and goal-focused manner, providing effective support for all stages of the e‑money institution licence process, including but not limited to the following aspects:

• E‑money Institution Licence Guidance: Advising on a wide range of aspects associated with e‑money institution licence as it relates to your specific situation
• Pre-licensing assessment: Covering compliance gap analysis as well as risk and compliance assessment
• Pre-licensing support:
• Drafting the necessary policies and procedures to help you comply with the e‑money institution licence conditions and financial markets' regulations
• Developing internal controls to help you meet your obligations under the EMI licensing regime
• EMI Licence Application Support: Covering the entire licensing process
• Post-licensing Support: Covering
• Ongoing compliance advice
• Comprehensive second-line risk and compliance support, including leading the implementation of your risk management framework (RMF), compliance management framework (CMF), compliance monitoring program (CMP), compliance calendar and checklist, ongoing risk assessments, internal and external reporting, outsourced providers' management, and more
• AML/CFT advice
• AML/CFT compliance management
• Compliance assurance solutions, including compliance assurance program (CAP) development, implementation, and internal control testing

 

Service Coverage

This page is about the e‑money institution licence. We offer comprehensive support for a wide range of EMI licence applications tailored to meet the specific needs of the following businesses:

• Peer-to-Peer Payment Services
• Domestic Money Remitters
• Consumer Money Remitters
• Commercial Money Remitters
• Mobile Payment Providers
• Prepaid Card Issuers
• Remittance Service Providers
• Foreign Exchange Dealers
• International Money Remitters

You can find more information about our e‑money institution licence solutions below:

 

E-money Institutions Licensing Solutions

A comprehensive set of e-money institutions' compliance solutions to help businesses obtain and maintain an e-money institution's licence. Pre-licensing compliance assurance, application handling, regulatory liaison, and support for efficient compliance with e-money institutions' licensing requirements and other e-money institutions' regulations, including post-licensing EMI compliance management. We provide comprehensive support for a wide range of e-money institutions' licensing applications, including:

• Australia: Where e-money institutions are typically regulated by the Australian Securities and Investments Commission (ASIC) under the Corporations Act 2001. Typically, these institutions require an Australian Financial Services Licence (AFSL).
• United States: Where e-money institutions are regulated at both the federal and state levels. Federal regulation includes compliance with the Electronic Fund Transfer Act (EFTA) and state-specific Money Transmitter Licenses.
• United Kingdom: Where e-money institutions are regulated by the Financial Conduct Authority (FCA) under the Electronic Money Regulations 2011.
• Singapore: Where e-money institutions are regulated by the Monetary Authority of Singapore (MAS) under the Payment Services Act.
• European Union: Where e-money institutions should comply with the E-Money Directive (EMD) and the Payment Services Directive (PSD2), regulated by national competent authorities.
• Cayman Islands: Where e-money institutions fall under the broader financial services regulations and may require licensing from the Cayman Islands Monetary Authority (CIMA) under the Money Services Law.
• Bermuda: Where e-money institutions are regulated by the Bermuda Monetary Authority (BMA) under the Digital Asset Business Act 2018.
• Gibraltar: Where e-money institutions are regulated by the Gibraltar Financial Services Commission (GFSC) under the Financial Services (Electronic Money) Regulations 2011.
• British Virgin Islands: Where e-money institutions are regulated by the British Virgin Islands Financial Services Commission (BVI FSC) under the Financing and Money Services Act.
• Seychelles: Where e-money institutions are regulated by the Financial Services Authority (FSA) under the Financial Services Authority Act.
• Vanuatu: Where e-money institutions are regulated by the Vanuatu Financial Services Commission (VFSC) under the Financial Dealers Licensing Act.

 

 

E‑money Institution Licence Preparation

Pre-licensing Compliance Assurance

Our e‑money institution licence solutions cover the following focus areas:

• Compliance Goals Analysis: We review your business-specific goals and resources against the suitability criteria for an e‑money institution licence
• Initial Consultation: We provide guidance on potential risk and compliance issues that may arise during the e‑money institutions' licensing process
• Choosing the Right Jurisdiction: We assist in evaluating regulatory, risk, and compliance environments to determine the most suitable jurisdictions for your e‑money institution licence, tailored to suit your:

• business objectives,
• operational capacity,
• client base,
• markets of operations,
• and other relevant factors

• Gap Analysis: We identify gaps between your existing operations and regulatory requirements and help you align them in a commercially oriented manner
• EMI Licence Application Plan: We help you establish a roadmap to effectively meet the e‑money institution licence requirements

 

 

E‑money Institution Licence Guidance

Selecting the right compliance model is crucial not only for navigating the licensing process but also for maintaining ongoing compliance and avoiding potential breaches. Our e‑money institution licence solution covers:

• Compliance Model Selection: To help you best comply with the EMI licensing regime and related risk and compliance obligations.
• Corporate Governance Model Selection: We offer practical guidance on establishing effective corporate governance practices that support your risk and compliance oversight.
• Operations Model Advisory: We advise you on optimising your operational and governance models to help you efficiently comply with the EMI licensing regime and other applicable regulated e‑money institutions’ obligations, keeping in mind your specific circumstances, available resources and business goals.

 

E‑money Institution Licence and Entering the Regulated Environment

We help businesses transition from an unregulated environment to operating under the EMI licensing regime, helping them meet their obligations as an e‑money institution licence holder.

We also assist already regulated businesses in aligning their existing risk and compliance management structures with the EMI licensing regime requirements.

Our focus areas for this service include:

• New businesses
• Existing payment institutions operating in unregulated markets
• Regulated UK payment institutions  expanding into foreign jurisdictions
• Financial institutions and/or service providers with an established risk and compliance framework seeking to offer regulated money transfer services as a new product.

 

Multi-Jurisdictional Compliance

With years of experience managing risk and compliance obligations for businesses operating under multiple financial licences across various jurisdictions, we help businesses remain compliant with the regulated payment institutions’ obligations globally.

 

E‑money Institution Licence and Wholesale Markets

Getting an e‑money institution may not always be the best fit for all. For example, a retail market expansion may not always align with your goals or the products you offer.

Operating in the wholesale environment can sometimes be a more suitable option. We offer a wider range of risk and compliance management solutions to assist  e‑money institutions that:

• Operate in the wholesale markets
• Operate under exemptions from the EMI licensing regime
• Offer services to sophisticated, eligible, and wholesale investors

We help them comply with the regulatory compliance obligations that are not caught by the  eEMI licensing regime, but that still have to be addressed and handled, including:

• Advertisement Rules
• Fair Dealing Regulations
• Risk Management
• Outsourced Providers' Oversight
• Restrictions on offering services to retail investors without a licence
• Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) laws and regulations
• Data Management Laws and Regulations

 

EMI Licence Application

We assist with your licence application through ongoing engagement in the e‑money institution licence process:

• Document Compilation and Review: We compile and review all required supporting documents to support your EMI licence application.
• Application Form Completion: We help you complete the forms so that all material information is accurate and complete.
• Pre-Submission Review: We can arrange a pre-submission review session with key stakeholders to ensure all parts of your application are understood and agreed upon. This session aligns application details with the actual situation, removing ambiguity.
• Regulatory Liaison: We manage the end-to-end submission process, maintaining clear and effective communication channels throughout the regulated e‑money institutions' licensing process.
• Timeline Management: We closely monitor and adhere to all necessary deadlines, providing timely updates and adjustments to keep the EMI licence application process on track.

 

Resolving E‑money Institution Licence Issues

Having competent compliance advisors is crucial when licensing issues arise. Therefore, our e‑money institution licence solutions include a range of services to address and resolve these issues effectively:

• Remediation Solutions for E‑money Institution Licence Applicants: We address and remediate risk and compliance issues identified by regulators, helping your operations align with the e‑money institutions' licensing regime requirements.
• Specific Licence Conditions Compliance: We can help you manage additional conditions imposed on your e‑money institution licence, developing a tailored action plan to maintain compliance and facilitate the eventual removal of these conditions with minimal disruption to your business operations.
• Licensing Issues Handling: We address common licensing issues encountered during the e‑money institution licence process, providing you with solutions to navigate and resolve these challenges efficiently.
• Further Information: You can visit our Compliance Remediation Solutions page for more information.

 

Post-Licensing Support

We offer a full range of ongoing risk and compliance solutions for regulated UK payment institutions. Our services include, but are not limited to:

Ongoing Risk and Regulatory Compliance

• Regulated Payment Institutions’ Obligations Guidance: We can advise your risk, compliance, management and other teams on meeting the requirements of the EMI licensing regime and other regulatory compliance obligations. You can visit our Compliance Advisory page for more information.
• Regulatory Risk and Compliance Management: We provide dedicated compliance managers to manage your overall compliance. For more information, visit our global Compliance Management Solutions page for Money Remmitance Providers
• Compliance Assurance Solutions: As part of our compliance assurance solutions, we offer:
• Compliance Assurance Program (CAP) development and testing options
• Internal Controls Design option
• Internal Controls Testing option
• Internal AML/CFT Review option
• Statutory AML/CFT Audit option
• Compliance Training Solutions: We offer training programs to different teams on complying with:

• regulated e‑money institutions’ obligations for risk and regulatory compliance management. You can visit our Compliance Training page for more information.
• regulated e‑money institutions’ AML/CFT obligations and operational best practices for fraud prevention. You can visit our AML/CFT Training page for more information.

• Crisis Management Planning: We can develop proactive strategies to manage potential compliance crises effectively.
• Anti-Money Laundering (AML) and Counter Terrorist Financing Solutions: We provide a full range of AML/CFT solutions for UK payment institutions. For more information, visit our Specialised AML/CFT Solutions page for Money Remitters.
• Advanced Compliance Technologies: We can assist you with selecting and integrating advanced technology solutions, such as compliance automation tools and regulatory technology (RegTech), to streamline compliance processes without disrupting operations.
• Risk and Compliance Framework Adjustments: Including adjustments to risk management frameworks (RMFs), compliance monitoring programs (CMPs), compliance management frameworks (CMFs), and other core procedures and policies to align them with:
• new business goals
• regulatory changes
• changes in your operations
• evolving market conditions
• changes in stakeholders’ risk appetites (your banking partners, insurance companies, liquidity providers, etc.).

 

 

Risk and Compliance Obligations for E‑money Institution Licence Holders

E-money institution licence holders are subject to various obligations set out in applicable laws and regulations. They are also expected to uphold standards for their conduct and internal operations, as outlined in regulatory guidance or accepted industry practices.

We can help you address these obligations and expectations through comprehensive support across various areas. The list below is not exhaustive:

E‑money Institution Licensing and Regulatory Compliance Obligations

• Compliance Management Systems: We can help you establish effective compliance programs, compliance monitoring plans, controls testing methodologies, compliance calendars and more.
• Risk Management Frameworks: We can help you develop comprehensive risk management regimes to fulfil regulated e‑money institutions’ obligations for identifying, assessing, and mitigating operational, regulatory, strategic, financial and other types of risks.
• Policy and Procedure Development: We can help you draft and implement policies and procedures aligned with the e‑money institutions' licensing requirements.
• Compliance Monitoring Plans: We can oversee the execution of your CMPs, covering ongoing monitoring of your compliance obligations under the e‑money institutions' licensing regime.
• Internal Control Testing and Compliance Assurance: We can conduct internal reviews and audits of your controls to test their effectiveness and compliance with the applicable regulatory standards.
• Digital Payment Token Services: If your business supports digital assets or stablecoin-based transfers, we can help you develop controls to meet AML/CFT requirements and applicable licensing conditions for digital payment token services, including transaction monitoring, wallet screening, and Travel Rule compliance.
• Safeguarding of Client Funds: We can help you implement and document safeguarding arrangements for customer funds under the EMI licensing regime.
• Data Protection and Privacy Controls: We can help you establish robust controls to comply with global data protection and privacy laws—GDPR (EU/UK), PDPA (SG), Privacy Act (AU), Privacy Act (NZ)-including data‑minimisation, breach notification processes, and secure handling of customer data.
• Financial Promotions Oversight: We can help you develop and implement controls to ensure all marketing materials and financial promotions comply with e‑money, payment services and consumer protection rules (EMRs, PSA, PSRs), preventing misleading statements and ensuring fair representation of features, fees and risks.
• Consumer Duty and Product Governance: We can help you design and embed product governance frameworks and controls to meet emerging Consumer Duty requirements (FCA) and equivalent fair‑outcomes expectations in other jurisdictions, ensuring your e‑money products deliver good customer outcomes.
• PSD2/Open Banking Technical Compliance: We can help you implement processes and controls to comply with PSD2 and local open‑banking API standards, including Strong Customer Authentication (SCA), secure API management, third‑party access governance, and technical reporting.

 

E‑money Institution Licensing and Operational Oversight Obligations

• Oversight of Outsourcing: We can establish a set of effective controls to comply with regulated e‑money institutions’ obligations for overseeing outsourced services, also covering related obligations under AML/CFT compliance, ISO requirements, and more
• Structures for Governance: We can help you establish effective governance structures to comply with regulated e‑money institutions’ obligations and develop an effective approach to overseeing your risk exposure and compliance status across different functions of your business.
• Senior Management Accountability: We can help you comply with the regulated e‑money institutions’ obligations for senior management and key staff conduct and competence.
• Maintaining Operational Resilience: We assist in developing continuity plans to meet regulated e‑money institutions’ obligations for operational resilience and transaction flow continuity, helping critical business services withstand disruptions.
• Managing Technology Risks: We provide guidance on technology risk management obligations under the EMI licensing regime.
• Business Continuity Frameworks: We can help you document and implement business continuity plans to comply with the FCA's expectations for operational continuity under the e-money institutions' licensing regime.

 

E‑money Institution Licensing and Market Integrity/Transparency Requirements

• Principles for Fair Treatment: We can help you implement controls to comply with expectations that cover adherence to principles of fair treatment and transparent communications with clients.
• Standards for Conduct and Disclosure: We can help you comply with e‑money institutions' licensing standards for conduct and disclosure.
• Protection of Client Assets: We can help you comply with e‑money institutions' licensing obligations to protect and segregate client assets.
• Resolution of Disputes: We can help you establish effective mechanisms for dispute resolution and complaints management, particularly for retail clients.

 

E‑money Institution Licensing and Resource Management Obligations

We can help you comply with the following requirements of the e‑money institutions' licensing regime:

• Adequacy of Resources: Covering financial, technological, human and other resources.
• Competence of Professionals: Covering key personnel, their necessary skills, knowledge, and professional competence.
• Our focus areas include:

• Assessment and Gap Analysis: We can help you evaluate the adequacy of your financial, technological, and human resources against the requirements of the EMI licensing regime.
• Resource Allocation Plans: We can help you develop strategies to optimise resource allocation, covering sufficient capacity for compliance, trading, operations, banking, customer support and other functions and departments.
• Technological Solutions: We can recommend and implement RegTech tools to streamline compliance processes, such as transaction monitoring, reporting, and audit trails.
• Key Personnel Assessment: We can help you assess the skills, qualifications, and experience of key personnel to identify areas for improvement.
• Training and Development Programs: We can design and deliver targeted compliance training programs to upskill personnel in compliance, risk management, and money transfer regulations.
• Representative Vetting: We can help establish a framework for assessing the competence and suitability of advisors and representatives before appointment.
• Compliance Monitoring: We can help develop controls to monitor representatives' adherence to conduct and disclosure obligations.
• Ongoing Training: We can help you create a framework to support continuous education for advisors and representatives on licensing obligations, market integrity, and client interaction standards.
• Regulator Liaison: We can act as an intermediary with regulators to address queries and help you demonstrate compliance with resourcing obligations.

 

E‑money Institution Licensing and Reporting

• Regulatory Reporting: We can help you prepare and submit periodic and ad-hoc reports covering:
  • regulated e‑money institutions’ licensing obligations
  • regulated e‑money institutions’ AML/CFT obligations (SMRs, STRs, SARs, cross-border transaction reports, cash transaction reports, and other reporting obligations)
• Incident Reporting: We can assist you in meeting your FCA notification requirements for fraud events, IT outages, and safeguarding breaches under the EMI licensing regime.
• Compliance Documentation: We can help you develop and maintain the necessary documentation to meet record-keeping obligations under various laws and regulations.
• Audit Readiness: We can prepare you for audits and reviews to demonstrate compliance with regulatory requirements, provisions of the e‑money institutions' licensing regime, applicable operational standards, and more.