FCA Electronic Money Institution Authorisation Solutions | Pre-licensing Support | FCA EMI Authorisation Application Management | Post-licensing Risk and Compliance Solutions

We offer a comprehensive set of solutions to help you obtain and maintain a UK Electronic Money Institution (EMI) Authorisation issued by the UK Financial Conduct Authority (FCA) under the Electronic Money Regulations 2011 (EMRs), 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
• FCA regulated electronic money 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 UK EMI authorisation regime in a commercially oriented and goal-focused manner, providing effective support for all stages of the FCA electronic money institution authorisation process, including but not limited to the following aspects:

• FCA Electronic Money Institution Authorisation Guidance: Advising on a wide range of aspects associated with FCA electronic money institution authorisation 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 FCA electronic money institution authorisation conditions and financial markets' regulations
• Developing internal controls to help you meet your obligations under the UK EMI authorisation regime
• FCA EMI Application Support: Covering the entire UK EMI authorisation 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 UK Electronic Money Institution Authorisation. In the United Kingdom, firms that issue electronic money - including prepaid cards, digital wallets, and stored-value payment solutions - must be authorised or registered with the FCA under the Electronic Money Regulations 2011 (EMRs).

There are two tiers of authorisation:

• Small Electronic Money Institution (SEMI) – for firms with lower outstanding e-money balances, subject to thresholds and reduced prudential requirements.
• Authorised Electronic Money Institution (AEMI) – for firms exceeding thresholds, or seeking to provide cross-border e-money issuance, subject to higher prudential, governance, and safeguarding obligations.

EMIs are subject to a wide range of regulatory obligations, including: safeguarding customer funds, AML/CTF compliance, conduct of business rules, capital adequacy, governance and internal controls, and FCA reporting. We offer comprehensive support for a wide range of FCA EMI applications tailored to meet the specific needs of the following businesses:

• Prepaid card issuers
• Digital wallets and mobile payment providers
• Cryptocurrency and stablecoin businesses offering fiat-backed e-money equivalents
• Fintech platforms integrating e-money issuance with payments
• International PSPs expanding into the UK market

You can find more information about our FCA electronic money institution authorisation solutions below:

 

FCA Electronic Money Institution Authorisation Preparation

Pre-licensing Compliance Assurance

Our FCA electronic money institution authorisation solutions cover the following focus areas:

• Compliance Goals Analysis: We review your business-specific goals and resources against the suitability criteria for an FCA electronic money institution authorisation
• Initial Consultation: We provide guidance on potential risk and compliance issues that may arise during the UK EMI authorisation process
• Choosing the Right Jurisdiction: We assist in evaluating regulatory, risk, and compliance environments to determine the most suitable jurisdictions for your FCA electronic money institution authorisation, 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
• FCA EMI Application Plan: We help you establish a roadmap to effectively meet the FCA electronic money institution authorisation requirements

 

 

FCA Electronic Money Institution Authorisation Guidance

Selecting the right compliance model is crucial not only for navigating the UK EMI authorisation process but also for maintaining ongoing compliance and avoiding potential breaches. Our FCA electronic money institution authorisation solution covers:

• Compliance Model Selection: To help you best comply with the UK EMI authorisation 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 UK EMI authorisation regime and other applicable FCA regulated electronic money institutions’ obligations, keeping in mind your specific circumstances, available resources and business goals.

 

FCA Electronic Money Institution Authorisation And Entering The Regulated Environment

We help businesses transition from an unregulated environment to operating under the UK EMI authorisation regime, helping them meet their obligations as an FCA electronic money institution authorisation holder.

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

Our focus areas for this service include:

• New businesses
• Existing money remmitance providers operating in unregulated markets
• Regulated UK EMIs  expanding into foreign jurisdictions
• Financial institutions and/or service providers with established risk and compliance frameworks 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 EMI obligations globally.

 

FCA Electronic Money Institution Authorisation and Wholesale Markets

Obtaining a UK EMI authorisation may not always be necessary or suitable for all businesses, particularly where activities are limited to intragroup transactions, wholesale settlement, or corporate treasury/payment flows that fall outside the scope of the Electronic Money Regulations 2011. Wholesale or corporate-only models are generally not regulated as retail e-money issuance.

We offer risk and compliance management solutions to assist wholesale or exempt businesses that:

• Operate exclusively in wholesale settlement or intragroup payment flows
• Qualify for exemptions under the EMRs (e.g., limited network or technical service provider exemptions)
• Provide treasury or corporate solutions without retail customer exposure

We help these businesses manage obligations that may still apply, including:

• FCA perimeter guidance (PERG) compliance and exemption analysis
• AML/CTF compliance under the UK Money Laundering Regulations 2017
• Data protection and PSD2-derived security requirements
• Restrictions on issuing e-money to retail clients without FCA authorisation
• Governance, risk management, and outsourced service provider oversight

 

FCA EMI Application

We assist with your licence application through ongoing engagement in the FCA electronic money institution authorisation process:

• Document Compilation and Review: We compile and review all required supporting documents to support your FCA EMI 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 UK EMI authorisation process.
• Timeline Management: We closely monitor and adhere to all necessary deadlines, providing timely updates and adjustments to keep the application process on track.

 

Resolving FCA Electronic Money Institution Authorisation Issues

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

• Remediation Solutions for FCA Electronic Money Institution Authorisation Applicants: We address and remediate risk and compliance issues identified by regulators, helping your operations align with the UK EMI authorisation regime requirements.
• Specific Licence Conditions Compliance: We can help you manage additional conditions imposed on your FCA electronic money institution authorisation, developing a tailored action plan to maintain compliance and facilitate the eventual removal of these conditions with minimal disruption to your business operations.
• UK EMI Authorisation Issues Handling: We address common UK EMI authorisation regime issues encountered during the FCA electronic money institution authorisation 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 EMIs. Our services include, but are not limited to:

Ongoing Risk and Regulatory Compliance

• FCA Regulated Electronic Money Institutions’ Obligations Guidance: We can advise your risk, compliance, management and other teams on meeting the requirements of the UK EMI authorisation 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 EMIs
• 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:

• FCA regulated electronic money institutions’ obligations for risk and regulatory compliance management. You can visit our Compliance Training page for more information.
• FCA regulated electronic 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 EMIs. For more information, visit our Specialised AML/CFT Solutions page for EMIs.
• 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 FCA Electronic Money Institution Authorisation Holders

FCA electronic money institution authorisation 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:

UK Electronic Money Institution Authorisation 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 (as required under the SYSC 6.1 and EMRs).
• Risk Management Frameworks: We can help you develop comprehensive risk management frameworks to fulfil FCA regulated electronic money institutions’ obligations for identifying, assessing, and mitigating operational, regulatory, strategic, financial and other types of risks (as required under the SYSC 7.1 and EMRs).
• Policy and Procedure Development: We can help you draft and implement policies and procedures aligned with the UK EMI authorisation requirements (as required under the PSRs 2017, Reg 18).
• Compliance Monitoring Plans: We can oversee the execution of your CMPs, covering ongoing monitoring of your compliance obligations under the UK EMI authorisation regime (as required under the PSRs 2017, Reg 18).
• 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 UK EMI authorisation regime.

 

UK Electronic Money Institution Authorisation and Operational Oversight Obligations

• Oversight of Outsourcing: We can establish a set of effective controls to comply with FCA regulated electronic money institutions’ obligations for overseeing outsourced services, also covering related obligations under AML/CFT compliance, ISO requirements, and more as required under the EMRs).
• Structures for Governance: We can help you establish effective governance structures to comply with FCA regulated electronic 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 FCA regulated electronic money institutions’ obligations for senior management and key staff conduct and competence (as required under the FCA SM&CR framework).
• Maintaining Operational Resilience: We assist in developing continuity plans to meet FCA regulated electronic 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 UK EMI authorisation 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 UK EMI authorisation regime.
• Prohibition on Interest: We can help you document your product structure to demonstrate compliance with the prohibition on paying interest or time-linked benefits on e-money balances.
• Agent and Distributor Oversight: We can help you put in place notification, onboarding and monitoring frameworks for agents and distributors to meet FCA requirements.

 

UK Electronic Money Institution Authorisation 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 (as required under FCA Principles for Businesses).
• Standards for Conduct and Disclosure: We can help you comply with UK EMI authorisation standards for conduct and disclosure.
• Protection of Client Assets: We can help you comply with the UK EMI authorisation regime requirements 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.
• Enhanced Safeguarding: We can help you design and document enhanced safeguarding arrangements, including segregated accounts, trust or insurance mechanisms required for EMIs.
• Restrictions on Activities: We can help you assess your business activities against EMR restrictions and document controls, showing that non-permitted activities do not impact your EMI’s financial soundness.

 

UK Electronic Money Institution Authorisation and Resource Management Obligations

We can help you comply with the following requirements of the UK EMI authorisation 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 UK EMI authorisation 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 FCA regulated EMIs' 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.

 

UK Electronic Money Institution Authorisation and Reporting

• Regulatory Reporting: We can help you prepare and submit periodic and ad-hoc reports covering:
  • UK EMI authorisation regime requirements
  • FCA regulated electronic 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 EMR authorisation regime (as required under SUP 15.3).
• 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 UK EMI authorisation regime, applicable operational standards, and more.