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Where to register YOUR Electronic Money Institution (EMI) ?
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post Feb 9 2019, 11:23 PM
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The first thing that comes to mind when entering the business of Payment Service Provider is :

What is an EMI (Electronic Money Institution)
Where to register the company?
Which license to get and passporting?
What are the capital requirements for the business?


EMIs are Payment Service Providers which carry out the following payment services:

1) Services enabling cash to be placed on a payment account and all operations required for a payment account.

2)Services enabling cash withdrawals from a payment account and all operations required for a payment account .

3)The execution of different types of payment transactions : direct debits, payment transactions executed via a payment card or similar device, credit transfers including standing orders .

4)The execution of following types of payment transactions where the funds are covered by a credit line for the service user, Direct debits, payment transactions executed by a payment card or credit transfers including standing orders .

5)Issuing payment instruments or acquiring payment transactions .

6) Money Remittance.

7)The execution of payment transactions where the consent of the payer to execute the payment transaction is given by any telecommunication, digital or IT device and the payment is made to the telecommunication, IT system or network operating as an intermediary between the user and the supplier.

8) Issue Electronic Money or digital currency for example money balance stored electronically on a stored value card (prepaid cards), E Wallets or other devices.

NOTE : Difference between PI or API (Payment Institution or Authorized Payment Institution) is only clause 8 since they can perform all the services of an EMI other than issue digital currency.

Which jurisdiction is the best choice for your new EMI business?

The best places to give your brand some credible backing of regulations is to register in EEA. EEA regulators are accepted as one of the best in keeping clients money safe and some sound regulations. The best for this case are UK, Lithuania, Czech Republic, Malta & Ireland. Some of these (UK & Malta) regulators have requirements like hiring of local staff and may demand for the directors to be local so you may choose UK for the highly prestigious regulation however Czech Republic and Lithuania offer a good compromise between services offered and prestigious jurisdiction with a more easy application as well.

Once you have your first EEA(European Economic Area) license you can passport the firm registered to other countries in the EEA without further authorizations needed. Many big multinational firms do this to increase their business presence in other countries.

Capital Requirements:

There are two sub categorizations of EMIs having small and full license. Depending on what type of EMI you want to start, what type of services you want to provide and where you get the licensing from will affect the capital requirements.

For example if you have a monthly turnover of less than 3 Million Euro then you can obtain a small EMI license and if your turnover exceeds this then you might need a full license.

For small EMIs the capital requirements range from 50,000 Euro to 60,000 Euro

whereas for full licenses EMIs providing all services might range between 350,000 Euro to 400,000 Euro.

Extra services you might consider :

1) Connection to Centrolink(central system provided for own clearing) allowing firm to provide IBANs to its customers.

2)Registration with SWIFT.

3)Connection to SEPA.

4)Card acquiring.

5)Issuing own cards.

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