Fintech & Licensing (EMI, MSB, VASP)

Why Tomorrow’s Financial Innovators Build on Regulated Offshore Fintech Licenses

If you touch money, payments or digital assets at scale, you don’t just have a “startup”. You are stepping into the regulated financial system, whether you like it or not. Without a proper licensing and regulatory plan, you quickly run into:

• Banks closing accounts because they “don’t understand the model”.
• EMI and card partners offboarding you after one compliance review.
• Regulators classifying you as an unlicensed payment institution or VASP.
• Card schemes and processors treating you as high-risk by default.
• Investors walking away because your regulatory perimeter is unclear.

A serious fintech or payments business cannot be built on vague “we’re just a tech platform” positioning. You need a clear, documented regulatory strategy: which licences you need (and which you don’t), which partners sit around you, and how your compliance, technology and capital stack support that story.

The goal is to:

• Operate inside the rules, with room to scale.
• Use other people’s licences where it makes sense – and your own where it matters.
• Build something investors, banks and regulators are willing to bet on.

What a fintech & licensing strategy can do for you

“EMI vs MSB vs VASP” is not just jargon. It’s shorthand for what you are allowed to do, where you can operate, and how counterparties will treat you. When we design a plan, it can:

Define your regulatory perimeter

• Clarify whether you’re a money service business, EMI, payment institution, VASP, agent, distributor, programme manager, or some combination of these.
• Map activities (issuing cards, holding client funds, FX, remittance, crypto brokerage, custody, on/off-ramp, wallets) to specific rules.

Choose the right licence path and sequence

• Decide when to rely on partners’ licences (sponsoring banks, EMIs, licensed exchanges) and when to apply for your own.
• Prioritise jurisdictions where your model, risk profile and budget actually fit.

Make banks and regulators more comfortable

• Present a coherent governance, AML/CTF and risk framework, not improvised policies.
• Show that capital, safeguarding, IT security and outsourcing are under control.

Unlock better economics and valuations

• Move from pure agent/referral economics to owning more of the value chain as you mature.
• Position the company so acquirers recognize it as a regulated platform, not just a thin front-end.

Reduce “headline risk”

• Design your crypto, high-risk or cross-border elements so they are explainable, documented and defensible when tested.

A Global Toolkit - Not “just get a licence in Country X”

There is no one perfect licence or jurisdiction. There is a stack of options that can be combined and sequenced.

EMI / Payment Institution regimes

For card issuing, IBAN accounts, e-money wallets and payment processing.

• EU/EEA EMIs and PIs.
• UK e-money and payment institutions.
• Selected mid-shore EMIs integrated with card schemes and SEPA/Swift rails.

MSB / MTL regimes

For money transmission, FX, remittance, and dealing in virtual currencies.

• Canada MSB registrations and full builds.
• US federal MSB (FinCEN) plus state Money Transmitter Licences (MTL).
• Other national MSB-type frameworks where your model fits.

VASP / digital asset registrations and licences

For exchanges, brokers, custodians, NFT platforms and crypto payment rails.

• VASP regimes in Europe and other leading jurisdictions.
• MiCA and other evolving frameworks where advance planning is essential.
• Hybrid structures where crypto sits alongside fiat EMI / MSB activity.

Agency, programme and partnership models

For founders who don’t need or cannot yet justify a full licence.

• Agent / distributor arrangements under existing EMIs and PIs.
• BIN sponsorship / card programme partnerships.
• White-label and BaaS arrangements with realistic risk and margin analysis.

You are commissioning a regulatory architecture that may include:

• One or more licensed entities (EMI, MSB, VASP, PI).
• Tech / IP companies, unregulated or lightly regulated.
• Outsourcing chains: KYC providers, processors, ledger, custodians.
• Governance: Board, MLRO/AMLCO, compliance, and internal audit functions.

Typical Strategies We Design

1. “Partner-first, licence-later” fintech launch

• Map product features against regulatory definitions.
• Structure an agent / programme manager model under licensed partners.
• Draft commercial agreements, risk-sharing, and compliance responsibilities.
• Build a roadmap for when to apply for your own licence as volumes justify it.

2. Building your own EMI / MSB / VASP platform

• Compare candidate jurisdictions based on model, risk, budget, and timelines.
• Design corporate structure: regulated entity, holding, tech/IP and commercial arms.
• Define governance: board composition, local directors, MLRO, risk and audit.
• Build the licensing pack: business plan, financials, capital plan, and AML/CTF framework.

3. Crypto businesses seeking to become bankable

• Clarify whether your model is a VASP, an EMI+VASP hybrid, or a pure tech stack.
• Position your flows (fiat, stablecoins, native tokens) so regulators and banks understand them.
• Design custody and safeguarding: on-balance sheet vs segregated accounts.
• Implement Transaction Monitoring and Travel Rule solutions that actually work.

4. International MSB / payments hub strategy

• Evaluate whether to anchor in one strong jurisdiction with agent networks or build multiple local licences.
• Allocate activities to manage regulatory capital, safeguarding and risk.
• Align cross-border flows with FX, treasury and liquidity management.

5. Regulatory clean-up and regularisation

• Regulatory gap analysis: what licences you should have vs. what you have today.
• Priority risk map: where you must act immediately to reduce exposure.
• Transition plan into a coherent, properly licensed model.

How Our Process Works

Step 1 - Diagnostic & perimeter mapping

We deep-dive on your tech stack, geographic footprint, and risk profile. We produce a clear view of what you are today and where the biggest risks sit.

Step 2 - Design the licensing & partner architecture

We design a Fintech & Licensing Plan that sets out which licences you need now vs. later, which jurisdictions make sense, and how money moves through the system.

Step 3 - Implementation & licence execution

We prepare your regulatory business plan, build your AML/CTF framework, and support you through Q&A with regulators and banks. We ensure your compliance story matches your infrastructure.

Step 4 - Ongoing governance & evolution

Once live, we assist with regulatory reporting, support you through bank/scheme reviews, and help you plan new products without breaking your licence conditions.

Who This Is For

• Founders building payment, FX, card, wallet, or remittance platforms.
• EMI and MSB operators wanting to expand into new markets.
• Crypto operators who want to become bankable and compliant.
• Traditional businesses adding embedded finance or “banking-as-a-feature”.
• Investors backing fintech platforms who need clarity on regulatory risk.

Note: We build regulatory structures that are defendable, auditable and investable. We do not work with "licence renting" or shadow banking models.

Why Work With Us (rather than a generic licence factory)?

• Structure-first, not “tick-box” licensing: We design governance so the licence can survive scrutiny from regulators and card schemes.
• Integrated view across fiat and crypto: We design hybrid models that make sense instead of fighting two sets of regulators.
• Banking and partner reality at the centre: We design with correspondent banking and de-risking trends in mind from day one.
• Jurisdiction-agnostic: We propose the right model for you, not just the most popular "island" destination.
• Long-term relationship: We stay engaged so your framework evolves with the rulebook instead of being caught out.

Common Questions

Ready to turn “we’re kind of like a bank, but not really” into a serious regulated platform?

If your product is already moving money or digital assets, or about to, you are in the financial system whether you acknowledge it or not.

We’ll walk you through:

• What you are really doing in regulatory terms.
• Which licensing and partner options genuinely fit your model and stage.
• How to build an architecture that is compliant, scalable and investable over the next 5-10 years.

Book a confidential strategy call to explore what a serious EMI / MSB / VASP licensing plan would look like for your business.