Fintech & Licensing (EMI, MSB, VASP)

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

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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 not to become a bank overnight. 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

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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 licensing and regulatory plan, it can:

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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.

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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 licence.

   • Prioritise jurisdictions where your model, risk profile and budget actually fit.

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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.

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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 and investors recognise 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.

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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. We work across:

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 and payment firms integrated with the card schemes and SEPA/Swift rails

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MSB / MTL regimes

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

- Canada MSB registrations and full builds

- US federal MSB (FinCEN) plus state Money Transmitter Licences (MTL), in conjunction with specialist US counsel

- Other national MSB-type frameworks where your model fits

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VASP / digital asset registrations and licences

For exchanges, brokers, custodians, NFT / token 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

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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 not “buying a licence”. You are commissioning a regulatory architecture that may include:

• One or more licensed entities (EMI, MSB, VASP, PI)
• One or more unregulated or lightly regulated tech / IP companies
• Outsourcing chains: KYC providers, processors, core banking / ledger, card issuers, custodians
• Governance: board, MLRO/AMLCO, compliance, risk and internal audit functions

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Typical strategies we design

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

For early-stage founders who need to get live without taking on full regulatory burden on day one.

• Map actual product features and flows against regulatory definitions
• Structure an agent / programme manager / white-label model under one or more licensed partners
• Draft and align commercial agreements, risk-sharing, liability and compliance responsibilities
• Put in place internal policies and tech to meet partners’ AML, fraud and monitoring expectations
• Build a roadmap for when and where to apply for your own licence as volumes and economics justify it

2. Building your own EMI / MSB / VASP platform

For founders and operators ready to step up from partner-only to owning regulated infrastructure.

• Compare candidate jurisdictions based on model, risk, budget, timelines and investor story
• Design the corporate structure: regulated entity, holding, tech/IP and commercial arms
• Define governance: board composition, local directors, MLRO/Compliance Officer, risk and audit
• Build the licensing pack: business plan, financial projections, capital plan, risk assessment, AML/CTF framework, policies and procedures, outsourcing and IT security documentation
• Coordinate with local legal counsel to navigate regulator queries and conditions

3. Crypto / digital asset businesses seeking to become bankable

For exchanges, brokers, OTC desks, Web3 projects and payment rails that want to be treated as serious financial counterparties.

• Clarify whether your model is a VASP, an EMI+VASP hybrid, a pure tech stack, or something else
• Position your flows (fiat, stablecoins, native tokens, NFT value transfer) in a way regulators and banks can understand
• Design custody and safeguarding: on-balance sheet vs segregated accounts, hot/cold wallet policies, key management
• Implement Transaction Monitoring, Travel Rule solutions and sanctions screening that actually work with your use cases
• Integrate with correspondent banks, EMIs and payment processors who are able and willing to support your profile

4. International MSB / payments hub strategy

For operators aiming to run cross-border payments, FX and remittance at scale.

• Evaluate whether to anchor in one strong MSB/EMI jurisdiction with passporting / agent networks, or build multiple local licences
• Allocate activities between entities to manage regulatory capital, safeguarding and risk
• Align cross-border flows with FX, treasury and liquidity management
• Design a compliance and operational model that can be scaled – not rebuilt – when you enter new corridors

5. Regulatory clean-up and regularisation

For businesses that have grown first and are now realising they are likely “in scope”.

• Regulatory gap analysis: what licences or registrations you probably should have vs what you have today
• Priority risk map: where you must act immediately to reduce exposure (geographies, products, marketing claims)
• Transition plan to move from improvised arrangements into a coherent, properly licensed model
• Communication strategy for investors, partners and – where appropriate – regulators

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How our process works

We don’t start with “get an EMI licence in Jurisdiction Y”.

We start with what your product actually does, how money moves, and who you are dealing with.

Step 1 - Diagnostic & perimeter mapping

Deep-dive on:

• Your product(s), flows and tech stack: who sends what to whom, in which currency and instrument
• Geographic footprint: customers, merchants, counterparties and team
• Current regulatory status and partner arrangements
• Risk profile: industries, ticket sizes, chargebacks, fraud vectors, crypto exposure
• Capital, investor expectations and timing

We produce a clear view of:

• What you are today (in the eyes of banks and regulators)
• What you are trying to become
• Where the biggest regulatory and banking risks sit

Step 2 - Design the licensing & partner architecture

We then design a Fintech & Licensing Plan that sets out:

• Which licences and registrations you need now, later, or not at all
• Which jurisdictions make sense and in what order to approach them
• How your entities (licensed, tech, IP, holding) should be structured
• Where you should use partners (EMIs, banks, card issuers, custodians) and how to contract with them
• The governance, compliance and risk framework you will need to support this

You get legal diagrams and plain-English explanations: what licence sits where, who supervises it, and how money moves through the system.

Step 3 - Implementation & licence execution

Working alongside specialist local counsel where necessary, we:

• Prepare or refine your regulatory business plan, financials and capital plan
• Build or upgrade your AML/CTF and sanctions framework, including policies, risk assessment and monitoring architecture
• Draft or coordinate key governance documents: board charters, committee terms, key function role descriptions
• Support you through Q&A with regulators, banks and partners
• Coordinate with technology providers (core ledger, KYC, TM, Travel Rule, card processors, custody providers) so your compliance story matches your infrastructure

Step 4 - Ongoing governance & evolution

Once live, we can:

• Assist with regulatory reporting, thematic reviews and periodic audits (via local partners where required)
• Prepare you for and support you through bank / scheme / partner reviews
• Update your framework as regulations evolve (for example, MiCA, AML package, Travel Rule developments)
• Help you plan new products, corridors and features without breaking your licence conditions

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Who this is for

Our Fintech & Licensing work is designed for:

• Founders building payment, FX, card, wallet, remittance or account platforms
• EMI and MSB operators wanting to expand into new markets or lines of business
• Crypto and digital-asset operators who want to become bankable and compliant – not operate in a grey zone
• Traditional businesses adding embedded finance or “banking-as-a-feature” to existing products
• Investors and family offices backing regulated or semi-regulated fintech platforms who need clarity on regulatory risk

If you are looking for a way to “rent” a licence with no real governance, run shadow banking without safeguards, or hide high-risk flows behind a thin front-end, we are not the right firm.

We build regulatory structures that are defendable, auditable and investable.

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Why work with us (rather than a generic licence factory)?

Structure-first, not “tick-box” licensing

We don’t just file forms and hand you a licence. We design the structure, flows and governance so that the licence can survive real-world scrutiny from regulators, banks and card schemes.

Integrated view across fiat and crypto

We understand both traditional EMI/MSB frameworks and emerging VASP regimes. That allows us to design hybrid models that make sense instead of fighting two sets of regulators at once.

Banking and partner reality at the centre

A licence without banking and scheme access is a very expensive certificate. We design with correspondent banking, de-risking trends and partner risk appetites in mind.

Jurisdiction-agnostic

We are not tied to a single country or provider. If a popular licensing destination is wrong for your model, risk tolerance or budget, we will say so and propose alternatives.

Long-term relationship, not one-off approval

Regulation and risk expectations move. What passed five years ago may not pass now. We stay engaged so your framework evolves with the rulebook – instead of being caught out.

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Common questions

“Do I really need a licence? We’re just a tech platform.”

If you touch client funds, instruct movements of money, hold e-money balances, intermediate FX or handle crypto for others, there is a high chance that at least one regulator disagrees with “just tech”. Our job is to map activities to rules and give you a clear answer.

“Can we just use a partner’s licence forever?”

Sometimes yes, especially if your value lies in distribution, UX or niche segments. But margins, control and valuation are often limited without some form of own regulatory asset. We’ll help you decide what makes sense at your scale.

“Will getting a licence make banking easy?”

It helps - but only if the underlying model, governance and risk profile are credible. A licence plus a weak compliance culture is still unbankable. We design for both.

“How long does it take?”

It depends on jurisdiction, licence type and how ready you are. Partner-based launches can be structured in weeks; full licences typically take months to over a year from serious start to approval. Your plan will include realistic timelines and milestones.

“Is this overkill for an early-stage startup?”

Not if you’re anywhere near other people’s money. A clear regulatory and licensing narrative is one of the quickest ways to stand out with banks, partners and investors - and to avoid fatal mistakes early on.

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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 a fintech & licensing 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.