Financial law
Payment services, EMIs and PSPs, AML compliance, crypto regulation (MiCA, VARA), payment agents for high-risk industries. When you need your own licence, when a partner model is enough, and what an AML framework a correspondent bank will accept looks like.
Four strands of the practice
Payments regulation
What counts as a payment service, who needs authorisation and which one.
AML / KYC
Policies, procedures and roles that stand up to the regulator and the bank.
Crypto regulation
MiCA in the EU, VARA in Dubai, the securities test.
Contracts in payments
With merchants, providers, partner banks.
The tasks clients came to us with
An EMI agent instead of an own licence: launched in four months
Terms with the principal, AML policies to the principal’s and the Bank of Lithuania’s requirements, a UK company for sales; the own licence is planned for year two.
A PSP for the affiliate industry: an AML framework the correspondent bank accepted
A rewritten acceptance policy, merchant risk scoring, monitoring with thresholds — the account opened at the second bank.
Moving an exchanger from a VASP registration to CASP authorisation
Assessment of capital and governance requirements, filing in Poland, authorisation before the transition period closed.
How long does an EMI licence take?
From filing a complete pack, 9–18 months depending on the country. Preparing the pack takes another 3–6. That is why many start as an agent.
Does an exchanger need MiCA authorisation from 2025?
Yes, in the EU VASP registrations have been replaced by CASP authorisation; transition periods differ by country. Without authorisation, serving EU clients is not possible.
Who is the MLRO, and can it be the founder?
The person responsible for anti-money-laundering. Formally yes, but regulators expect experience and independence; for an EMI/CASP a separate person is usually needed.
How does a payment agent differ from a PSP?
An agent collects funds on the operator’s behalf under a contract without its own licence; a PSP is a licensed service. In gambling the agent is often part of the operator’s structure.
What we have written about financial law
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Read articleLaunching a payments or crypto product?
Describe how the money moves and where the clients are — we will say which authorisation is needed and which AML framework the bank expects.
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