To begin, it is important you understand how the business model you wish to provide is regulated, either under the payment services or e-money regulations.

This will depend on:

• Where are you based and where do you want to offer your services?
• Are there any exclusions you can utilise?

Answering these questions will help you understand whether your only option is to get regulated.

Once you’ve determined you need to get regulated, what are the key requirements you need to consider before going any further?

• Do you have the right team on board?
• Have you identified the costs involved in being an authorised e-money institution?
• Can you safeguard your customers’ funds?
• Have you considered how you will wind-down your business?

From the outset, we will discuss all the important considerations and requirements with you so that you understand what is expected of you throughout the application process. Based on our experience, we will highlight to you any areas of weakness or areas that may be problematical, and we will suggest how the issues can be remedied so that you can make the best case for registration or authorisation.

During this phase, you may have key decisions to make about which activities to include in the initial phase of your business and which to plan to undertake later, how to organise your business and who to appoint as suppliers and staff.

We will then complete the application forms and compile the supporting documentation based on the business arrangements your team has developed and agreed. 

Your board of directors and senior management team should receive regular reports that allow them to keep track of the risks to which the business is exposed. Management information should include:

• confirmation that there are adequate capital resources;
• the results from the compliance testing;
• how many internal and external suspicious activity reports were made;
• confirmation that the safeguarding procedure has been followed;
• and a review of the risk register.