Services you can provide with an Electronic Money Institution Licence in Ireland
 

An Electronic Money Institution licence in Ireland enables the licence holder to offer a number of services:
 

     -     Issuing of electronic money e.g. prepaid cards and electronic wallets. 
     -     services enabling cash to be placed on a payment account and all the operations required for operating a payment account;
     -     services enabling cash withdrawals from a payment account and all the operations required for operating a payment account;
     -     the execution of payment transactions, including transfers of funds on a payment account with the user’s payment service                   provider or with another payment service provider, including, execution of direct debits, including one-off direct debits;                         execution of payment transactions through a payment card or a similar device; execution of credit transfers, including                         standing orders;
     -     the execution of payment transactions where the funds are covered by a credit line for a payment service user, including,                   execution of direct debits, including one-off direct debits; execution of payment transactions through a payment card or a                     similar device; (iii)execution of credit transfers, including standing orders;
     -     issuing payment instruments or acquiring payment transactions;
     -     money remittance;
     -     payment initiation services;
     -     account information services.

 

 

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Definition of electronic money
 

Electronic money or e-money is the digital equivalent of cash and can be software or hardware-based. Card-based e-money is commonly stored on a prepaid card, an electronic purse or a wallet. Similarly, it may also be stored in a payment account. The legal framework for electronic money was established by Directive 2000/46/EC. More recently, Electronic Money Directive 2 or EMD2 was adopted to modernise the framework for the issuance of electronic money and enable innovation in doing so.

 

 

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The Irish regulator for Electronic Money Institutions
 

The Central Bank of Ireland regulates firms that provide regulated services, including, payment services, electronic money, lending and investment services.
 

If you wish to issue electronic money services in Ireland, such as prepaid cards or electronic wallets,  you will require an Electronic Money Institution licence from the Irish regulator, namely, the Central Bank of Ireland.

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Advantages of obtaining an Electronic Money Institution (e-money) licence in Ireland

     -     Top 15 most innovative countries in the world. 
     -     1st in the world for investment incentives. 
     -     Low corporation tax rate of 12.5%
     -     1st in the world for flexibility and adaptability for people. 
     -     The best country in Western Europe to invest in.
     -     Top 10 global ranking for education and skills.
     -     2nd most competitive economy in Europe.

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Key features of the Electronic Money Institution (e-money) licence in Ireland

     -     A licence issued in Ireland is recognised in all other EEA (European Economic Area) member states. Through ‘passporting’,               this enables the electronic money institution to operate across all EEA countries with a single licence.
     -     Issue e-money, such as prepaid cards, electronic wallets and payment account with IBAN codes, across Europe.
     -     Join payment schemes such as SEPA.
     -     Issue Visa or Mastercard payment cards for both individual and business users.

 

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The regulations for Electronic Money Institutions in Ireland

The Payment Service Directive 2 or PSD2 for short, is an EU Directive (Directive 2015/2366) that sets requirements for businesses wishing to provide payment services. It applies to banks, building societies, payment institutions, e-money institutions and their customers.
 

The PSD2 directive aims to promote innovation within the payments sector and improve protection for consumers, whilst making payments both safer and more secure. The PSD2 directive came into force on 13 January 2018.
 

The key objectives of the PSD2 directive are to:

     -     Contribute to a more integrated and efficient European payments market 
     -     Improve the level playing field for payment service providers (including new players) 
     -     Make payments safer and more secure 
     -     Protect consumers

 

 

Key requirements to become an Electronic Money Institution in Ireland

     -     A minimum capital requirement of €350,000 to establish an electronic money institution (e-money) licence.
     -     The requirement to safeguard client funds either with a segregated client bank account or with an insurance policy.
     -     The management body of the electronic money institution must be of good repute and possess the relevant qualifications and             experience to perform their duties. 

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Applying to become an Electronic Money Institution in Ireland

As part of an Electronic Money Institution (e-money) licence application, you will be required to provide the following information: 

     -     company identification details  
     -     programme of operations  
     -     business plan and financial forecasts  
     -     a description of your business’s organisation structure  
     -     evidence of your initial capital  
     -     measures to safeguard the funds of your users  
     -     compliance & governance arrangements and internal controls  
     -     procedure for monitoring, handling, and following up on security incidents and security-related customer complaints  
     -     processes for filing, monitoring, tracking and restricting access to sensitive payment data  
     -     business continuity measures  
     -     the principles and definitions applicable to the collection of statistical data on performance, transaction and fraud  
     -     security policy  
     -     internal control mechanisms to comply with obligations in relation to money laundering and terrorist financing (AML/CTF                     obligations)   

     -     details of your qualifying holdings (shareholders)  
     -     details of any outsourcing arrangements

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Choosing the right consulting partner

     1.    Expertise and Specialism in Banking, Payments and E-money
Banking, e-money and payment services are specialist fields, requiring prior expertise, knowledge and a specialist focus. You should ensure that your consultant specialises in this area as opposed to generalising in it. They should be comfortable explaining the technical aspects of this field, such as providing technical and regulatory requirements for licence authorisation. The financial regulator will have conditions and expectations regarding different parts of the application. For example, shareholders and management should be fit & proper, of good repute and have relevant experience and knowledge. A good consultant should be able to advise you on the regulatory requirements early on in order to manage your time effectively and minimise any delays or wrong decisions. It should be your consultant’s role to guide and advise you on best practices and regulatory requirements. For example, we spend time advising clients from an early stage, in fact during the initial meeting and prior to taking on their application, of such requirements so that they can make an informed decision before investing their time.

 

     2.    Ability to access banking products and services
Setting up an e-money, payment or banking fintech goes beyond the scope of obtaining a licence. You will require specialist banking facilities, such as client safeguarding accounts, and access to payment systems, such as SEPA and Swift. Furthermore, you will require systems and software to manage your business. It is therefore vital that your consulting partner has a strong network of connections with banks, technology partners and regulators. For example, by working closely with partners, such as Visa, Mastercard, Wirecard, and central banks, we are able to help clients by arranging banking facilities, such as safeguarding accounts, issuing cards, and access to payment infrastructures, such as SWIFT and SEPA.

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     3.    Communication
Communication between a consultant and their client is extremely important. They should be open to meeting with you if required or to discuss your project during an initial meeting and thereafter have regular conversations with their clients. For example, we have at least a weekly telephone or conference call with our clients to discuss the progress of their licence authorisation application or related project. This helps the client to understand the progress on their application and be able to report key information and developments to their management team or board. At the same time, it enables us to understand how the client is coming along in developing the operational aspect of their business. 

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     4.    International approach
Banking, electronic money and payment services are international in their very nature. As our clients grow internationally their needs change. Firms, therefore, require licences, banking facilities, infrastructure and partners in international markets. We often find firms working with multiple legal, accounting and related firms. This can be challenging for such firms and often slows their international growth. Furthermore, firms then must work with multiple partners within each country to manage different requirements e.g. company formation, accounting, legal, systems & IT, banks, and software vendors. This is further problematic when entering new markets. To manage these problems, our services are offered on an international level with offices strategically located in key jurisdictions across Europe and Asia. Our clients enjoy one point of contact for all their national and international requirements. This helps to remove any language barriers which they would otherwise face. Our services include accounting, legal, administrative and banking, which means that our clients can centralise their requirements with us.

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     5.    Prior authorisation applications experience and success rate
Firms should ensure that their consulting partner has good knowledge and experience in banking, e-money and payment services. They should be able to demonstrate strong knowledge and experience within this area and be comfortable with explaining the legal and regulatory framework concerning banking, payment services, and electronic money. Your consulting partner should be able to share a client reference or provide client testimonials for similar past successful projects. For example, our website provides details of our recent work as well as the names of some of our clients.