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Enabling you to gain access to the UK market and offer electronic money, including electronic wallets and prepaid cards

Electronic Money Institution (EMI), United Kingdom

E-money License UK - Electronic Money Institution/ EMI License UK License 

If you wish to obtain an E-money UK License EMI UK License / Electronic Money Institution license in the UK, you will need to apply to the FCA for authorisation as an E-money/EMI Electronic Money Institution. 
 
Below you will find the key information about obtaining an E-money license EMI license/ Electronic Money Institution license in the UK. If you wish to become an E-money license EMI / Electronic Money Institution in the UK, you must meet the FCA's threshold conditions.
 
Buckingham Capital Consulting can help you to become an E-money EMI/ Electronic Money Institution in the UK by offering a full end-to-end service, from company formation to complete E-money EMI/ Electronic Money Institution license preparation and management. 

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List of services you can offer with a UK E-money license / Electronic Money Institution license UK (EMI) License

An E-money EMI / Electronic Money Institution license enables the license holder to offer a number of services:

  1. issuing of electronic money e.g. prepaid cards and electronic wallets.

  2. services enabling cash to be placed on a payment account and all of the operations required for operating a payment account;

  3. services enabling cash withdrawals from a payment account and all of the operations required for operating a payment account;

  4. 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;

  5. 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;

  6. issuing payment instruments or acquiring payment transactions;

  7. money remittance;

  8. payment initiation services;

  9. account information services.

 

Definition of electronic money in the UK

As per Article 2(2) of Directive 2009/110/EC, “e-money” means “electronically, including magnetically, stored monetary value as represented by a claim on the issuer which is issued on receipt of funds for the purpose of making payment transaction, and which is accepted by a natural or legal person other than the electronic money issuer”. Prepaid cards and electronic wallets are examples of electronic money.

 

The UK Regulatory Framework for E-money license UK Electronic Money Institution license UK / EMI License UK Firms

The Financial Conduct Authority in the UK’s regulator for financial services, including, consumer credit, payment services, e-money, lending, insurance and investment services. If you wish to issue electronic money services in the UK you will require an E-money EMI / Electronic Money Institution license from the Financial Conduct Authority.

PSD2, or the Payment Service Directive 2, is an EU Directive (Directive 2015/2366) that sets requirements for businesses that provide E-money and payment services. It applies to banks, payment institutions, electronic money institutions and their customers.

The following laws and regulations are applicable to E-money EMI / Electronic Money Institution firms in the UK:

 

- The Financial Services and Markets Act 2000

- The Payment Service Directive (Directive 2015/2366)

- The Electronic Money Regulations 2011

- Directive 2009/110/EC of the European Parliament

- The Payment Service Regulations 2017

- Payments in Euro (Credit Transfers and Direct Debits) Regulations 2012

- Regulation (EC) No 924/2009

- The SEPA Regulation (Regulation (EU) 260/2012

- The Payment Accounts Regulations 2015

- EU Payment Accounts Directive

- Data Protection Act 2018

- Guide to the UK General Data Protection Regulation (UK GDPR)

- Proceeds of Crime Act 2002 (POCA)

- Terrorism Act 2000

- Money Laundering, Terrorist Financing and Transfer of Funds 2017

- Regulation on interchange fees for card-based payment transactions (EU) 2015/751

- The Money Laundering and Terrorist Financing Regulations 2019

Timeframe to obtain the UK E-money license EMI license / UK Electronic Money Institution license

 

The Financial Conduct Authority is required by the European Banking Authority to assess and make a decision on an E-money EMI / Electronic Money Institution license application within three months of receiving a complete Electronic Money Institution application. In reality, it takes, on average, around 6 months for an application to be assessed and a decision to be made.

 

Initial capital requirement for the UK E-money license EMI license / UK Electronic Money Institution license

 

The initial capital required for an E-money license EMI license / Electronic Money Institution license is €350,000

Ongoing capital requirement for the UK E-money license EMI license / UK Electronic Money Institution license

 

The ongoing capital required for an E-money license EMI license / Electronic Money Institution license is calculated at 2% of the outstanding electronic money a firm has issued.

Reasons for choosing the UK for the E-money license UK Electronic Money Institution license UK / EMI License application

     -     World’s fifth-largest economy

     -     Low corporation tax

     -     Low business costs

     -     Business tax relief of up to 230% on research and development

     -     Access to a highly skilled workforce

     -     Strong fintech growth and investment

     -     Strong reputation in financial services

Key requirements to become a UK E-money EMI / UK Electronic Money Institution firm

  1. A minimum capital requirement of €350,000 is to establish an E-money EMI / Electronic Money Institution business.

  2. The requirement to safeguard client funds either with a segregated client bank account or with an insurance policy.

  3. The management body of the E-money EMI / Electronic Money Institution license must be of good repute and possess the relevant qualifications and experience to perform their duties.

Documents required to apply for the Electronic Money Institution / EMI E-money license in the UK

As part of your E-money EMI / Electronic Money Institution license application, you will be required to provide the following information as part of your application:

  1. company identification details 

  2. programme of operations 

  3. business plan and financial forecasts 

  4. a description of your business’s organisation structure 

  5. evidence of your initial capital 

  6. measures to safeguard funds of your users 

  7. compliance & governance arrangements and internal controls 

  8. procedure for monitoring, handling, and following up on security incidents and security-related customer complaints 

  9. processes for filing, monitoring, tracking and restricting access to sensitive payment data 

  10. business continuity measures 

  11. the principles and definitions applicable to the collection of statistical data on performance, transaction and fraud 

  12. security policy 

  13. internal control mechanisms to comply with obligations in relation to money laundering and terrorist financing (AML/CTF obligations) 

  14. details of your qualifying holdings (shareholders) 

  15. details of any outsourcing arrangements

E-money EMI / Electronic Money Institution UK License application fee

 

The application fee for the E-money EMI / Electronic Money Institution license application is £5,000. The fee is paid when you submit your license application online. The application fee for the Small E-money SEMI / Small Electronic Money Institution is license application is £1,000.

Comparison between the E-money Electronic Money Institution, Small EMI and the API Payment Institution licenses

Choosing the right consulting partner for your UK Electronic Money Institution / EMI UK E-money License application

     1.    Expertise and Specialism in UK E-money EMI / UK Electronic Money Institution license applications

E-money and payment services are a specialist field, 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 license authorisation. The financial regulator will have conditions and expectations regarding different aspects 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 the 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 are able to make an informed decision before investing their time.

 

     2.    Ability to access the right banking products and services for your UK E-money EMI / UK Electronic Money Institution

Setting up an e-money, payment or banking fintech goes beyond the scope of obtaining a license. 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 important 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.

 

     3.    Communication with your UK E-money EMI / Electronic Money Institution UK consultant 

Communication between a consultant and their client is extremely important. They should be open to meet 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 license authorisation application or related project. This helps the client to understand the progress on their application and being 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.

 

     4.    International approach and reach

Banking, electronic money and payment services are international in their very nature. As our clients grow internationally their needs change. Firms, therefore, require licenses, 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 down 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.

 

 

     5.    Prior UK E-money EMI / UK Electronic Money Institution application experience and success rate

Firms should ensure that their consulting partner has good knowledge and experience within 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.

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What our clients say

"Buckingham Capital Consulting has been a reliable and trusted partner. They spent time understanding our business, people and processes and worked closely with us throughout the process. They completed our licensing application to a high standard and in a timely and efficient manner. We were delighted with how smooth the entire process was from the application preparation and submission but also with the case officer at the FCA. Buckingham Capital Consulting ensured that our licence was obtained in an efficient and smooth manner. The value and expertise they provide became obvious early on in the process. We highly recommend Buckingham Capital Consulting."

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