There are two types of e-money licences firms can apply for. First, you may apply to become a small e-money or electronic money institution. You can do so only if your outstanding e-money does not success EUR 5m. The registration process is cheaper and more straightforward in comparison to an authorised e-money or electronic money institution, but there are no passporting rights. Small EMIs or electronic money institutions may also provide unrelated payment services I.e. money remittance or payment processing, as long as their average monthly total of payment transactions does not exceed EUR 3m.
Your second option is to become an authorised EMI or formally, an electronic money institution. As an authorised electronic money institution, you will be subject to initial capital requirements (EUR 350k). This means providing audited accounts (where you have been trading long enough) or a bank statement confirming this amount.
As part of your e-money licence application, you will be required to submit a number of documents, policies and procedures, including, a business plan, your safeguarding measures (how you will keep your client money separated and ring-fenced), your governance arrangements and risk management, your procedures for managing and handling security incidents and customer complaints, your security policy and your measures against financial crime, including AML and terrorist financing.
An important part of your e-money application is to ensure you meet the FCA’s basic conditions. These are known as the threshold conditions and are the basic requirements you must have in place before the FCA issues you your licence. For example, you will need to ensure that your ‘mind and management’, in other words, your employees must be located in the UK. You will need to demonstrate through your application that you have appropriate resources to operate your business. This includes having sufficient financial, management, staff, and systems to manage your business. Your team should be suitable and competent for their roles. You will also be expected to have in place a physical office in the UK. This may be a serviced office but virtual or e-offices will not be accepted.
As part of your e-money licence application, you will need to provide details of your IT systems, including both core systems and any support systems. The FCA will expect to see that you have these in place before it issues you your e-money licence.
Buckingham Capital Consulting is a leading international consulting firm, specialising in payment services, electronic money, banking and investment services. We are able to advise you on the best course of action and strategy based upon your business plan and financial product or service. We can help you with licencing, compliance, operational setup and related services, including, obtaining banking facilities.
Call us today on 02078662512 or 442078662512 if you are calling from abroad. You can send an email to firstname.lastname@example.org to arrange a telephone call or to discuss your requirements and plan. We are also able to arrange calls or conference calls using Skype. Our Skype ID is BCC54321. If you wish, we can arrange a meeting at one of our offices.
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