EMI in Lithuania for a Gulf-based payments group
A Middle East payments group moving into business payments in the EU, which needed a licence it could use across Europe, kept separate from its existing parent company.
The situation
A payments group working across the Gulf wanted an e-money licence it could use throughout the EU for business-to-business payments. The parent company had older activities the group didn't want inside a licensed company, and its chain of ownership ran through three countries.
- The licensed company had to be clean: no old activities and no unrelated loans between group companies.
- The regulator had to be able to see who owned every layer, including two nominee arrangements (people holding shares on someone else's behalf) that were undone.
- Safeguarding of customers' money had to work before the first customer, not be added later.
- Accounts with partner banks had to be in place, or the licence would be no use commercially.
The licensed company does one narrow job; everything else the group does sits above or beside it.
- Customer funds
- Held in the safeguarding account and checked every day against the e-money issued.
- Revenue
- Fees belong to the EMI as its own money, kept strictly outside the customers' money.
- Technology
- Licensed from the group holding company at a fair market rate, documented for the regulator and for transfer pricing.
What we did, step by step
- 01Perimeter drawn
Decided in week one what would and wouldn't go inside the licensed company, which shaped everything after.
- 02Ownership cleaned
Undid two nominee arrangements and documented the whole ownership chain, so the regulator's checks on the owners went through without repeated questions.
- 03Business plan and model built
Wrote the financial model, capital plan and business plan together so they matched — mismatches are the most common reason applications stall.
- 04Local substance hired
Recruited the CEO, anti-money-laundering officer and risk lead in Lithuania and named them in the application, rather than promising them for later.
- 05Safeguarding designed
Built and tested the account setup, the daily checking routine and the evidence trail before the licence was granted.
- 06Correspondent banking in parallel
Worked on two EU partner banks at the same time as the application, not after, which is why the licence was usable from the day it was granted.
- Lithuanian EMI licensed eleven months after the first filing.
- Accounts opened with two EU partner banks before launch.
- The daily safeguarding checks passed the regulator's first review cleanly.
- We ran the compliance function for the first year while the group built its own team.
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