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Industry 02

Fintech & Payments

Authorisation, safeguarding, partnerships and ongoing compliance for businesses that move, hold or issue money.

Topics: EMI & PI licensingSafeguardingOpen bankingEmbedded finance

Payment cards with contact chips leaning against a stone block on a deep teal ground.

Who we advise

  • Electronic money and payment institutions
  • PSPs, gateways and payment orchestrators
  • Banking-as-a-service and card programme providers
  • Open banking (AIS / PIS) providers
  • Platforms embedding payments or accounts
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Specialisations

Business models we advise

01Payment Institutions
Authorisation, safeguarding and conduct of business for payment institutions, including agent networks.
02Electronic Money Institutions
E-money licensing, safeguarding, distribution through agents and distributors, and card programmes.
03PSPs & Acquirers
Acquiring, gateway and payment service provider models, scheme rules and merchant onboarding obligations.
04Payment Facilitators
Sub-merchant onboarding, card scheme registration and the regulatory position of the flow of funds.
05Merchant Services
Merchant onboarding, underwriting and monitoring, and the contracts between providers and merchants.
06Embedded Finance
Allocating regulatory responsibility between licensed providers and the brands that distribute their products.
07Payment Platforms
Platforms that collect and pay out funds for others, and the licences and exemptions that apply to them.

Context

The regulatory landscape

Payments and e-money businesses operate under close supervisory attention. Regulators expect robust safeguarding, operational resilience and governance from the first day of authorisation, and banks expect the same before they provide the accounts that make the model work.

We advise payment and e-money institutions, PSPs, BaaS providers and companies embedding financial services into their products — from licence selection and application through to partnerships, outsourcing and supervisory engagement.

Challenges

Where businesses need support

  1. 1.

    Selecting the regime

    Payment institution, e-money institution or an agent model — and in which jurisdiction — for a given product.

  2. 2.

    Safeguarding

    Designing and evidencing safeguarding that satisfies regulators, auditors and partner banks.

  3. 3.

    Operational resilience

    ICT risk management, outsourcing and third-party oversight requirements under frameworks such as DORA.

  4. 4.

    Partner bank relationships

    Securing and keeping safeguarding and operational accounts with credit institutions.

  5. 5.

    Passporting and expansion

    Using EU passporting rights and planning for markets where passporting is not available.

  6. 6.

    Embedded finance allocation

    Allocating regulatory responsibility between licensed providers and the brands distributing their products.

Services

How we help

  • Regulatory & Licensing

    01

    Licence strategy, applications and regulator engagement for gaming, payments, e-money, investment and crypto-asset businesses.

  • Banking & Payments

    03

    Bank account opening, merchant account and acquiring setup, payment flows and safeguarding for businesses banks consider high-risk.

  • AML & Financial Crime Compliance

    04

    AML/CFT programmes, MLRO-as-a-Service, independent AML/CFT audits, risk assessments, monitoring, sanctions and inspection support.

  • Privacy & Data Protection

    05

    Privacy compliance and GDPR programmes, notices and DPAs, DPIAs, data mapping and ROPA, transfers, audits and breach response.

Jurisdictions

Relevant frameworks

Cartography by ROZSUD from Natural Earth data (public domain).

Africa & Indian Ocean1

Insights

Related analysis

Practice note

DORA in practice for payment and e-money institutions

The Digital Operational Resilience Act has applied since January 2025. For smaller payment and e-money institutions, the practical burden sits largely in ICT third-party arrangements.

5 min read

Questions

Frequently asked

Do we need our own licence to offer payments in our product?

Not always. Depending on the flow of funds, an agent or distributor model with a licensed partner, or a specific exemption, may be available. We analyse the flow before recommending an authorisation route.

Discuss your matter with a senior advisor.

Share a few details about your business and plans. We will come back to arrange a confidential initial conversation.

Request a consultation