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Legal Opinions

Reasoned legal opinions on whether and how your model is regulated, which banks, payment providers and investors can rely on before they onboard or invest.

Discuss your matter

Typical deliverables

  • Opinion letter scoped to the recipient's question
  • Statement of facts and assumptions
  • Multi-jurisdiction opinion matrix
  • Supporting regulatory memorandum

A cross-jurisdiction capability, supported across the jurisdictions in our directory. See jurisdictions

Overview

Why it matters

Before a bank, acquirer, payment provider, exchange or investor onboards, lists or invests in a business whose regulatory position is not obvious, it will usually ask for a legal opinion. A well-built opinion answers the question the recipient must resolve, sets out the facts and assumptions it relies on and reaches a clear conclusion, so the review can proceed without avoidable rounds of questions.

We prepare opinions on regulatory status, licensing requirements and the legal characterisation of products and flows of funds, for a counterparty or for your own licence and market decisions. Where an opinion must be given by counsel qualified in a particular jurisdiction, we coordinate that counsel and keep the analysis consistent across every jurisdiction involved.

Scope

What we do

  • Licensing / Regulatory Perimeter Opinions

    Whether an activity requires authorisation, which exemptions apply and where the perimeter sits for the model as it actually operates, before you commit to a licence.

  • Payment / Banking Legal Opinions

    Opinions for banks, acquirers and PSPs on payment flows, safeguarding, agent models and the need for payment or e-money licences.

  • Gaming / Gambling Legal Opinions

    Whether a product is gambling under the applicable law — including skill games, prize mechanics, virtual items and loot boxes — and where it may be offered.

  • Crypto / Digital Assets Legal Opinions

    Token classification, MiCA and VASP perimeter questions, and the opinions exchanges, banks and custodians require.

  • Cross-Border Legal Opinions

    Coordinated opinions covering several jurisdictions, with consistent facts and assumptions and a single point of contact.

Questions

Frequently asked

Who can rely on the opinion?

The addressees and any reliance terms are agreed at the outset. Banks and partners often require an opinion addressed to them, or a reliance letter, so we agree the form with them before drafting. The decision to onboard, list or invest stays with them; the opinion gives them a reasoned conclusion on the agreed facts.

How long does an opinion take?

We agree the scope, the facts to be verified and a timetable before we start, so you can plan around it. Timing depends mainly on the number of jurisdictions and the complexity of the facts.

Related

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

  • Bank account opening, merchant accounts, acquiring, payment flows and safeguarding for international businesses, including gaming, crypto, forex and other high-risk models.

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

All practice areas

Need a legal opinion for a bank, partner or investor?

Tell us who has asked for the opinion and what it must answer. We go through the facts, jurisdictions and addressees, then send a written proposal with scope, timetable and fee.