Licence strategy, applications and regulator engagement for gaming, payments, e-money, investment and crypto-asset businesses.
Practice area 08
Legal Opinions
Reasoned, clearly scoped legal opinions that banks, payment providers, partners and investors can rely on — on whether and how a business model is regulated.
Discuss your matterTypical deliverables
- Scoped opinion letter
- 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
Banks, acquirers, payment providers, exchanges and investors routinely ask for a legal opinion before they onboard, list or invest in a business whose regulatory position is not obvious. A useful opinion answers the specific question they need answered, sets out the facts and assumptions it relies on, and reaches a clear conclusion.
We prepare opinions on regulatory status, licensing requirements and the legal characterisation of products and flows of funds. 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
- 1.
Regulatory Legal Opinions
Opinions on the regulatory status of a business or activity under the rules of one or more jurisdictions.
- 2.
Business Model Legal Opinions
How a specific business model, product or flow of funds is characterised in law, and what follows from that characterisation.
- 3.
Licensing / Regulatory Perimeter Opinions
Whether an activity requires authorisation, which exemptions apply, and where the perimeter sits for the model as it actually operates.
- 4.
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.
- 5.
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.
- 6.
Crypto / Digital Assets Legal Opinions
Token classification, MiCA and VASP perimeter questions, and the opinions exchanges, banks and custodians require.
- 7.
Cross-Border Legal Opinions
Coordinated opinions covering several jurisdictions, with consistent facts and assumptions and a single point of contact.
Jurisdictions
Supported across jurisdictions
Legal Opinions is one of our cross-jurisdiction capabilities: we support it for businesses across the jurisdictions in our directory. What the law requires, and how the work is delivered, differs between jurisdictions; where local qualification is required, we coordinate locally qualified counsel.
- Europe18
- Asia & Middle East4
- Americas & Caribbean11
- Africa & Indian Ocean6
Industries
Where we apply it
- iGaming & GamingB2C operators, B2B suppliers, platforms, aggregators and affiliates.
- Fintech & PaymentsPayment and e-money institutions, PSPs and acquirers, payment facilitators and embedded finance.
- Crypto & Digital AssetsCASPs and VASPs, exchanges, custodians, wallets, token projects and crypto payments.
- Forex & InvestmentsForex and CFD brokers, investment firms, trading and investment platforms.
- Digital Platforms & MarketplacesOnline marketplaces, platform operators and intermediary business models.
- Technology BusinessesSoftware, SaaS, data-driven and ICT businesses operating across borders.
- High-Risk & Regulated Digital BusinessesBusiness models that banks, payment providers and regulators treat with enhanced scrutiny.
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.
How long does an opinion take?
It depends on the number of jurisdictions and the complexity of the facts. We agree the scope, the facts to be verified and a timetable before we start.
Related
Related practice areas
Bank account opening, merchant account and acquiring setup, payment flows and safeguarding for businesses banks consider high-risk.
AML/CFT programmes, MLRO-as-a-Service, independent AML/CFT audits, risk assessments, monitoring, sanctions and inspection support.
Market prioritisation, regulatory roadmaps and launch readiness for businesses expanding into new jurisdictions.
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.