"Most fintech licences fail at the bank, not at the regulator."
ASJ Group sequences banking and acquiring fit before regulator filings — the layer that decides whether an EMI, PSP or VASP licence actually processes revenue.
How we work with fintech & crypto operators.
The regulator is only one of three tables that decide whether a fintech works. The bank is the second — the sponsor bank for safeguarding, the acquirer for cards, the correspondent for payouts. The customer-base regulator is the third — MiCA for EU crypto distribution, FCA for UK payment services, VARA for UAE virtual assets.
ASJ Group sequences all three from day one. A licence that cannot open a sponsor bank account or connect to an acquirer is a certificate on a wall, not a business — and we build against that failure mode explicitly.
We work with founders launching EMI, PSP, VASP, MSB and crypto authorisations, and with established fintechs migrating between regulators post-Brexit or under MiCA.
What we've seen go wrong.
- Filing the licence application before scoping banking and acquirer fit — and then watching the licence be granted with no way to process revenue
- Choosing Lithuania because it looks fast, without modelling Bank of Lithuania's current thematic focus on capital adequacy and MLRO qualifications
- Under-capitalising: EMI regulatory minimum is €350k, but Bank of Lithuania and FCA both require materially more based on forecast volumes
- Assuming a UAE VARA licence gives EU distribution rights (it does not) or that a UK EMI passports into the EU (it does not, post-Brexit)
The shape of the work.
Every engagement is fixed-fee, director-led, and quoted in writing before any work begins.
- 01Regulator, sponsor bank and acquirer fit assessment (2–3 weeks)
- 02Full application build: business plan, forecasts, MLRO manuals, IT and safeguarding frameworks
- 03Filing, regulator Q&A and any pre-application meetings
- 04Post-authorisation: banking, acquirer onboarding, first audit and compliance oversight
Questions we hear from fintech & crypto operators.
- How long does an EMI licence realistically take?
- Twelve to eighteen months in the UK, nine to fifteen months in Lithuania and Malta. Timelines quoted at under nine months are usually filing dates, not authorisation dates.
- Can I run a crypto business from the UAE and serve EU customers?
- Cross-border crypto distribution to EU customers now falls under MiCA. A UAE VARA licence alone does not authorise EU distribution; you need MiCA compliance or a licensed EU distributor.
- Do you provide the MLRO?
- In some jurisdictions we can introduce vetted candidates or, through regulated affiliates, provide the MLRO function directly. In most we help you hire and onboard the right person.
Explore further for fintech & crypto operators
Fintech Licensing
EMI, PSP, VASP, MSB and crypto licences filed with the right regulator.
Crypto & Digital Asset Structuring
Hold and transact crypto through licensed VASPs, foundations and DAO-LLC hybrids.
International Banking
Warm introductions to 25+ active private and corporate banks — UK, EU, GCC, APAC, Caribbean, US.
Every engagement begins with a twenty-minute director-led call. Fixed fees, in writing, before any work begins.