EMI in Lithuania for a Gulf-based payments group
A MENA payments group entering EU B2B payments, needing a passportable licence ring-fenced from the operating parent.
The brief
A payments group operating across the Gulf wanted EU-passportable e-money capability for B2B flows. The parent carried legacy activity that the group did not want inside a licensed entity, and its ownership chain ran through three jurisdictions.
- The licensed entity had to be clean: no legacy activity, no unrelated intra-group lending.
- Ownership had to be made transparent to the regulator through every layer, including two nominee arrangements that were unwound.
- Safeguarding had to be operational before the first customer, not retrofitted.
- Correspondent banking needed to be in place for the licence to be commercially useful.
The licensed entity is deliberately narrow; everything else the group does sits above or beside it.
- Customer funds
- Held in the safeguarding account and reconciled daily against the e-money issued.
- Revenue
- Fees accrue to the EMI as own funds, kept strictly outside the safeguarded pool.
- Technology
- Licensed down from the group holding company at an arm's-length rate, documented for both the regulator and transfer pricing.
How it was built, in order
- 01Perimeter drawn
Decided in week one what would and would not sit inside the licensed entity, which shaped everything afterwards.
- 02Ownership cleaned
Two nominee arrangements unwound and the full chain evidenced so the qualifying-holding assessment could proceed without repeated queries.
- 03Business plan and model built
Financial model, capital plan and business plan drafted together so they were internally consistent — the most common cause of stalled applications.
- 04Local substance hired
CEO, AML officer and risk lead recruited in Lithuania and named in the application, not promised for later.
- 05Safeguarding designed
Account structure, daily reconciliation procedure and evidence trail built and tested before authorisation.
- 06Correspondent banking in parallel
Two EU clearing relationships pursued alongside the application rather than after it, which is what made the licence usable on grant.
- Lithuanian EMI authorised in eleven months from first filing.
- Correspondent relationships opened with two EU clearing banks before launch.
- Safeguarding reconciliation clean at first supervisory review.
- Ongoing compliance function retained by us for the first year while the internal team was built.
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