Flawless Money Limited | A niche consultancy focusing on payments and dealing with the financial regulation of electronic money, money remittance, and other payments.

Authorisations

Flawless Money has managed over 50 applications for regulatory authorisation as an electronic money institution or payment institution in various EU member states.

Our full-service authorisation package can be tailored to support applications in all EU member states and includes:

  • Advice on the appropriate permissions to support service delivery. An analysis of the services provided by the applicant business will be performed to assess which permissions are required and whether any exemptions may be utilised. It may be possible to structure services under different regulatory interpretations, each with consequent implications for the business.
  • Advice on which member states should be considered. A comparison of different member states will be performed to identify suitable jurisdictions for authorisation. Regulatory frameworks, individual approaches taken by local regulators and specific requirements of the applicant business will be considered and the relative advantages and disadvantages presented.
  • Prepare a preliminary ‘Gap Analysis’. A detailed review of the existing and intended business arrangements and resources, considering the required permissions and member state jurisdiction, to determine ‘gaps’ and to provide solutions for their remediation before submission of the application.
  • Develop a project plan and timeline. Considering the findings of the Gap Analysis, and in consultation with the client, the project plan will detail the respective responsibilities in order to deliver the application in accordance with the required timeline.
  • Preparation of the application for authorisation. We will work with the applicant to produce the application package for submission to the relevant regulator, including the requisite forms and operational documents. We are able to support all required areas of an application, in particular: IT Security, legal advice and drafting, AML and regulatory compliance.
  • Preparation of supporting operational documentation. Assistance developing a bespoke suite of documents, as referenced in the application package, and which will be required once the business is authorised. Typically, such documents comprise Compliance Manual, Risk Register, AML Manual and Compliance Monitoring Programme.
  • Assisting with the submission of the application for authorisation and ongoing liaison with the regulator through to conclusion of the project.

The above process can also support variations of permissions for existing authorised entities and will, in both instances, utilise Flawless Money’s full range of expertise that distinguishes us from our competitors.

We are also able to offer practical assistance to facilitate the establishment of the applicant business, including incorporation, legal and recruitment services.