Fintech · EMI

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.

11 months to authorisationAnonymised · published with consent

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.
Structure diagram
Group holding, licensed EMI and safeguarding

The licensed entity is deliberately narrow; everything else the group does sits above or beside it.

Owners
Founding shareholders
Qualifying holdings assessed
Two nominee layers unwound so the regulator could see through to individuals.
Group
Group holding company
Platform IP, group staff
Licenses technology to the EMI on arm's-length terms.
Legacy MENA operations
Kept outside
Deliberately excluded from the licensed perimeter.
Licensed
Lithuanian EMI
Bank of Lithuania authorised
Local CEO, AML officer, risk and IT functions resident in Lithuania.
Client money & reach
Safeguarding account
EU credit institution
Daily reconciliation from day one.
Two clearing banks
Correspondent access
EEA passport
Notified host states
How value moves
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

  1. 01
    Perimeter drawn

    Decided in week one what would and would not sit inside the licensed entity, which shaped everything afterwards.

  2. 02
    Ownership cleaned

    Two nominee arrangements unwound and the full chain evidenced so the qualifying-holding assessment could proceed without repeated queries.

  3. 03
    Business 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.

  4. 04
    Local substance hired

    CEO, AML officer and risk lead recruited in Lithuania and named in the application, not promised for later.

  5. 05
    Safeguarding designed

    Account structure, daily reconciliation procedure and evidence trail built and tested before authorisation.

  6. 06
    Correspondent banking in parallel

    Two EU clearing relationships pursued alongside the application rather than after it, which is what made the licence usable on grant.

Outcome
  • 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.