SEGREGATED CLIENT FUNDS BANK ACCOUNTS FOR FINTECH’S. PAYMENT AND ELECTRONIC MONEY INSTITUTION AGENT REGISTRATION

Payment Service Providers, Electronic Money Institutions, Cryptocurrency exchange and wallet operators as well as other non-banking Fintech’s usually need the segregated client funds account or correspondent account with the bank or other financial institution to safeguard client (third party) funds and process client payments. Opening of the account for client (third party) funds processing usually is much more complicated comparing to the opening of the account for own funds. Banks deeply investigate internal AML/KYC procedures implemented by Fintech’s and origin of the funds to be processed thorough the account as third party payments.

Payment and Electronic Money Institution (EMI) Intermediary Agent or Distributor Registration

Intermediary Agents and Distributors frequently called PSD or EMD agents can act on behalf of licensed Payment Institution (PI) or Electronic Money Institution (EMI). Agents and distributors ae allowed to have their own client and service them using EU/EEA passportable license of partnering financial institution without any additional licensing. They can provide all payment processing, payment card acquiring and issuing, e-wallet, IBAN account opening, e-merchant payment collection, electronic money issue and any other services licensed PI’s or EMI’s can provide.

Intermediary Agent acts on behalf of a PI or EMI providing payment services.

Distributor acts on behalf of an EMI to distribute and/or redeem electronic money.

Services provided by ECOVIS ProventusLaw:

– Selection of the bank or other finance institution willing to onboard the client in accordance with the client risk profile and business needs.

– Selection of the finance institution according to the currencies (EUR, USD, GBP, etc.) need to be processed.

– Introduction of the client to the bank, payment or electronic money institution.

– Assistance in the preparation of the client internal AML/KYC policies and procedures, other information required by the finance institution.

– Communication with the finance institution and assistance in client authorization process.

– Assistance in getting SWIFT, BIC codes.

– Company registration and business incorporation. Office services.

Kęstutis Kvainauskas

Lawyer, attorney at law, partner of the law firm.

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