Fintech & Licensing (EMI, MSB, VASP)

Lithuania: 3–6 months. Malta: 6–12 months. Ireland: 12–18 months. Netherlands: 9–15 months. Minimum initial capital: EUR 350,000 (full EMI) or EUR 125,000 (PI). Total advisory, legal and regulatory fees for a Lithuanian EMI application typically range from EUR 40,000–80,000 depending on complexity and whether AML framework and MLRO services are included. For FCA or CBI applications, total costs are typically GBP 80,000–150,000+ given the longer process and more demanding requirements. We provide a detailed cost and timeline estimate at the outset.

Yes — all EU EMI and PI licences require genuine local establishment, not a letterbox entity. The Bank of Lithuania requires at minimum a local director, a qualified MLRO, a registered office address and evidence of actual operational presence. MFSA and CBI requirements are more demanding: local management team, compliance function, IT systems and substance commensurate with the scale of the business. VARA requires physical UAE presence. The regulator will assess the genuineness of your local establishment during the review process and as an ongoing licence condition. We assist in identifying qualified local directors, MLROs and compliance personnel.

Only for activities that do not require authorisation in the relevant jurisdiction. You cannot issue electronic money, accept customer funds into payment accounts, execute payment transactions, or operate a crypto exchange without the relevant licence. Operating without authorisation — even during a beta or soft-launch phase — constitutes a criminal offence in most jurisdictions and can result in formal regulatory proceedings that compromise the pending licence application. We advise on what is legally permissible in the pre-licence development and testing phase, including sandbox regimes available in the UK (FCA Regulatory Sandbox), UAE (ADGM RegLab) and Lithuania.

EU EMI: EUR 350,000 initial capital, maintained on an ongoing basis. EU PI (payment initiation, account information): EUR 50,000–125,000 depending on services. VASP requirements vary: UAE VARA categories from AED 200,000; Cayman VASPA registration no minimum capital requirement; Gibraltar DLT licence EUR 100,000. US state MTL requirements vary from USD 10,000 (Vermont) to USD 2,000,000+ (New York). New York BitLicence has no specified minimum capital but requires a surety bond. We provide a jurisdiction-specific capital requirement analysis as part of the regulatory mapping.

MiCA (Markets in Crypto-Assets Regulation, EU Regulation 2023/1114) is the EU's comprehensive regulatory framework for crypto-asset service providers and issuers, fully applicable from December 2024. MiCA creates three asset classes (asset-referenced tokens, e-money tokens, and other crypto-assets) and requires all Crypto-Asset Service Providers (CASPs) operating in the EU to obtain a MiCA authorisation from a national competent authority — passportable across all 27 member states. MiCA replaces fragmented national VASP registration regimes (including the existing French, German and Spanish regimes). Businesses currently operating under transitional provisions must apply for MiCA authorisation by December 2024. We advise on MiCA readiness and manage authorisation applications.

Licensed EMIs, PIs and VASPs face a continuous compliance burden: annual regulatory reporting (financial statements, safeguarding audit, AML effectiveness review), ongoing transaction monitoring, SAR filing with the national financial intelligence unit, periodic regulatory returns (liquidity, capital adequacy, large transaction reports), staff AML training, quarterly MLRO compliance reports to the board, and notification of material changes to the business model, ownership or key personnel. Breach of ongoing licence conditions can result in licence suspension or revocation. We provide a post-licence compliance calendar and ongoing MLRO advisory support for clients requiring it.