Payment & E-money Institution

Payment Institution and E-Money License for Crypto Payment Services

E-banks and payment gateways are increasing in popularity over the last years. However, Blockchain and cryptocurrency platforms which also serve as a payment gateway for fiat, in the European Union are considered to provide regulated services which require a license. In Cyprus, Payment Institutions and E-money Institutions are legal persons, licensed and supervised by the Cyprus Central Bank under the Payment Services Directive and the E-Money Directive which were incorporated into Cyprus Law. If you mean to establish your payment gateway solution or e-money institution, this is the kind of license that is required. Therefore, a license is required when the payment institution and/or E-money Institution provides exchange services in any Fiat currency as well.

Services provided by a Payment Institution (PI)

A licensed payment institution can provide the following services.

  1. Services enabling cash to be placed on a payments account as well as all the operations required for operating a payment account.
  2. Services enabling cash withdrawals from a payment account as well as all the operations required for operating a payment account.
  3. Execution of payment transactions, including transfers of funds on a payment account with the user’s payment service provider or with another payment service provider:
    a) Execution of direct debits, including one-off direct debits.
    b) Execution of payment transactions through a payment card or a similar device.
    c) Execution of credit transfers, including standing orders.
  4. Execution of payment transactions where the funds are covered by a credit line for a payment service user:
    a) Execution of direct debits, including one-off direct debits.
    b) Execution of payment transactions through a payment card or a similar device.
    c) Execution of credit transfers, including standing orders.
  5. Issuing and/or acquiring of payment instruments.
  6. Money remittance.
  7. Payment initiation services
  8. Account information services

Form Requirements

A company applying for a license to provide any of the above investment services must be incorporated in Cyprus and its head office must be in Cyprus.

Initial Capital Requirements

A company applying for license to provide payment service number 6, must have an initial capital of at least €20.000. A company applying for license to provide payment service number 7, must have initial capital A company applying for license to provide the services numbers 1 to 5, must have an initial capital of at least €125.000.

Services provided by an Electronic Money Institution (EMI)

A company that wishes to issue electronic money will require to apply for an EMI license to the Central Bank of Cyprus. Therefore, with an EMI license, a company shall be able to provide the services provided by licensed PI plus issuing electronic money. Electronic money is defined as a digital equivalent of cash stored on an electronic device or remotely at a server. The scope of the e-money definition excludes prepaid goods/services and a limited network of goods/services subject to an agreement with the issuer. An EMI license is granted only if the applicant company has is incorporated in Cyprus and provides at least part of its e-money services and/or payment services which are not related to the issuing of e-money in Cyprus.

PI & EMI Passporting

The term passporting describes the ability of an institution licensed under Cyprus Central Bank to provide cross-border investment services to clients in the EU Member- States with a simple notification procedure.

Simon Zenios & Co. LLC assists you in obtaining the license from a to z

Our lawyers understand the complexities Blockchain and cryptocurrency platforms are faced with when it comes to regulation and licensing. At Simon Zenios & Co LLC our lawyers have been closely following the developments in this area and have acquired the specialized legal knowledge in order to be able to advise and assist their clients on regulatory and licensing requirements.

Our team of lawyers will be able to advise and assist you throughout the process which will begin with an introductory call with our team of experts, the point of which is for our team to understand your requirements and objectives. Following this, we can then provide you with a quote for our legal services. If the quote is accepted and you decide to engage our legal services, the next step will be for us to collaborate with your team and come up with a detailed legal services plan.

Payment Institutions and E-Money institutions are under prudent supervision by the Cyprus Central Bank. Therefore, companies applying for the relevant license must comply with certain rules and requirements.

We offer all the required Legal Services for licensing including:

Corporate & Accounting Services (Part A)

  • Selection of the appropriate license features and corporate structure.
  • Company name search & application.
  • Company incorporation in compliance with the licensing requirements.
  • Appropriate Memorandum & Articles of Association.
  • First minutes and Resolutions.
  • Cyprus resident nominee directors (individuals)
  • Nominee Shareholder (corporate or individual shareholder).
  • Registered office and arrangements for actual office premises for the Firm.
  • Drafting of corporate documents.
  • Fiduciary Services.
  • Assistance in day to day Governance and Administration.

Preparation of PI or EMI Application to Cyprus Central Bank (Part B)

  • Preparation and submission of the license application with all the accompanying questionnaires and documents.
  • Preparation of group and organizational structure.
  • Preparation and/or review of operations manual and business plan
  • Preparation of Know Your Client procedures and Anti-Money Laundering compliance policies

Accounting and Audit Services (Part C)

  • Tax Registration & Services
  • VAT registration & Services
  • Internal & Statutory Audit Services

For any queries regarding any aspect of Payment Institution and E-Money License for Crypto Payment Services in general, or any other legal matter under the sun, we are always available.