OK so here is a wild though :
Since most of you need a
bank account, either personal or business, or a
merchant account for your online business, why don't you simply join forces and start your own EMI ?
More than 50 % of the issues here are :
Crypto services looking for a bank account / payment gateways.
International customers looking to access EUR and USD.
Online businesses, regulated or not.
Online gambling and high risk industries.
With a contribution of 1000 Euro per person, you can get your EMI running within 3-6 months, and that money will be credited to your account balance upon formation.
The idea can be interesting if you find people willing to invest a minimum capital of € 100K. per head. A minimum of 30 partners.
Most of the people in this forum and in many other forums are looking for a bank or an EMI that somehow does not share information and that is flexible within some possibilities within a framework of legality that allows them to operate with some flexibility, legal businesses but that many EMIs do not accept.
For this type of approach I do not think that an EMI in Europe is the most interesting since it will be subject to
CRS in 95% of cases. And correspondent banks that are under the criteria of European compliance will not facilitate the work either.
For this type of entity that may interest many, it is best to create an IFE in Puerto Rico. It is the EMI version in offshore but in a territory that does not have CRS.
The OCIF establishes that the training can be done with a deposit capital of $ 300K as a guarantee fund, plus $ 250K of share capital initially disbursed.
The incorporation expenses with ITE , core banking, permits, governement fees, laywer fees, business plan,
company formation, etc., can vary between 150 and 200K. This is the real first expenses
Once the license is obtained the difficult thing comes. To find a correspondent bank. Obviously it is not with a paid-up capital of $ 250k that they will accept to open an account. As a minimum, the company must demonstrate a minimum of $ 2M of capital reserves. If you don't want a correspondant bank and you prefer to be in the FED you will need to wait for 1 or 2 year. And with more complicated process, but you will not need to pay extra comissions to the corresponsal bank.
But it must also be said that this capital and the capital deposited as a guarantee fund are not expenses. They are deposits that can be invested bonds etc.
Operating expenses with a minimum required of 5 local employees, will start from 17K monthly with local, director, compliance, IT specialist, accountant, etc...
The benefits in the first months/year will be negative. And founders should approach this type of setup as a corporate tool for their own needs. Most of the Puerto Rican banks that are set up obtain benefits with high entrance fees and consistent monthly fees as well as commissions on cards, movements, etc. I know 2 banks than they ask 5000$ for entry, and per account
It must be necessary to have in mind that the clientele must be very well chosen and avoid, citizens of Russia, the USA (to avoid
fatca problems), Venezuela,
China, etc ..., that in case they could shoot the red flags of the FED controls.
There are several IFEs that have recently had problems hosting Maduro's money.
From here the topic is feasible. You just have to find 30 partners who contribute with minimum € 100K.
Currently there is a bank that is waiting for a license and raised capital through crowfunding. I mean arival bank.
Another one who is also waiting to receive a license is
zenus
The business niche is mainly found in customers in Europe who want to avoid CRS and who want some flexibility in working within the limits and parameters set by compliance.
People on this forum are generally suspicious, because, let's face it, people on this forum are into some suspicious stuff themselves... and it's generally a human trait to be sceptical 
.
