Why don't you join forces and start your own EMI

[JustAnotherNomad]

Hate to be the party pooper, but how is this going to work? If you want to be lax with KYC/AML, then you will very quickly become a laundromat and be shut down, probably forfeiting your whole investment.
Because of the capital requirements, you can’t just do this with one or two other people, and I don’t think anyone wants to trust a bunch of random strangers from an internet forum like this.
And if you’re strict, there’s no advantage compared to other EMIs.

 

[andres33]

Hate to be the party pooper, but how is this going to work? If you want to be lax with KYC/AML, then you will very quickly become a laundromat and be shut down, probably forfeiting your whole investment.
Because of the capital requirements, you can’t just do this with one or two other people, and I don’t think anyone wants to trust a bunch of random strangers from an internet forum like this.
And if you’re strict, there’s no advantage compared to other EMIs.

I don't said to be lax with AML/KYC. I said to be flexible inside the posibilities, but remaining in the total legality. If you are a part of your bank it will be diferent for compliance that if you are a new customer that he don't know. If your compliance know you the AML can be more flexible if it remain in the total legality and procedure. No more frozen account. Your compliance will be your alliance and an adviser.
For that I consider to be vigilant with customers and funds origin. Advantage over EMIs is not CRS.
I don't pretend to say that this forum is the ideal place to find partners for this enterprise evidently. But I say that the possibility exist using other way

 

[andres33]

Easy to say when you are not a citizen of Russia
-1 contributor

I know it. But unfortunatelly all complance today take the microscope when a russian custumer appear in the scenario. A transfer coming from Rusia is automaticly stoped before to see what there are behind, etc...
If a bank or emi wnat to be relax, is better to leave these clients to baltics EMIs.

 

[avalanche]

I know it. But unfortunatelly all complance today take the microscope when a russian custumer appear in the scenario. A transfer coming from Rusia is automaticly stoped before to see what there are behind, etc...
If a bank or emi wnat to be relax, is better to leave these clients to baltics EMIs.

To be honest, never had issues with banks due to being Russian so far. As long as you have a solid background, there should be no discrimination. Including swiss banks (which have Russian speaking staff by the way.

Transferwise easily allowed 50k EUR transactions with no problem. I dont know where this phobia is coming from

 

[JustAnotherNomad]

I don't said to be lax with AML/KYC. I said to be flexible inside the posibilities, but remaining in the total legality.

How is that different from what any other EMI would do? They all want your money.
But if they are too lax, bad stuff will happen. You certainly don’t want to have a reputation as a laundromat. I don’t see any way to do this. You can’t have your cake and eat it, too.

 

[Irration4l]

Thank you Martin Everson,

so we have a customer Base and we are looking for a white Label Partner. I know that for example Railsbank in England is doing a good job.

Hey, Paul,

As an alternative to Railsbank as I mentioned you can try and get in touch with Globalnetint. I know they offer some sort of Whitelabel solution as well and have quite a few agents set up already:
https://www.lb.lt/en/sfi-financial-market-participants/globalnetint-uab

 

[Paul Panzer]

Thank you Irritaion4I , i contacted them. I also contacted Pervesk,l but it seems like they would not be interested to sell their product. I was contacted by extremely unprofessional Business Development, so i decided to skip that company. If Business starts already like that, there is more to come to be expected... Seems ike we will have to aquire our own EMI license. This to me seem simpler than to ask other EMIs.

 

[Irration4l]

Thank you Irritaion4I , i contacted them. I also contacted Pervesk,l but it seems like they would not be interested to sell their product. I was contacted by extremely unprofessional Business Development, so i decided to skip that company. If Business starts already like that, there is more to come to be expected... Seems ike we will have to aquire our own EMI license. This to me seem simpler than to ask other EMIs.

Cool, could you give us a broader outlook of what the offers were like, what are the steps and prices involved and what was the unproffesional part from both Pervesk and Globalnetint?

 

[Paul Panzer]

The offers were like that you have to pay more than the price that they offer the accounts, this is as if you buy 10 tons of apples you have to pay more per apple than buying one apple. Globalnetint, i just contacted yesterday. The Pervesk just do not react to clear quesions, lloks like an intern is handling the requests.

 

[Irration4l]

Gotcha. Keep us updated how Globalnetint responds if that is any better.

 

[Praetorian]

From my knowledge Globalnetint and Pervesk have some sort of Whitelabel services available to get an EMI agency.
Their current agents are listed under Intermediaries:
GlobalNetint, UAB
https://www.lb.lt/lt/finansu-rinku-dalyviai/uab-pervesk#item-contra-intermediaries

Pervesk is ran by eastern european mobsters for the most part. Be careful trusting them with any money at all.

Typically, a successful EMI is either 1) Backed by a real bank and has the customer base for it or 2) A laundromat with fake compliance, little controls and mostly dirty money flowing through it, which is a time bomb as its only a matter of time until the regulators decide to knock on their door, think of epayments.

 

[andres33]

Thank you Irritaion4I , i contacted them. I also contacted Pervesk,l but it seems like they would not be interested to sell their product. I was contacted by extremely unprofessional Business Development, so i decided to skip that company. If Business starts already like that, there is more to come to be expected... Seems ike we will have to aquire our own EMI license. This to me seem simpler than to ask other EMIs.

If you are planning to set up an EMI, know that Lithuania is the most interesting country from the point of view of conditions. You should have a budget of approximately € 480K. Of which 350K of capital, + 50K of attorneys' fees with the expenses of incorporation of the company included, + 1200 € of government fees, + 20/40K minimum for IT, + 15K for the business plan, + 8/10K monthly minimum operating expenses. You will find several law firms capable of mounting an EMI with these budgets. Ad provision for the first 2 year running and in 6/9 months you can start the EMI

 

[reesek]

It was like that 2 years ago
Now very hard to get an application approved

If anybody is willing to buy a stake in an operational emi with solid team i can suggest one

 

[Paul Panzer]

Thank you Praetorian (OK, i think we stay out of Lithuania), Andres33 (OK, we have a customer Base ) and reesek (no stakes, we need 100% control - thank you).

 

[FinTech Avenger]

Well, welcome to the world of FinTech dreamers

The idea which was circulated by the TS is bizarre at best from the point of anyone familiar with the world of regulatory compliance, because no EU regulator would approve application for issuance of EMI license if they'd not be comfortable with the source of funds for initial regulatory capital. Collecting proofs of legitimacy of the funds from even 10 people can become a real nightmare, rocketing up legal costs and decreasing chances of success.

Corporate governance would be of a big concern as well. You can't enforce any meaningful risk policy if all the shareholders would be users of EMI services. Regulators don't like captive financial services providers nowadays, as they bring in poor controls and practices.

 

[reesek]

transaction with more than 10% of equity in licensed financial intermediary always triggers regulatory approval which is similar to the process of getting a new license