1. SPI (Small Payment Institution) –
UK
Regulator: Financial Conduct Authority (FCA)
Description: An SPI is a type of license under
the UK’s Payment Services Regulations 2017. It's meant for smaller firms
offering limited payment services.
Key Points:
- Maximum monthly payment transactions: €3
million (average over 12 months).
- Can offer services like money remittance,
payment initiation, and account information.
- Lower capital requirements than
Authorised Payment Institutions (APIs).
- Fewer compliance obligations, but cannot
passport services across the EU post-Brexit.
2.
API (Authorised Payment Institution) – UK
Regulator: Financial Conduct Authority (FCA)
Description: This is for larger firms looking to offer payment services on a broader
scale than SPIs.
Key Points:
- No transaction volume cap,
unlike SPIs.
- Must meet higher capital
and safeguarding requirements.
- Can offer services such as:
- Money remittance
- Direct debits
- Credit transfers
- Payment initiation and account
information services
- Post-Brexit, APIs must comply
with local licensing in each EU member state to operate there.
3.
SEMI (Small Electronic Money Institution) Licence – UK
Regulator: Financial Conduct Authority (FCA)
Description: Allows issuing electronic money on a
limited basis.
Key Points:
- Total outstanding e-money cannot
exceed €5 million.
- Must comply with AML regulations
but faces lighter regulatory oversight.
- Cannot passport into other
countries (like a full EMI could pre-Brexit).
- Typically used by early-stage
fintech start-ups.
4.
Money Transfer License – Europe
Regulator: Varies by country, typically central
banks or national financial authorities.
Options:
- Payment Institution
(PI) or E-Money Institution (EMI) license under the EU’s
PSD2 directive.
- Can passport
services be used across the EEA (European Economic Area) if
based in the EU.
Key Points:
- Subject to Anti-Money
Laundering (AML) and Know Your Customer (KYC) requirements.
- Capital requirements vary
based on the services provided.
- Post-Brexit UK-based
entities cannot passport into EU—they need a local EU license.
5.
Money Transfer License – USA
Regulator: State-by-state licensing + Federal
oversight
Description:
- Each U.S. state has its
own Money Transmitter License (MTL) requirements.
- Federal oversight
from FinCEN (Financial Crimes Enforcement Network) for AML
compliance.
Key Points:
- Need a license in every
state where you operate (some states offer exemptions or
reciprocity).
- Costly and time-consuming: must
meet bonding, net worth, compliance,
and reporting standards per state.
- Must register as an MSB
(Money Services Business) with FinCEN.
6.
Money Transfer License – Australia
Regulator: AUSTRAC (Australian Transaction Reports
and Analysis Centre)
Description:
- Money transfer businesses must
register as Remittance Service Providers.
Key Points:
- Must comply
with AML/CTF (Counter-Terrorism Financing) rules.
- No separate “license” like in
the U.S.—registration and ongoing compliance are required.
- Businesses may also need
an AFSL (Australian Financial Services Licence) depending on the
services.
7.
Cryptocurrency Licence – UK
Regulator: Financial Conduct Authority (FCA)
Description:
- Firms that deal in crypto must register with
the FCA under the Money Laundering Regulations (MLRs).
Key Points:
- Covers crypto exchanges, custodian
wallet providers, etc.
- Must meet AML/KYC and fit and
proper standards.
- Not a license to operate as a financial
institution (no passporting, no FSCS protection).
- FCA has been strict, rejecting many
crypto firm applications.
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