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Electronic Money Institution (EMI)

Electronic Money Institution (EMI)

An electronic money institution is an entity that issues electronic money and provides related payment services. Electronic money is monetary value stored electronically that the issuer is obliged to redeem on demand at any time. Under this model, money is not tied to a specific physical form but exists in virtual form, which allows it to be used for online and offline transactions.

Unlike small-scale electronic money institution, electronic money institutions are not limited by the amount of electronic money they can issue. Within the scope of its licence, it may also provide certain payment services that do not necessarily relate to electronic money and perform other related activities, including the provision of credit.

What can we do for you?

  • We will assess your business model and discuss with you the scope of the licence you should apply for from the CNB as part of the licensing procedure.
  • We will prepare a detailed checklist for the licence application.
  • We will advise you on the appropriate organisational structure and internal management.
  • We will help you prepare a detailed business plan, which is one of the most important parts of the licence application, including financial projections.
  • We will arrange a personal meeting with the CNB to discuss the business plan before submitting the licence application.
  • We will help you establish appropriate rules for calculating capital adequacy.
  • We will advise you on the adequate setup of information and communication (ICT) systems and procedures, including in accordance with the regulations under the new DORA regulation.
  • We will prepare all necessary internal regulations, including AML/CFT guidelines, regulations on the issuance of electronic money, the provision of payment services, risk management, conflicts of interest and outsourcing.
  • We will assess the requirements for persons with qualifying holdings in the client and senior management, including their trustworthiness and expertise.
  • We will prepare the necessary client documentation;
  • We will assist you in preparing all other relevant documents for the licence application, including resumés, affidavits and other declarations.
  • We will assist you in obtaining a draft agreement with a bank for the maintenance of bank accounts on which the funds of electronic money holders will be held, or in obtaining a draft agreement with an insurance company or the necessary insurance.
  • We will ensure that the authorised representatives through whom you will provide payment services are entered in the list maintained by the CNB.
  • We will guide you through the entire licensing process;
  • Throughout the licensing procedure, we will actively communicate with the CNB and, in cooperation with you, ensure that any information and documents requested by the CNB are provided, including participation in any meetings with CNB representatives;
  • We will help you secure the possibility of cross-border provision of your services.
  • After obtaining the licence, we will be happy to assist you in fulfilling your regular reporting obligations to the CNB, ensure compliance and internal audit, assist you in the event of an inspection by the CNB or provide you with any other legal services.

  • inspection by the CNB or provide you with any other legal services.

If you are interested in obtaining an electronic money institution licence, arrange an initial meeting with us, where we will discuss all the steps that need to be taken together to achieve this.

People

Jan Šovar, partner Finreg Partners

Jan Šovar

Partner

Ondřej Mikula, partner Finreg Partners

Ondřej Mikula

Partner

Petra Šimůnková, advokátka Finreg Partners

Petra Šimůnková

Associate

Denis Tichánek, advokátní koncipient Finreg Partners

Denis Tichánek

Associate

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