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Electronic Money

At Thistle, we offer a full range of regulatory compliance services to electronic money institutions (EMIs).

Electronic money, or e-money, is essentially any monetary value stored in digital form that can be used to transact between two parties. That value can be stored locally on a physical device, like a payment card, or in software form.

An array of regulations now prescribe the activities of institutions. The key regulatory landmarks for EMIs are 2011’s Electronic Money Regulations (EMR), implementing the EU’s second Electronic Money Directive (2EMD), and the Revised Payment Services Directive 2017 (PSD2).

Under EMR, all issuers of electronic money must be registered (small EMIs) or authorised by a nominated authority. Which, in the UK, is the FCA.

PSD2 affects institutions around the transferring of money in and out of a nominated segregated account, which EMIs are then able to transfer to other accounts (payees) under the customer’s (payer’s) instruction.

If you’re moving into e-money provision for the first time, we can guide you seamlessly through the application process for FCA registration or authorisation. If you’re an established EMI, we can assist you with a full range of regulatory support services – including auditing, training, and advisory services. This is particularly pertinent following the changes due in September 2019 deriving from PSD2.

We can also carry out anti-money laundering and know your customer (AML/KYC) risk assessments in accordance with the fourth – and soon to be fifth – money laundering directives, to make sure you’re meeting your regulatory obligations.

On the training front, we offer both face-to-face training and competency sessions, as well as modular online training.

Whatever your regulatory support needs, our specialist team has the experience and expertise to help. We’re always delighted to hear from new electronic money providers. Please get in touch – and we’ll be happy to explain how we can help.

Contact us on 0207 436 0630 or email

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