BANKING & PAYMENTS · PAYMENTS & E-MONEY
Electronic Money Institution
Framework
An e-money institution holds client funds without lending them, which makes safeguarding — not capital — the centre of the licence and the first thing an auditor tests. We build the institution around that obligation: safeguarding accounts and reconciliation, payment account and card issuance rails, onboarding and financial crime controls, scheme and BIN arrangements, and regulatory reporting.
THE SPECIFICATION
Architecture & Audience
An EMI issues electronic money and holds client funds without taking deposits or lending. Because it does not lend, it is not subject to bank capital rules — but it must safeguard client funds absolutely, in segregated accounts, reconciled daily, and never used for its own purposes. Safeguarding failures are the most common cause of EMI enforcement, and they are almost always operational rather than deliberate.
Founders building accounts and payments products; platforms embedding financial services into an existing business; and groups seeking a faster route to market than a banking licence permits.
What We Deliver
A complete architecture, designed, launched, and managed
We define the e-money permission scope and select the jurisdiction that fits the institution’s client base, product set, and growth plan. Jurisdiction selection weighs supervisory speed, passporting access, and the safeguarding rules that will govern the business.
We design the safeguarding model — segregated account structure, eligible credit institutions, and the daily reconciliation process — that meets the letter and the spirit of the safeguarding obligation. Safeguarding failures are the most common cause of EMI enforcement.
We select and implement the core ledger and payments platform that holds e-money balances, processes payment instructions, and reconciles positions in real time. The platform is selected for regulatory reporting capability and operational resilience, not only feature count.
We establish access to the payment schemes and rails required for the institution’s product set — domestic instant payment schemes, SWIFT, and card scheme connectivity — through direct membership or sponsorship arrangements negotiated before launch.
We build the onboarding flow and identity verification infrastructure that satisfies the regulator’s customer due diligence requirements. The process converts at a commercial rate without compromising the compliance standard the supervisor will test.
We implement the financial crime controls appropriate to the EMI’s product and client profile: real-time transaction monitoring, sanctions and PEP screening, fraud detection, and a suspicious activity reporting function scaled to the transaction volume.
Where the institution issues cards linked to e-money accounts, we design and integrate the card programme: BIN sponsorship or principal membership, processor selection, scheme compliance, and the dispute and chargeback function that the scheme requires.
We manage the regulatory approval process for the institution’s senior management team and key function holders. Submissions are prepared with the documentation the regulator expects, not filed and left for the supervisor to identify gaps.
We build the reporting infrastructure that delivers the prudential, safeguarding, and conduct returns required by the supervisory authority on schedule. Reporting is automated from the core system and reconciled before submission.
What We Deliver
A complete architecture, designed, launched, and managed
We define the e-money permission scope and select the jurisdiction that fits the institution’s client base, product set, and growth plan. Jurisdiction selection weighs supervisory speed, passporting access, and the safeguarding rules that will govern the business.
We design the safeguarding model — segregated account structure, eligible credit institutions, and the daily reconciliation process — that meets the letter and the spirit of the safeguarding obligation. Safeguarding failures are the most common cause of EMI enforcement.
We select and implement the core ledger and payments platform that holds e-money balances, processes payment instructions, and reconciles positions in real time. The platform is selected for regulatory reporting capability and operational resilience, not only feature count.
We establish access to the payment schemes and rails required for the institution’s product set — domestic instant payment schemes, SWIFT, and card scheme connectivity — through direct membership or sponsorship arrangements negotiated before launch.
We build the onboarding flow and identity verification infrastructure that satisfies the regulator’s customer due diligence requirements. The process converts at a commercial rate without compromising the compliance standard the supervisor will test.
We implement the financial crime controls appropriate to the EMI’s product and client profile: real-time transaction monitoring, sanctions and PEP screening, fraud detection, and a suspicious activity reporting function scaled to the transaction volume.
Where the institution issues cards linked to e-money accounts, we design and integrate the card programme: BIN sponsorship or principal membership, processor selection, scheme compliance, and the dispute and chargeback function that the scheme requires.
We manage the regulatory approval process for the institution’s senior management team and key function holders. Submissions are prepared with the documentation the regulator expects, not filed and left for the supervisor to identify gaps.
We build the reporting infrastructure that delivers the prudential, safeguarding, and conduct returns required by the supervisory authority on schedule. Reporting is automated from the core system and reconciled before submission.
Infrastructure Selection
X-CHASE holds no commercial interest in any provider, assessing them strictly on live performance, structural fit, and renewal terms. Providers are named exclusively under formal engagement, never on a public website.