E-money

We have been at the forefront of the electronic money regulatory space, advising on innovative legal and regulatory structures that enable businesses to offer services on a pan-European basis.

Our team led the first authorisation of an electronic money institution in both the UK and the EU, prior to the formation of the firm, through our sister consultancy, Flawless Money Limited.

We have since engaged extensively with regulators on a wide range of issues, assisted clients in developing innovative business models, and advised on the interpretation of regulatory provisions affecting products, business practices and operational arrangements.

AML and due diligence

Our lawyers proposed and developed exemptions from anti-money laundering (AML) customer due diligence obligations for low-value e-money payments, and succeeded in securing acceptance of simplified due diligence processes in both UK and EU legislation.

Digital assets and crypto

We continue to engage with regulators on the evolution of the concept of e-money, its regulatory treatment, and the impact of distributed ledger technology, including its application to crypto equivalents of e-money such as fiat-backed stablecoins.

E-money and CBDCs

We advise on e-money in various form factors, whether account-based, token-based, voucher, card or mobile app-based, and we also support clients in understanding the implications of central bank digital currencies (CBDCs) for e-money businesses.