
In the dynamic realm of financial fintech in Europe, Electronic Money Institutions (EMIs) stand as pivotal players, redefining how we interact with money. As we embark on a journey through 2023 - 2024, understanding the regulatory landscapes of key jurisdictions becomes paramount. This overview not only dissects the prominent EMI jurisdictions but also unveils the strategic reasoning behind Delos Banking's choice of Greece as a central hub.
Ireland: Fintech Hub of Growth
Ireland's unique ecosystem has cultivated a world-class fintech sector, fostering continuous growth. Renowned for research, development, and innovation, the country provides financial support, including tax incentives and comprehensive government assistance. E-money issuers and payment companies in Ireland enjoy a low corporate income tax rate of 12.5%, comprehensive double tax treaties, and numerous research and development tax incentives. Its high economic and political stability, along with favorable conditions for business activities, makes Ireland an attractive choice. Costs, however, tend to be on the higher side.
Czech Republic: Progressive European Jurisdiction
The Czech Republic emerges as a progressive European jurisdiction, actively promoting the latest technologies in the financial sector. Obtaining an EMI license in the Czech Republic is advantageous due to its favorable conditions for commercial project development, strategic location in the heart of Europe, political and economic stability, lack of bribery and corruption, a loyal taxation system, transparent laws, and a reliable banking infrastructure. The regulations, and process, are quite opaque, which makes the CNB a complex regulator when obtaining an EMI license.
Malta: Tax Privileges and Stable Economy
While Malta doesn't have offshore status in the traditional sense, it offers favorable tax privileges. The benefits include a stable economy with fast growth rates, the opportunity to pay general income tax at a 5% rate, various government programs supporting entrepreneurship, a low VAT rate of 18%, and tax advantages compared to other European countries. However, a prolonged presence of Malta on the FATF grey list, has made obtaining correspondent relationships challenging, in addition to an "overcrowding" of EMI applications in recent month increasing licensure wait times, as Malta is the premier jurisdiction of choice for EMI's moving out of the UK due to Brexit.
United Kingdom: Reliability and Profitability
The United Kingdom's reliability and profitability make it a preferred space for entrepreneurs globally. Political stability, a strategic location, reliable banking structures, tax benefits, government support for business development, and a reputation for supporting innovative businesses contribute to the UK's appeal. However, Brexit has made European correspondent banking relationships challenging, CentroLink access more complicated, as well as the absence of passporting making operating an EMI in the UK more challenging, and reducing market reach of UK EMI's.
Spain: Progressive Support for Entrepreneurship
Spain is open to supporting projects, providing comprehensive backing to the fintech sector. Its highly developed status, strict yet encouraging laws, straightforward company establishment procedures, and the option to apply for residence with a tax-paying operating company make it an attractive jurisdiction for EMI projects. Taxes in Spain, however, are notably high, with very little tax breaks being possible even for Fintech projects.
Lithuania: The Original European Fintech and Crypto Hub
This license enables entities to receive SWIFT payments, open accounts for both private individuals and corporate firms, issue payment cards, and provide a broad spectrum of financial services to international clients. Lithuania has gained a solid reputation as a respectable jurisdiction and the original jurisdiction that paved the way for mass EMI adoption, making it an attractive option for businesses operating in the European fintech landscape. However, it's essential to note that the regulatory landscape is evolving, with increased scrutiny in the industry.
While Lithuania continues to be recognized as a European fintech and crypto hub with a relatively straightforward process for obtaining an EMI license, it is essential to acknowledge the evolving regulatory environment. Recent developments indicate an increased scrutiny and regulatory changes, signaling a crackdown on certain aspects of the fintech sector.
Cyprus: Bridging Continents for Fintech Innovation
Cyprus is actively investing in its digital transformation, establishing advanced telecommunications networks, including 5G, and fostering a business-friendly environment. With a milder recession due to Covid-19 compared to the eurozone average, Cyprus offers a high standard of living, low crime rate, warm climate, political stability, and a friendly business environment. EMI setup in Cyprus provides various advantages, including the ability to operate across all EU jurisdictions under one license, offer SEPA payment services, and tap into Cyprus' strategic location connecting Europe, Asia, and Africa. However with the recent popularity, and several indicators noting considerable regulatory overload, the licensure times on the island have increased to as much as 2 years post-application.
Netherlands: A Hub of Economic Stability
The Netherlands, with its robust regulatory environment, is a prominent player in EMI and PI licenses. The Dutch regulator, De Nederlandsche Bank (DNB), is one of the most active in the EEA, issuing a significant number of licenses. The process of obtaining a Payment or E-money Institution license in the Netherlands is relatively faster than in most European jurisdictions, taking about 6 to 9 months. The Netherlands stands out for its low requirements for a local presence, allowing international teams to operate with only two local directors. Documents for license applications can be submitted in English, simplifying the process, however costs for obtaining a DNB license, tend to be fairly high for start-up EMI's.
Luxembourg: Fintech Advancements in a Global Financial Hub
Luxembourg, renowned for its financial prowess and stable economy, is an attractive destination for fintech businesses seeking EMI and PI licenses. The country's regulatory authorities, under the supervision of the Commission de Surveillance du Secteur Financier (CSSF), have established stringent yet advantageous requirements for license applicants. Holding an EMI license in Luxembourg provides access to the EU, positioning it as an ideal hub for conducting business seamlessly across member states. The stable regulatory environment, global connectivity, and strategic location make Luxembourg a compelling choice for fintech innovation.
Why Greece?
Delos Banking's strategic decision to establish operations in Greece goes beyond regulatory nuances. The Greek regulatory framework governing EMIs, primarily shaped by Law 4021/2011, aligns with the EU’s Electronic Money Directive. This framework emphasizes innovation, consumer protection, and the stability of the monetary system.
The licensing process, overseen by the Bank of Greece, ensures rigorous assessments of organizational structures, internal controls, and compliance procedures. Greece's commitment to consumer protection is evident in its emphasis on transparency, disclosure, and effective dispute resolution mechanisms.
Delos Banking sees Greece not just as a gateway to European markets but as a country fostering a conducive environment for fintech innovation. The skilled workforce, technological infrastructure, and supportive regulatory framework align with Delos Banking's vision of providing cutting-edge financial solutions globally. Greece's commitment to fostering the growth of the digital economy and monetary inclusion resonates with Delos Banking's ethos.
In conclusion, Delos Banking's choice of Greece exemplifies a commitment to regulatory compliance, innovation, and a vision of providing advanced financial solutions on a global scale.
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