Licensing

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The evolution of the payments landscape has also led to the evolution of licensing requirements for Financial Institutions (FI) both Banks and Non-Banks (NBFIs), as regulators try to match the requirements of this digital age and do their best not to stifle innovation in the financial services industry.

Fintechs, from companies offering web and mobile-based financial services, to pioneering blockchain & cryptocurrency services, are moving licensing forward as they disrupt decades-old structures, partnerships, and relationships, within the growing ecosystem of financial services & products.

Regulations will be always behind the fast evolution of the payments landscape. Some services & products might not be regulated yet, but regulators face the task every day to determine if a company needs licensing based on the products and services they offer and the regulations that are in place. Certain fintechs might decide to experiment without the proper licensing in place. International financial institutions might decide to offer services in certain jurisdictions without analyzing the potential fines they face if regulators determine that they should be licensed.

We at Mohr World, with our Corporate Partners expert advise and their in-depth understanding of the industry, can lead you into a safe path and provide you with the help you need. We can help you with the Application Submission in many jurisdictions for a fast and successful licensing process.

It has been stated many times that US licensing for FIs is a complex process requiring Federal & State guidance in order to make sure that licensing for the services & products that you plan to offer is:

  • needed
  • desirable
  • required

We at Mohr World can discuss with you the options, costs & benefits of licensing as a Money Transmitter in the US. Even if you plan to offer your services to individual customers across the country, which will require licensing in 49 states plus the District of Columbia, US state regulators have been working together, through their own association, the MTRA, to make the process easier for the industry. Seventeen states have developed a protocol, hereby presented in a video interview from Rick St. Onge, Chairman of the MTRA: https://youtu.be/Ofk-o1cBFnk

This process allows the common submission of most of the documentation needed for those initial 17 states with a few other requirements added by some states. This is a leap forward now that the Federal government has been pushed to come up with a Federal License, something that we don’t think it will be achievable anytime soon.

If you plan to offer Corporate Services, then maybe licensing is not required but most banks are demanding licensing of MSBs, even if only in one state, to protect themselves.

Our Corporate Partners in the US can work together with you to provide the best advice and guidance throughout the process, leveraging the multi-disciplinary approach that we have developed, saving you time and money and achieving the coherence and consistency you need to achieve a successful licensing process.

Europe is leading the way in the regulation of financial services and the new Revised Payment Services Directive, PSD2 will surely change the way banks and NBFIs work together with the opening banking rails through Application Program Interfaces (APIs) to NBFIs.

“PSD2 allows bank customers, whether they are businesses or consumers, to use third-party providers to manage their finances. By January 2018, European banks must provide access to customer information (e.g. account balances and details) to AISPs (Account Information Service Providers), introducing another entity to the customer relationship. In addition, banks must expose customer information and payments services to Payment Service Providers (PSPs), dis-intermediating the traditional payments model. Most importantly, banks and financial services institutions may also take on the role of AISPs and PSPs themselves. Thanks to PDS2, in the near future, you might use Facebook, Apple, or perhaps a fintech startup to pay your bills, analyze your spending and create a budget, or transfer money, while still having your money in your current bank account. PSD2 obligates banks to give these third-party providers access to their customers’ accounts through open APIs, allowing third parties to build financial services on top of banks’ data and infrastructure”.  (more info here)

Payment institutions with operations and clients in other parts of the world have seen the importance of establishing themselves in one of the European countries and seek a Payment Institution (PI) license in order to benefit from the single market and the PSD2. Which European country to get licensed in is a decision that cannot be taken lightly. Before Brexit, UK was an obvious choice but today other countries have taken the lead in offering guided paths to licensing and banking rails such as Lithuania to name one of the several choices (Cyprus, Malta, Luxemburg are always mentioned as PI friendly jurisdictions.

We at Mohr World can discuss with you the options, costs & benefits of licensing as a PI in Europe. Our Corporate Partners work together to provide the best advice and guidance throughout the process, leveraging the multi-disciplinary approach that we have developed, saving you time and money and achieving the coherence and consistency you need to achieve a successful licensing process.

Mohr World Consulting Americas was established in Mexico City to provide cross-border payment companies with the help to develop a successful strategy for the Mexican Market.

We can help you determine the need for licensing or set-up the corresponding partnerships in order to grow and expand. We work together with you to provide the best advice and guidance throughout the process, leveraging our multi-disciplinary approach which will save you time and money, achieving the coherence and consistency you need to achieve a successful licensing process in Mexico.

With the new Fintech Law in Mexico that was recently approved by the Mexican Congress, the market is ripe for innovation and expansion into this untapped market where the very few players in place and feeling the increased presence of foreign entities in their own turf.

We make sure the licensing process lays out a clear path and your team develops an in-depth understanding of the regulation, the licensing process and the development of operations. We want to be your partners in Mexico.

Mohr World Consulting has established corporate partnerships in Brazil since 2012 to provide cross-border payment companies with the help to develop a successful strategy for the Brazilian Market.

We can help you determine the need for licensing or set-up the corresponding partnerships in order to grow and expand. We work together with you to provide the best advice and guidance throughout the process, leveraging our multi-disciplinary approach which will save you time and money, achieving the coherence and consistency you need to achieve a successful licensing process in Brasil. We have strong relationships with regulators in Brasilia and have worked with them in the bi-yearly conferences we have developed with IMTC since 2012.

Listen to an interview with Juan Ferreiro from Banco Central (in portuguese) and Hugo Cuevas-Mohr in Basil in 2018

We make sure the licensing process lays out a clear path and your team develop an in-depth understanding of the regulation, the licensing process and the development of operations. We want to be your partners in Brasil.

We have Corporate partners in most of the major cross-border remittance markets, such as Canada, Australia, Singapore, just to name the markets we have been active, providing you with the help to determine the need for licensing or set-up the corresponding partnerships in order to grow and expand. We work together with you to provide the best advice and guidance throughout the process, leveraging our multi-disciplinary approach which will save you time and money, achieving the coherence and consistency you need to achieve a successful licensing process. We make sure the process lays out a clear path and your team develop an in-depth view of the regulation and the licensing process.