Trace the movement of funds
We review who receives funds, which entity owes obligations to the customer and how settlement or redemption takes place. This helps identify possible payment-services or e-money issues and distinguish them from the separate treatment of crypto assets. The relevant permissions depend on the actual activity.
- Funds-flow and contractual-role mapping
- Review of account and payment features
- Identification of regulatory and partner dependencies
Review partner and customer arrangements
Banking and payment relationships can shape the viability of a product. We help examine contractual responsibilities for onboarding, refunds, complaints, data sharing and interruptions. A clear agreement should explain what happens when transactions fail or a provider changes its service.
- Payment-provider and distribution agreements
- Customer terms and fee disclosures
- Suspension, termination and transition arrangements
Coordinate the permission strategy
A crypto authorisation should not be assumed to cover a separate regulated payment service. We can help organise the issues requiring assessment and prepare the legal work for the appropriate route. Contact us with a diagram of the proposed flows and details of existing providers or permissions. This allows us to focus advice on the interfaces that could affect launch and ongoing operations.
Your questions, answered
Does MiCA authorisation automatically permit payment services?
No. Payment-services and e-money questions require their own assessment against the activities and applicable legal framework.
Can we rely entirely on a payment partner's licence?
The answer depends on the contractual and operational roles. Your own activities must be examined, even where a licensed provider is involved.
General service information. The scope and provider of professional services are agreed in a separate engagement. Read our regulatory guide.