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Insights

Fintech, EMI & compliance industry notes

Commentary on licensing, AML compliance, Swiss SRO affiliation, vendor selection and the wider fintech industry. New posts are added as significant developments happen.

Swiss SRO vs. FINMA licence: how to tell which one you actually need

A practical walkthrough of when SRO affiliation is sufficient and when a business tips into needing a FINMA Fintech or banking licence.

Switzerland

What EMI applicants can learn from recent regulator enforcement action

Why safeguarding and outsourced-agent oversight remain the two areas regulators scrutinise hardest — and what a strong application addresses upfront.

Licensing

UK vs. Lithuania: choosing an EMI jurisdiction after Brexit

A practical comparison of timelines, capital requirements and passporting trade-offs for founders choosing between the two most common EMI routes.

Licensing

Why "EMI licence for sale" listings skip the step that matters

A look at how regulatory change-of-control approval actually works, and why it can't be shortcut regardless of what a broker promises.

Brokering

How to run a KYC/AML vendor RFP that isn't just a features comparison

Scoring criteria that actually predict how a vendor performs under your real transaction volumes and risk profile.

Technical

Why AML documentation drifts from operations — and how to catch it

A recurring pattern across licensed entities: policy documents that were accurate at authorisation but no longer describe how the business actually runs.

Compliance