Acquisition of shares in an electronic money institution
We advised a polish comapny on obtaining Bank of Lithuania approval for the acquisition of 100% of the shares in a licensed Electronic Money Institution (EMI). Our work focused on the preparation of a comprehensive change of control application package, including ultimate beneficial ownership, financial standing, business plan impact, source of funds, and fit and proper assessments for management and key function holders. We also coordinated all regulator Q&A and ensured the submission met the highest supervisory standards.
In parallel, we conducted a thorough review and update of the target company’s internal corporate and regulatory documentation to align with post acquisition expectations. This included revising governance arrangements, AML/CFT frameworks, safeguarding mechanisms for client funds, ICT/outsourcing policies, and compliance procedures under PSD2, EMD2 and MiCA.
The documentation included thet the trgeted EMI will a broad range of payment products, including:
- E- money tokens issuance, copliant with MICA regulation
- Multi currency payment accounts allowing individual and business customers to receive deposits, withdraw cash, and perform full financial management operations;
- Payment card issuance services enabling cashless transactions in stores, online purchases and ATM cash withdrawals;
- BLIK code issuance services and BLIK payment acceptance services
- SEPA and Elixir payment handling services
By ensuring that both the regulatory application and the company’s internal documentation were fully aligned with supervisory requirements, we secured Bank of Lithuania approval within the expected timeframe. This allowed the client to close the transaction successfully and strengthen the target’s compliance posture, supporting further product development and growth across the EEA.
See also:
We are advising a Lithuanian-licensed Electronic Money Institution, on the design and full regulatory implementation of its euro denominated Electronic Money Token (EURM) in compliance with EU Markets in Crypto Assets Regulation (MiCA).
We advised a licensed Polish e-money institution, on a strategic, cross-border initiative involving the regulatory structuring, operational planning, and legal implementation of MiCA-compliant Electronic Money Tokens (EMTs) intended for issuance and trading across Asia.