Our
experience

Innovative payments accounts

We provided full-scope legal and regulatory support to a licensed e-money institution including regulatory implementation, and contractual roll-out of a new payment service model based on payment accounts structured on electronic money (e-money).

As part of the project, the client launched two innovative products:

• dedicated IBAN payment sub account.

• sub account with a pool of virtual IBANs (vIBANs).

Both solutions are ideal for marketplaces, payment service providers (PSPs) and cryptocurrency exchanges, offering a streamlined and fully automated way to identify transactions and end customers (both individual and corporate).

We advised on the legal qualification of the new product offering, ensuring compliance with PSD2, EMD2, and MiCA, covering the regulatory treatment of e-money as the underlying asset in payment accounts. We drafted and negotiated the full set of client-facing agreements, including: Payment Account Terms & Conditions, Framework Contracts for E-Money and Payment Services, ensuring regulatory clarity, consumer protection, and risk disclosures.

We supported the client in redesigning its internal risk management framework to reflect the new operational model, including revised risk assessment processes, liquidity management, and safeguarding mechanisms for customer funds. We conducted a comprehensive review and update of the client’s AML/CFT procedures, ensuring they were fit for the expanded service scope and compliant with both local AML laws and EU AML Directives.

We helped the client update its regulatory business programme, providing the necessary documentation for supervisory review, reflecting the new services, operational processes, and risk controls.

Our work enabled the client to successfully expand its licensed activities, providing fully regulated, multi-purpose e-money-based payment accounts to both individual and business customers. The project positioned the client as an innovator in the Polish and EU payment services market, offering a compliant alternative to traditional banking services while leveraging its e-money license.