Luxembourg CSSF Electronic Money Facility (EMI) License Application Registration Guide

In accordance with the Payment Services Act(PSL), EMI authorized to issue electronic money, And can provide a wide range of payment services and payment account operations. PI is limited to providing payment services, No authority to issue electronic money. The statutory minimum paid-in capital of the two is respectively 35 million euros (EMI) and 2 Wanzhi 12.5 million euros (PI).

EMI intends to provide cross-border services in other EEA countries, When operating as an agent or branch, Applicable notification procedures must be followed to the CSSF, and comply with relevant host country rules. The passport mechanism does not cover markets outside the EEA such as the UK, It does not constitute an unconditional business guarantee.

EMI initial capital must not be less than 350,000 euros, and must prove capital composition, Source and availability at the time of authorization. What can be included in capital projects and investment certificates are determined according to legal and CSSF case requirements.; "Local bank freeze" or all shareholder borrowing situations should not be written as a uniform statutory prohibition.

EMI must continue to meet its own capital requirements that are at least no less than the statutory initial capital., And calculated based on the average outstanding electronic money and incidental payment services using the applicable method; CSSF can be adjusted according to law. The final amount must be calculated based on business data and capitalized items.

Electronic money is not a deposit. Relevant client funds must be safeguarded in accordance with applicable rules, Not allowed to be mixed with the institution’s own funds; Segregation or qualifying insurance/bondage available. Account, assets, Reconciliation frequency and difference processing must be confirmed according to the specific guarantee plan.

The registered office and central administration shall be located in Luxembourg, and have local decisions that are commensurate with the business, personnel, Location and control capabilities. CSSF will be based on business, Systems and Outsourcing Review Substance, This page does not use the "at least 5 employees" threshold that has no official basis..

Applicants must configure AML/CFT management responsibilities and control functions in accordance with Luxembourg law and CSSF requirements, Ensure personnel have experience commensurate with responsibilities, Permissions, independence and resources. permanent, Language, Years of experience and scope of outsourcing must be confirmed based on responsibilities and cases.

Foreign shareholders are not necessarily prohibited, But shareholders, chain of control, COUGH, Financial soundness and sources of funds and wealth will be reviewed. Whether 100% overseas holding can be adopted must also be combined with qualified shareholdings., Group supervision and other applicable legal judgments.

Protected client funds may not be used for group financing or institutional operations. Institution’s own funds, Distributable profits and group transactions are subject to capital, company law, Related party transactions, Governance and regulatory requirements; All legitimate capital flows cannot be summarized with the exception of “dividends only”.

ICT services may use onshore or offshore suppliers subject to DORA and other outsourcing rules. Organizations must retain ultimate responsibility, risk assessment, Contract and Audit Access, Incident and continuity management, Subcontracting and exit arrangements; Test scope and frequency determined by risk and statutory classification.

CSSF will conduct a completeness and substantive review, You can also request supplementary documents or management explanations.. The total period depends on the scope, Material, personnel, systems, Third Party Arrangements and Inquiries; There is no official basis for this page to promise unification for 4 to 12 months, Authorization decisions are made in accordance with Luxembourg legal procedures.

Authorized institutions must continue to fulfill financial, Capital, client-funds safeguarding, AML/CFT, audit, Obligation to report statistics and major changes. specific form, frequency, Duration and audit scope depend on current rules, Institutional Category and CSSF Requirements, Submissions should be checked item by item through the CSSF declaration calendar and notifications.

CSSF分别处理支付机构, 电子货币机构及账户信息服务等路径, 业务和资金风险不同. 只提供账户信息的登记不能用来发行电子货币.

Can refer to卢森堡 EMI 电子货币牌照主管机关的监管及申请资料, Check corresponding systems and processing information.

Submitting an application or obtaining a principled opinion does not mean that you are officially allowed to operate.. Final authorization should be confirmed first, Licensing conditions and prerequisites for starting business; Technical testing should be distinguished from real client funds and regulated transactions.

Cannot be regarded as the same approval. Regulatory authority assessment business authorization; Banks independently review customers, Source of funds and purpose of account. Obtaining a license or in-principle approval does not guarantee account opening, Clearing access and ongoing account services.

New products first, Customer Category, A case-by-case comparison of capital flows and operating areas with existing registrations or authorizations. If it exceeds the scope or affects the applicable conditions, Corresponding changes should be completed, It will be launched after notification or separate application..

Compare legal names, Registration or license number, Authorized business, Licensing conditions and actual website. Group brand, The identity of affiliated companies and agents cannot replace the authorization of the contracting entity., Should be cross-checked with official records and licensing documents.

Both may change the control relationship. Direct and indirect shareholdings should be identified before trading, Significant impact and changes in ultimate controller, Check approval or notification procedures, and write regulatory conditions into the delivery arrangements.

First check whether the license conditions are still met, Arrange temporary supervision, Business restrictions and handovers, and complete applicable personnel notifications or new hire approvals. Nominal substitutes cannot solve gaps in actual performance of duties.

It is recommended to record complaints, Products and people involved, Processing time limit, Evidence and conclusion, and inform customers of applicable upgrade channels.. Processes should be rectified when systemic problems are discovered, Instead of just closing a single ticket.