Opening a payment company for high-risk industries: requirements, compliance

Open a payment company for high-risk industries

High-risk segments such as gambling, cryptocurrency, fintech, brokers, and subscription services require separate payment infrastructure, strictly compliant with AML, KYC, PCI DSS and local regulations.
Open a payment company for high-risk industries It is possible to do so legally if you choose the right jurisdiction, license type, banking partners, and technological architecture.

Jurisprudential Consulting Group prepares the legal, operational and technical structure of payment companies in the EU, UK, UAE, the Caribbean and Central America.

1. High-risk licensing (EMI, PI, MSB, PSP)
2. AML/KYC, anti-fraud, risk control policy
3. Connecting acquiring banks and payment providers
4. Complete turnkey legal infrastructure

Consultation cost from 250 euros

What is a payment company for the high-risk segment?

Payment companies working with high-risk clients provide the following services:

1. payment acceptance (card processing, acquiring);
2. payout infrastructure;
3. exchange, transit or aggregation of funds;
4. multi-currency wallets;
5. Solutions for merchants: API, SDK, white-label gateways.

High-risk means that the company's clients are businesses that require increased control:
iGaming, crypto exchanges, OTC brokers, financial startups, donation platforms, infobusiness, subscription services, aggregators.

What licenses are suitable?

Jurisdiction determines the model, and the choice of license determines the set of permitted operations.

EMI (Electronic Money Institution)

For Europe and UK.
Allows you to issue electronic money, open accounts, and make payments.

PI (Payment Institution)

Working with transactions, merchant accounting, payouts.

PSP/MTO/MSB (Money Services Business)

UAE, Canada, Caribbean region.
Suitable for high-risk projects and flexible structure.

We offer a solution at the level of international standards

Gambling-friendly jurisdictions

Anjouan (Comoros), Costa Rica, Belize - used as payment hubs for iGaming operators.

Jurisdictions that will actually work in 2025

UAE (DMCC, IFZA, Meydan, RAKEZ)

1. high tolerance for high-risk activities, including crypto;
2. Possibility of PSP and MSB licenses;
3. Strict AML procedures are required.

Lithuania (EU)

1. classic EMI/PI license;
2. Suitable for white-label fintech projects working with European banking.

Czech Republic / Poland

1. CASP + payment registrations;
2. flexibility and fast time-to-market.

Belize, Anjouan, Panama

1. operating jurisdictions for gambling and high-risk e-commerce;
2. There are no restrictions on the type of clients, but there are strict AML requirements.

Requirements for opening a payment company

1. Capital

Depends on the license:

1. EMI in the EU - €100,000–350,000;
2. PI — from €20,000;
3. MSB — from $10,000.

2. Substance

Regulators require real presence:

1. office;
2. employees;
3. local director;
4. operational infrastructure.

3. Compliance Officer and AML/KYC Policy

Documents include:

1. AML policy,
2. Risk-based approach,
3. Transaction monitoring,
4. Enhanced Due Diligence.

4. Banking partners

The payment company must open:

1. safeguarding accounts,
2. corporate multi-currency accounts,
3. correspondent accounts for payout networks.

5. IT infrastructure

1. payment gateway,
2. anti-fraud system,
3. API for merchants,
4. reporting, logging, backup.

The process of opening a turnkey payment company

1. Jurisdictional analysis — we select the country and type of license.
2. Formation of corporate structure — founders, directors, substance.
3. Preparing a full compliance package — AML, KYC, internal policies.
4. Company registration.
5. Submitting an application to the regulator (EMI/PI/MSB/PSP).
6. Integration of banks and acquiring partners.
7. Launch of the payment platform: gateway, API, antifraud.
8. Support and continuous monitoring (the regulator requires quarterly reports).

Key risks to consider

1. blocking of bank accounts for non-compliance with AML policies;
2. inability to work with cards if MCC codes are not allowed;
3. the bank may close an account if there is a suspicion of high risk, unless this is provided for by the license;
4. refusal to work with Visa/Mastercard providers;
5. reputational risks due to non-compliance with PSP network requirements.

What does Jurisprudential Consulting Group do?

We support the project from concept to operational launch :

1. analysis of jurisdictions and requirements;
2. company formation and substance requirements fulfillment;
3. preparation of all AML/KYC documents;
4. interaction with regulators;
5. selection of banks, EMI partners, and acquirer networks;
6. payment gateway integration;
7. ongoing legal support.

Сonclusion

Opening a payment company for high-risk industries is legal if:

1. choose the right jurisdiction,
2. ensure substance and compliance,
3. connect available banks and providers,
4. build a technological architecture.

Companies that prepare infrastructure in advance gain a significant competitive advantage.
We'll develop your payment model, prepare the necessary documents, and launch your turnkey project.