- Joined
- Dec 2025
- Messages
- 49
JohnnyDoe said:This is only theory, unfortunately.
I think not, but it's a rather small part of the sector. I was involved in the management of an EU PI in the past which has had its license revoked (actually for relatively small issues in the grand scheme of things; I think you well know how regulators can be) and we had a more strict approach to compliance officers that meant they had to leave the customers alone if there were not serious worries.
Serving legit but high-risk clients WITHOUT VC funding and loss operations, WITHOUT background dirty-money operations is possible, though surely not in the monkey messes like Lithuania, Estonia, UK, where so many payment providers have jumped in and trapped themselves. And with time it's getting only harder and harder to operate this way.
JohnnyDoe said:The reality is that the sector is polluted by monkeys, and things happen randomly. Sometimes you can obtain results with bananas, when you don’t care it’s just randomness.
Definitely. Well, who has the money and effort and temperament to deal with regulators that never worked in a private company once in their lives and know AML only from the tellings of people far far away from any practical activity? Simply does not make sense for many people with legit-ish interests to enter the market at all
JohnnyDoe said:Plus, many of these EMIs exist just for reasons only known to their owners. Genuine customers are a nuisance.
Yes, of course, I was trying to insinuate this, often these companies just serve customers from the market at a loss and with overly-careful compliance while the rest of the team is focused on laundering (processing in various ways?) money from alternate sources. But it is a fault of the regulation itself (as is usually the case) because the profitability of legit operations in the EMI space is quite low. Nowadays it has gotten better because safeguarding accounts pay more reasonable interest. Although it has also become more profitable to just structure in Canada MSB/Australia RSP and use EU only as a BaaS.

