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If we don’t hold U.S. MSB coverage across most states or an EU EMI license, which partner company is best to work with to offer a digital wallet or micropayments solution?

Payments
Asked by Question Bot06/Oct/20141 answer

1 Answer

F

Faisal Khan

Answered 06/Oct/2014

This is no easy feat.

In both the cases, either in US or Europe you would need someone with a Money Transmitter Licenses or PI license respectively (more on this later)

You would also most likely need access to banking services. No MSB/PI will provide you access to their banking relationships. Commingling of funds (with other clients) is not allowed, so the MSB/PI will most likely ask you to procure a bank account for yourself and the MSB/PI. This may seem trivial, but the very minute you make the declaration that you are a money transmitter, all bets are off, and most banks will refuse to do business with you.

This is a prevalent issue in many countries (US, UK, Canada, parts of Europe, and now in Australia), etc. --- finding a bank to work with you, is going to be next to impossible.

Coming to the MSB/PI part, you cannot just partner up with a company and obtain (or rent/lease) their licenses. This would not be permitted nor would you get an approval fro the State regulator when you are being on-boarded as an Agent.

The MSB/PI you work with, must fundamentally connect in a very strong sense to your business and business model. The two entities you and the license holder have to be literally inseparable as a business, for the State Regulator to grant you Agent status.

This means, you will have to find an MSB/PI that provides the core functionality of what you are trying to achieve. There isn't a specific company per se you can walk up to - that would indicate the company is open to leasing its licenses for business.

Your best option is to talk and mingle around to find out what names prop up and how to connect with them so that they will listen to your case.

Before this, you must thoroughly work your banking circle to find out a bank that would allow you to manage a bank account with sub-accounts and would provide you with some real-time API and/or service to move money amongst the accounts, etc.