The business behind the form
A payment or e-money application is more than a set of forms. The supervisor reads it to understand whether the business can operate safely from the first transaction.
Areas that receive the most attention
- Governance and key persons — who is accountable, and whether they are fit and proper.
- Financial position — capital, projections and how the business is funded through its early years.
- Customer funds — how money is safeguarded, reconciled and kept separate.
- IT risk and resilience — security, incident response, continuity and outsourcing oversight.
- AML/CFT and fraud — customer due diligence, monitoring and reporting.
- Customer treatment — fees, disclosures and complaint handling.
Consistency is the common thread
The business plan, the policies and the system design must describe the same business. Most follow-up questions come from places where they do not.
A practical first step
Map your money flows end to end — who pays, who holds, who settles. The licence type and most of the control design follow from that map.