Video Briefing

Offshore Citizen: Can you trust Electronic Money Institutions / EMIs

Feb 24, 2020Video Briefing6:58Watch on YouTube

Electronic Money Institutions (EMIs) sit between traditional banks and fintech services, issuing electronic money without actually holding deposits themselves. Because they rely on a sponsoring bank and a regulatory licence, assessing their safety requires looking beyond the surface brand.

How EMIs work

  • An EMI issues a digital representation of fiat currency (e.g., a “e‑wallet”) that can be used for payments and transfers.
  • The underlying cash is kept in a separate, usually traditional, bank account held by a sponsoring bank.
  • The EMI itself is granted a licence by a national regulator (often under EU directives) but does not enjoy the same deposit‑insurance protections as a full‑service bank.

Key risk factors

Factor What to check Why it matters
Sponsoring bank Identify the bank that holds the underlying cash. If the bank fails, the EMI’s assets may be frozen, adding a second layer of risk.
Regulatory jurisdiction Note where the EMI is licensed (e.g., EU, UK, other EU‑like regimes). Some jurisdictions issue licences cheaply and may apply lighter due‑diligence standards.
Capital backing Look for venture‑capital or institutional investors (e.g., Wise, Revolut). Strong backers usually mean larger budgets, higher compliance standards, and reputational safeguards.
Licensing cost & depth Cheap licences can indicate minimal oversight. Low‑cost licences often correlate with weaker consumer protections.
Operational track record How long has the EMI been operating? Any regulatory actions? A longer, clean history reduces uncertainty.

When EMIs are a reasonable choice

  • Limited banking alternatives – Offshore entities (e.g., Belize, Seychelles) often cannot open accounts with traditional banks. EMIs may be the only viable gateway for payments and cash management.
  • Crypto‑friendly services – Some EMIs accept cryptocurrency deposits or facilitate crypto‑related transactions where conventional banks refuse.
  • Small‑scale cash needs – For modest amounts (e.g., personal travel funds, low‑value business expenses) an EMI can be convenient and cost‑effective.

Practical advice

  1. Assess your alternatives first

    • If you can obtain a traditional bank account (e.g., HSBC Hong Kong, DBS Singapore, Barclays), prefer that route.
    • Use an EMI only when other options are unavailable or impractical.
  2. Evaluate the EMI’s backing

    • Prefer EMIs with well‑known investors and sizable market caps (e.g., Wise, Revolut).
    • Be cautious of providers based in jurisdictions known for “cheap licences” or where regulatory oversight is minimal.
  3. Limit exposure

    • Avoid storing large sums (e.g., millions of dollars) in any EMI, regardless of its reputation.
    • For substantial balances, move funds to a brokerage or a traditional bank as soon as possible.
  4. Use brokerage accounts as a safety net

    • Brokerage platforms often allow quick, first‑party transfers from an EMI, letting you place assets in a more secure environment.
    • This approach reduces the time your money spends in a potentially higher‑risk EMI.
  5. Monitor regulatory news

    • Stay alert to any enforcement actions or licence revocations affecting your EMI.
    • Changes in the sponsoring bank’s status can directly impact your access to funds.

Decision checklist for choosing an EMI

  • Do I have other banking options?

    • Yes → Choose a traditional bank.
    • No → Continue to the next step.
  • Where is the EMI licensed?

    • Strong jurisdiction (EU, UK with robust oversight) → Proceed.
    • Low‑cost licence jurisdiction → Require deeper due‑diligence.
  • Who funds the EMI?

    • Reputable venture capital or institutional investors → Higher confidence.
    • Unknown or opaque backers → Higher risk.
  • What is the sponsoring bank’s health?

    • Established, well‑capitalized bank → Lower risk.
    • Small or financially unstable bank → Higher risk.
  • Can I limit the amount kept in the EMI?

    • Yes → Use EMI for short‑term needs.
    • No → Seek alternative banking solutions.

Bottom line

EMIs can fill a niche when conventional banking is unavailable, especially for offshore companies or crypto‑related transactions. Their safety hinges on the strength of their sponsors, the rigor of their licensing jurisdiction, and the depth of their capital backing. Treat them as a temporary conduit rather than a long‑term repository for large sums, and always have a plan to move funds into more secure accounts when possible.