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ExplainerLicensing

When moving money requires a licence

The perimeter question comes before the application question. This explains the distinctions regulators actually draw.

The question regulators ask

Regulators do not ask what your product is called. They ask whether you are carrying on a regulated activity: holding customer funds, transmitting money for other people, issuing e-money, dealing in securities, or providing virtual asset services.

Two businesses with identical marketing can sit on opposite sides of that line depending on where the money legally rests.

The distinctions that decide it

  • Collecting payment for your own goods or services is normally not money transmission
  • Receiving funds and paying third parties usually is
  • Holding balances customers can withdraw normally points to e-money or payment accounts
  • Using a licensed partner's permission can be legitimate, but the terms have to actually cover your activity

Why the sequence matters

Operating a regulated activity without permission is a serious matter, and it is not something a readiness review can fix retroactively. If there is any doubt, the perimeter analysis comes first — before product launch, and before an application.

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