- We do not want to hide the fact that we are a crypto company in Asia; however, for EU, we understand crypto topics could be sensitive to most banks. Thus, we prefer to simply utilize the fiat transaction in EU (via an EMI license holder). Can you please tell us how we could be flexible in this case?
- There is no crypto-license sponsorship option in the EU, am I right?
- When you said an office is needed, do you mean we have to incorporate first and rent an office, or just a virtual office (same as the license holder’s office) while there is likely no staff (of us) to work there?
- Can you give some examples of additional services not offered by the Principal License Holder?
- It’s mentioned that “the funds will be kept in the custodian accounts with the EMI, which has opened with particular banks”, how are we supposed to withdraw that fund to our bank account?
- Do we have to hire an accounting firm in the license holder’s country?
- Out of the referral fee (€ 28,000) and non-refundable application fee (€ 1,500), what is the monthly or yearly service charge from the license holder?
- Your fee for new US MTL applications is very high. What do you provide in this service?
- Since your company only contacts, arranges, and opens the door to negotiate; is it possible to negotiate with the company willing to work with our company? What happens if an agreement is not reached on the issue of prices or for any other issue? Is the payment for your services reimbursed 100%?
- Would our company be an agent of the sponsor? I’ve read a lot of jargon about the agent relationship; could you please elaborate on this a bit.
- Is a money transmitter license adequate for launching crypto-related services in the US?
- What is cryptocurrency-as-a-service?
- Do I need a license if I resell crypto without holding any money and only charge a commission?
- For the Bitcoin ATM business, are the financial institutions prescreened and verified?
- Is it possible to get the interbank (mid-market rate)?
- What are the solution providers payout rails? How can we find out their commercial terms and delivery times for the pay out countries?
- Can we have a legal company name and then have a separate name (register a “doing business as”)? Is that allowed?
- As a fresh startup, what is the probability of being sponsored by a bank or an exchange company?
- Is there a non-compete clause for the customers that we bring in?
- Can I initiate a transfer without having the money flow through a bank I own?
- What is a list of reasonable payout countries that we can get access to by the solution provider when we are setting up our money transfer business?
- Is there a list of reasonable countries that we will get access to?
- What is the timeline before we can go live?
- Can I write “To be determined” or “To be negotiated” in the Term Sheet Consideration?
- Is handling crypto-currency already included in the pre-built application?
- How long does the leasing period last?
- If I lease a license will it allow us to integrate Mastercard and Visa?
- Is it possible to go live within 6-8 weeks after the initial engagement?
- Does your price quote cover the complete plan of Partnership License acceptance and execution?
- What is the timeline followed by your company after you accept a potential client?
- Are there any restrictions on MSB licenses that we should know about?
- What does it mean to acquire a Money Transmitter License (sponsorship)?
- What is the timeline to pay the referral fee?
- What is the consultation and facilitation fees offered by your company?
- Isn’t the idea of ‘renting’ a license considered wrong? Could it have legal ramifications if we rented a license?
- Are they (the principal license holder) going to hold some money? For example, if they got 100% from the customer, do they hold to the funds or will they release it all?
- What does it mean to sponsor under their license?
- Can I pick and choose a few US states for which we require money transmitter license coverage? If so, how does the pricing work?
- Would the financials be in line with the expectations we have set in the term sheet?
- Before we sign with your company, are there any reference projects we can see to help us make a decision?
- Is there a monthly fee charged by the Principal License Holder?
- Is there any monthly fee if I avail Remittance As A Service?
- What are the next steps once I pay the referral fees?
- How long does it take to sign the contract with the Principal License Holder providing us with regulatory coverage?
- What documents do you need from us before we sign up to be your client?
- Once we are ready to sign and go ahead, how long does it take for the contract to start?
- How many days will the owner of the license take to make a deposit (liquidation of the money) in my clients bank account?
- Who sets the forex rate ? Is it the principal license holder or me as the business owner?
- How much would the service provider charge for a money transmitter license?
- What is the best way to present our use-case to the partner?
- What does it mean to “lease” a license and what services does your company (Faisal Khan & Co) provide for the fee you charge?
- How do BIN Partnerships differ from what MSB will provide us?
- What happens if we decide not to move forward with the agreement?
- How long will the money transmitter license coverage be provided for?
- What is the rate for your services?
- What does it mean to list the MUST HAVE STATES?
- Are you the owner of the license to be rented?
- What are the restrictions on the MSB License that my company will acquire?
- Can we also market in the African corridors we are licensed in and send/receive payments between the African corridors?
- Our model indicates the fact of using crypto transactions in Asia only (not in the EU), and that instead of connecting user to user, we aim to connect merchants (in Asia) to users (in EU) and merchants (in EU) to users (in Asia). Is this model valid?
- Do you have any typical sponsorship agreements drafts that you could share so I can get a better understanding of the potential terms we can expect?
- Can we apply for a Lithuanian license if we are already incorporated in Ireland? That would be our preferred option given that we’ll need to staff operations in whatever country we do get our license.
- Since our company is about to obtain a Labuan Money Brokering license, may I know whether it is sufficient to use this license to apply to be a Registered Agent (RA) under an EMI holder?
- All we need is our CEO, a compliance officer, and an office located in the EU (possible). Am I correct? Are the compliance officer + the office required to be based in the license holder’s country?
- How will the new UK/EU integrations affect our pricing?
- Our understanding was that the UK/EU integrations could be possible in Q4 2021, kindly confirm if this understanding is correct.
- Is Faisal Khan the principal license holder or a sublicensee and solution provider (in the case of US as well as the UK/EU rollout)?
- Have you prepared the pricing for the UK/EU subscription? (including all cost components affecting the unit transaction costs?)
- What is the status of the UK-EU RAAS program rollout?
- Does Faisal Khan offer compliance management? I’m not sure how this works in America, but in the United Kingdom, sometimes the license consulting company is also the Chief Compliance Officer.
- What is the difference between an agent and non-agent of an EMI in Europe/UK?
- Is there an advantage of getting the EMI license in Lithuania vs Ireland?
- With a US sponsored solution provider for Remittance-as-a-Service, would we also be able to use Europe as sending corridors?
- Does the solution provider only allow us to conduct business in the US (as we only seek to conduct business in the US based on domestic clients and domestic transfers)?
- How many locations under the PLH’s license in the USA are we allowed with starter package and Pro packages for sending? Can more be added without upgrading to the next higher package?
- Can we, in due time, transfer to another license in the future (if one day we decide to obtain our own license in the USA)?
- Would we be sub-licensed under the Principle License Holder (PLH)?
- What if the license holder has some problem with the government? Will our funds be frozen?
- We have established a money transfer company in Canada and now we are looking for a bank in the US and want to be its Authorized Delegate in the USA for money transfer services.
- Regarding the US: which states are included? Are TX, CA and NY included as part of the initial package?
- If we do not intend to establish a company in the US, due to the regulations, taxes, etc. Is it possible to continue to operate from Ecuador, with payment and correspondent agreements given that we comply with all regulations in Ecuador?
- In summary, there are 3 ways to enter the remittance market in the US, 1) obtaining your own licenses, 2) through an agreement with a company that has the licenses to operate (this is the way we currently work), and 3) operating a digital platform where the whole process is done by the MSB, and we never touch the funds. Is this correct?
- Montana does not require a money transmitter license, so if I register a company there am I exempt from money transmitter licenses?
- Do Trust Companies provide money transmitter license coverage?
- Our company is currently structured as a Delaware C-corporation. Will this present any issues? Is there a standard entity type a ‘sponsoree’ would be more likely to choose?
- Can we work under a Trust’s Money Transmitter License?
- Do OTC services require a license?
- Can a company registered in Barbados as a licensed MSB operate (send/receive money) from/in Florida?
- Is nationwide US state coverage guaranteed?
- Is a payout partner provided only in the case of a white-labeled offering?
- Is nationwide coverage guaranteed?
- Can we get the US multi-currency accounts without being licensed in the US yet?
- Can we selectively get license coverage for some states in The United States?
- Do you have any list price for regulatory coverage for each US state to help us pick our “Must-have States”?
- Is there a price list for renting each state money transmitter license?
- How can I gain access to regulatory coverage for Canada?
- Is a License Necessary to Start a Money Transfer Business?
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This page was last updated on February 15, 2023.
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