Sub-Licensed Under Principle License Holder Explained

The question in full

In the US Remittance-as-a-Service (RaaS) model, there is no sub-licensing under the Principal License Holder (PLH). The license remains fully with the PLH, who manages compliance, regulatory obligations, and custody of funds. White-label partners operate without holding a direct license.

Answer

In the United States and under the Remittance-as-a-Service (RaaS) solution, there is no grant of a sub-license. The license is never granted to you. You must understand this very clearly. Your program (i.e. your white-label) service is handled by the PLH (Principal License Holder). Meaning the white-label solution, from a regulatory, compliance, licensing, and custody of funds point of view is handled by the PLH. The PLH has no concern with your brand. That is for you to manage.

Would we be sub-licensed under the Principle License Holder (PLH)?

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