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I misunderstood the Operator-Led model. Can you please explain again?

The question in full

the 'Operator-Led model' is the dominant architecture for independent Money Transfer Operators (MTOs). Unlike the Bank-Led or Agent-Led models where the technology and licenses are controlled by a legacy principal, the Operator-Led model places the fintech company at the center of the ecosystem.

Answer

The operator-led model allows you to go live in a very short period of time, provided the EDD (enhanced due diligence is completed). The anticipated time to go live is between 3-6 weeks. It requires no regulator approval so that is a huge plus. The compliance burden, reporting, etc. are all done by the EMI themselves.

The funds are handled on your behalf by the EMI operator. Meaning if your merchant has an account with you, it would be an account held either under your pooled account or as a separate account, but under an FBO (For Benefit Of) arrangement of your merchant. 

The money handling is done by the EMI or the account holder directly. You are not allowed to touch your merchant’s funds. 

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Faisal KhanAnswered 07/Aug/2026
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Page Last Updated: 07/Aug/2026 (8745030)