LG 223

Deloge, Deputy Head of the Innovation,
Payments, Market Infrastructures and
Governance Department at the CSSF.
Business as usual?
While some companies call it contingency
planning, developing a new EU strategy,
or relocating as a result of Brexit,
Luxembourg’s role as a European payment
hub has certainly been reinforced since the
UK’s vote to leave the EU. A number of
major Payments institutions and Electronic
Money Institutions have chosen to establish
operations in Luxembourg, or reinforce
their existing setups in the Grand Duchy, in
order to continue to serve the EU market
from a strategic location in the heart of
Europe.
The fact that a payment company already
has an FCA approval does not necessarily
facilitate the application for an E-money or
Payment Institutions license elsewhere, nor
the supervisory work of the regulator, but it
makes life easier for the entity itself as they
understand the general application file and
required documentation.
“We do not have a fast-track procedure for
Brexit-based applications. All application
files are reviewed the same way. But having
gone through the FCA process may be an
advantage for the entity applying: we notice
that those that have already been through
an application process previously generally
have application files that are better
prepared because they have experience in
the type of information that is required”,
explains O’Sullivan.
One of the main areas a EMI or PI
application file covers are the organisational
requirements of a payment license to
ensure that it is compliant with regulatory
requirements and aff¬ords appropriate
consumer protection thereby making it
Karen O’Sullivan and Natasha Deloge
“We have
experience
with small startups
and big players,
so we are not
afraid of what lies
ahead of us”