01
🇱🇹
Lithuania.
Bank of Lithuania
- Regulatory framework
- PSD2 (Law on Payments) · EMD2 (Law on Electronic Money and Electronic Money Institutions)
- Authorisations covered
- EMI · PI
A dense Lithuanian EMI sector hosts many merchant-acquiring and e-money issuance operations. Common patterns include extended rolling reserves, pre-termination security account transfers, and contested chargeback assessments. The Bank of Lithuania operates an established complaints framework and engages substantively with documented merchant complaints.
02
🇮🇪
Ireland.
Central Bank of Ireland (CBI)
- Regulatory framework
- European Union (Payment Services) Regulations 2018 · European Communities (Electronic Money) Regulations 2011
- Authorisations covered
- PI · EMI · credit institution
Ireland hosts a number of large-scale EMI and payment platform operations passporting throughout the EEA. Files typically present significant scheme passthrough volumes, complex documentary chains, and a sophisticated counterparty legal function.
03
🇲🇹
Malta.
Malta Financial Services Authority (MFSA)
- Regulatory framework
- Financial Institutions Act · Banking Act
- Authorisations covered
- Financial institution licence (FIA) covering payment services and e-money
A sector with strong activity in card acquiring, alternative payment methods, and gaming-adjacent merchant categories. Files often present elevated rolling reserves, contested VIRP/scheme programme assessments, and undocumented internal adjustment lines.
04
🇨🇾
Cyprus.
Central Bank of Cyprus (CBC)
- Regulatory framework
- Payment Services and Access to Payment Systems Law · Electronic Money Law
- Authorisations covered
- PI · EMI · credit institution
Cyprus authorises a meaningful EMI and payment institution population, with frequent multi-merchant programmes. Recurring features include long-duration fund retention beyond contractual release windows and phantom contractual provisions cited in assessment letters.
05
🇬🇧
United Kingdom.
Financial Conduct Authority (FCA)
- Regulatory framework
- Payment Services Regulations 2017 · Electronic Money Regulations 2011
- Authorisations covered
- API · EMI · authorised credit institution
The UK regulatory regime is well-established and the FCA operates a mature complaints and supervisory engagement framework. Counsel of record is selected from the panel of senior commercial litigators with prior PSP-side or merchant-side engagement.
Outside this footprint
Counterparties authorised in other EU Member States, the EEA, or other comparable regulatory regimes are considered on a case-by-case basis. Where the structural facts are sufficiently strong, the firm will engage counsel of record in the relevant jurisdiction.
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