- Is an EMI a real bank account?
- No, and this is the critical distinction. An Electronic Money Institution provides an account that can hold electronic money, make payments, and receive funds, often with an IBAN. However, it is not a bank. The money is 'safeguarded' in a segregated account at a partner bank, not protected by national deposit insurance schemes like the FSCS or FDIC. This structural difference is why EMIs have different regulations and risk appetites. For day-to-day payments, it functions like a bank account, but legally and structurally, it is not the same.
- Why do banks and EMIs discriminate against my IBAN?
- This practice is known as IBAN discrimination. While technically illegal within the SEPA zone, it happens frequently. Some counterparties have outdated payroll or payment systems that are hard-coded to only accept domestic IBANs, rejecting foreign ones from EMIs. More often, it is a deliberate risk-management choice. A bank's automated screening systems may flag payments to or from IBANs associated with certain EMIs or jurisdictions (like Lithuania or Malta) for extra scrutiny. They are not declining the IBAN itself, but managing their perceived risk associated with the institution that issued it. This is a practical reality of using EMI accounts.
- Can an EMI legally serve a high-risk industry?
- Yes, this is often their specific purpose. Because EMIs are not banks and do not lend customer money, they are regulated under a different framework (like PSD2 in the EU). This allows them to develop specialised compliance programs for industries that traditional banks will not service due to reputational risk or a lack of understanding. An EMI can build its entire business model around verticals like affiliate marketing, subscription software, or international digital services. However, the EMI must have the specific expertise and willingness to manage the compliance for that industry, and its safeguarding bank must also be comfortable with the arrangement.
- What does 'safeguarding' mean if it's not deposit insurance?
- Safeguarding is a key regulatory requirement for EMIs. It mandates that all client funds must be held completely separate from the EMI's own operational funds, usually in a designated client money account at a large partner bank. If the EMI itself becomes insolvent, those funds are ring-fenced and should be returned to clients, shielded from the EMI's creditors. However, it is not the same as the government-backed deposit insurance you get with a bank (e.g., up to £85,000 via FSCS in the UK). In the unlikely event the large bank holding the safeguarded funds fails, that money could be at risk.
- Why was my account at a major EMI closed so suddenly?
- Mass-market EMIs like Revolut or Wise build their business on rapid, automated onboarding. Initial checks are minimal to reduce friction. This means you can get an account quickly, but the real due diligence happens later via automated transaction monitoring and periodic file reviews. If your business activity, transaction counterparties, or corporate structure triggers a rule in their risk engine, your account is flagged. For them, it's more efficient to close the account than to spend compliance resources understanding your complex business. The sudden closure is a feature, not a bug, of their high-volume, low-touch business model. To get started with a more suitable institution, contact us at xavioncapital.com/start.