What is a Small Electronic Money Institution (SEMI)?

A SEMI is a regulated entity that issues electronic money but operates under lower thresholds than larger electronic money institutions, often subject to simpler or scaled regulatory obligations.

What licensing or authorisation is required for SEMIs?

SEMI licensing typically involves meeting criteria around governance, capital, AML/CTF/KYC policies, risk assessment, customer protection, and regulatory filings as per electronic money regulations.

How do AML/CTF obligations apply to SEMIs?

Even as a SEMI, you are required to have AML/CTF policies and procedures, risk-based customer due diligence, transaction monitoring, suspicious activity reporting and record keeping, consistent with regulatory requirements.

Do you help with regulatory reporting for SEMIs?

Yes. We assist SEMIs in preparing and submitting regulatory reports, ensuring accuracy and timeliness, and tracking changes in reporting requirements.

What operational controls are needed for SEMI compliance?

Operational controls typically include internal governance, oversight, customer-fund safeguarding (if applicable), transaction monitoring, data protection, audit trails, and policies that ensure compliance.

Is ongoing compliance support important for SEMIs?

Yes. Regulations evolve, risk environments change, and ongoing support helps SEMIs keep their policies, procedures, staff training and operations aligned with legal and regulatory expectations.

SEMI Compliance Solutions | Small Electronic Money Institutions

Overview

Small Electronic Money Institutions (SEMIs) are firms authorized to issue electronic money and provide certain payment services, but within prescribed limits. Under FCA regulations, SEMIs may handle up to €5 million in outstanding e-money and facilitate an average monthly transaction volume not exceeding €3 million. While SEMIs benefit from lighter prudential requirements compared to Authorised EMIs (AEMIs), they must still operate within a strong compliance culture, demonstrating adequate safeguarding of customer funds, adherence to AML/CFT standards, transparent governance, and sound risk management practices.

For startups, SEMI status offers a strategic entry point into the payments and e-money ecosystem, allowing them to test and scale business models before transitioning into full authorisation. However, obtaining and maintaining SEMI status requires careful planning, accurate documentation, and a robust operational framework to align with FCA expectations.

ABM supports clients throughout this journey—covering licensing applications, governance design, policy development, risk assessment, and operational readiness. Our role is to ensure SEMIs are not only compliant but also equipped for sustainable growth in an evolving regulatory environment.

We provide services for SEMIs:

Business Model Development
FCA Authorisation – Application Drafting & Submission
Ongoing Compliance Support
Regulatory Reporting & Filing
Specialized Training
Audit & Assurance Services