What is business model development for a SEMI?

It involves defining your services, revenue streams, cost structure, compliance obligations, operational design and risk governance to build a sustainable SEMI-based business.

How does regulation affect SEMI business models?

Regulations impact licensing requirements, AML/CTF and KYC obligations, capital or financial thresholds, consumer protection, reporting and ongoing operational compliance, all of which shape cost and design of your business model.

What should be included in revenue and cost planning?

Key elements include projected transaction volumes, fees, costs for staff, technology, compliance, regulatory fees, risk management, infrastructure, overheads, and financial buffers for unexpected regulatory demands.

Why is operational infrastructure important for SEMI?

Because even with smaller scale, you need robust systems for compliance (AML, KYC), transactions, data, security, record keeping and oversight. Weak operations can lead to regulatory non-compliance or risk.

How are risk governance and compliance integrated?

Risk governance means setting up oversight, policies, accountability, monitoring of risk exposures, compliance checks and ensuring that business decisions consider regulatory and operational risks from the outset.

What deliverables can I expect from this service?

Typically, a business plan, financial model, regulatory constraint mapping, operational roadmap, risk governance framework and recommendations for infrastructure and compliance design.

How long does business model development take for SEMI?

It depends on complexity — scale of operations, number of services, regulatory environment, and readiness of internal resources. Could take a few weeks to a few months.

SEMI Business Model Development | Regulatory & Financial Viability

Business Model Development

ABM provides an end-to-end structured framework for building a sustainable and FCA-compliant business model for SEMIs. Our approach ensures that every aspect of the institution’s setup is aligned with both regulatory expectations and long-term commercial objectives. From defining the scope of services to designing governance, safeguarding, and risk frameworks, we cover the entire lifecycle of SEMI establishment and growth, ensuring operational resilience and regulatory sustainability.

Defining Scope of Services

The first step in developing a SEMI business model is to clearly define the scope of services that the institution will provide. ABM assists in identifying which services fall within SEMI permissions, such as issuing e-money, remittances, card issuance, and payment processing. At the same time, we carefully map out the restrictions and limitations that apply under SEMI thresholds to avoid regulatory breaches. This ensures the business model operates within the FCA’s regulatory boundaries while maximizing commercial opportunities.

Customer Journey & Onboarding Framework

Customer onboarding is a critical component of any SEMI business. ABM designs seamless customer journeys that integrate KYC and AML checks, digital identity verification, and ongoing customer due diligence. We ensure that onboarding processes strike the right balance between compliance and user experience, minimizing friction for customers while meeting the FCA’s stringent AML and financial crime prevention requirements. This includes embedding processes for ongoing monitoring of customer activities, which supports both operational efficiency and regulatory compliance.

Safeguarding Structure

Protecting customer funds is at the core of FCA supervision for e-money firms. ABM helps SEMIs establish robust safeguarding structures by setting up designated safeguarding accounts and implementing daily reconciliations to ensure client funds are always segregated from operational money. We draft clear safeguarding procedures that align with FCA rules, giving customers assurance that their money is secure and instilling trust in the institution. These mechanisms not only protect clients but also demonstrate compliance with regulatory obligations during audits or supervisory reviews.

Governance & Organisational Structure

Strong governance is a cornerstone of any SEMI business. ABM supports in defining clear roles and responsibilities for directors, senior management, and key function holders, ensuring accountability across the organization. We also establish governance frameworks such as board oversight, compliance and risk committees, and internal reporting lines. These structures are tailored to reflect FCA expectations, providing assurance that the firm operates with transparency, integrity, and proper oversight.

Risk & Compliance Framework

Compliance with AML/CFT regulations is essential to protecting both the SEMI and the wider financial system. ABM develops tailored AML/CFT and financial crime prevention frameworks based on the SEMI’s risk profile. This includes transaction monitoring systems, suspicious activity reporting procedures, compliance testing, and ongoing training for staff. We ensure the SEMI has a robust second line of defense in place to detect, report, and mitigate risks of money laundering, terrorist financing, and other financial crimes, keeping the firm in line with FCA requirements.

Capital & Financial Planning

Meeting financial requirements is critical for FCA approval and ongoing operations. ABM assists SEMIs in demonstrating that both initial and ongoing capital requirements are met. We prepare comprehensive financial projections, stress test scenarios, and liquidity assessments to prove resilience under different market conditions. These financial models provide the FCA with assurance that the institution has a sustainable business model with adequate resources to operate responsibly.

Technology & IT Infrastructure

Technology forms the backbone of a SEMI’s operations. ABM evaluates IT systems to ensure they can support secure payment processing, data protection, and fraud prevention. We also ensure alignment with the FCA’s operational resilience requirements, including cybersecurity protocols, data privacy controls, and incident management procedures. By doing so, SEMIs can operate with confidence, knowing that their technological infrastructure is both secure and scalable.

Regulatory Alignment & Documentation

A successful SEMI application depends on the accuracy and completeness of its regulatory documentation. ABM prepares and reviews all necessary FCA submission documents, including the business plan, safeguarding policy, AML/CFT framework, governance policies, and risk assessments. We ensure that every filing, declaration, and attestation is consistent with FCA requirements, minimizing the risk of application delays or rejections.