Selecting a jurisdiction in which to launch a high-risk payment company involves carefully considering the credibility, access, and sustainability each offers.
Your chosen jurisdiction determines how clients, banks, and partners perceive your business, and it defines how easily you can operate across borders. In this guide, we explore the leading jurisdictions in 2025 for setting up a high-risk payment company, focusing on licensing conditions, regulatory strength, and banking reliability.
Understanding “High-Risk” in the Payment Context
A high-risk payment company typically services industries or markets that attract stricter oversight due to higher fraud or chargeback exposure. Common examples include crypto exchanges and digital asset platforms, iGaming and betting operators, forex, CFD, and remittance services, adult content, nutraceuticals, and subscription models, or cross-border fintechs with non-traditional structures. Because these sectors face elevated scrutiny, regulators and financial institutions expect strong AML (anti-money laundering), KYC/KYB, and transaction monitoring frameworks before approval.
Key Factors When Choosing a Jurisdiction
When evaluating jurisdictions for a high-risk payment setup, consider:
- Licensing Framework – Availability of EMI, PI, or PSP licences suitable for your model.
- Banking Access – Whether banks in that jurisdiction accept high-risk clients.
- Reputation – How regulators, acquirers, and card schemes perceive the jurisdiction.
- Regulatory Cost & Timeline – Capital requirements, application time, and compliance workload.
- Passporting or Cross-Border Reach – Especially for EU/EEA operations.
- Supervisory Environment – Quality of AML oversight, reporting, and regulator responsiveness.
1. Malta – EU Passporting and Sector Specialisation
Why Malta Stands Out
Malta is one of the few EU jurisdictions that welcomes high-risk payment businesses, particularly those linked to gaming, FX, and digital assets. The Malta Financial Services Authority (MFSA) issues both Payment Institution (PI) and Electronic Money Institution (EMI) licences under the EU’s Payment Services Directive (PSD2), allowing full EU passporting rights.
Advantages: EU-recognised licence enabling operations across EEA markets; established ecosystem for fintech, iGaming, and crypto-related services; strong service provider network (law firms, compliance consultants, auditors); competitive corporate tax incentives and flexible workforce.
Challenges: Lengthy approval process (often 12–18 months for full EMI); strict fit-and-proper requirements for directors and shareholders; banks are selective and may require multi-jurisdictional structuring.
Best for: Well-capitalised PSPs or EMIs targeting the European market and willing to maintain a visible presence and substance in Malta.
2. United Kingdom – Credibility and Financial Infrastructure
Why the UK Remains a Global Benchmark
Despite Brexit, the UK remains one of the most respected jurisdictions for payment institutions. The Financial Conduct Authority (FCA) supervises both Payment Institutions (PIs) and E-Money Institutions (EMIs) under the Payment Services Regulations 2017.
Advantages: Strong global reputation and trusted financial ecosystem; access to advanced banking and fintech infrastructure; transparent, well-documented licensing and supervision process; high confidence from acquirers, investors, and counterparties.
Challenges: High compliance cost and longer regulatory process; FCA scrutiny is particularly intense for high-risk business models; no longer part of the EU passporting regime; ongoing reforms to safeguarding and capital rules (2025–2026).
Best for: Companies prioritising reputation and long-term stability, particularly those seeking institutional partners or UK-based client acquisition.
3. Alternative Jurisdictions – Flexibility vs. Reputation
For businesses unable to meet EU or UK standards, smaller offshore or mid-tier jurisdictions offer lighter regimes. Examples include Curaçao, Seychelles, Mauritius, and Georgia.
Advantages: Faster incorporation and lower licensing costs; flexible corporate and tax regimes; easier acceptance of niche or emerging business models.
Challenges: Limited banking relationships and correspondent access; increased risk of de-risking by acquirers and PSPs; weaker international reputation and difficulty securing card scheme approval; potential for blacklisting by EU/FATF if oversight is insufficient.
Best for: Early-stage or niche high-risk operators testing the market before transitioning to a stronger regulatory environment.
Comparison Overview
| Jurisdiction | Licence Type | Market Access | Banking Environment | Regulatory Strength | Typical Setup Time |
| Malta | EMI / PI | EU Passporting | Moderate | High (MFSA) | 12–18 months |
| United Kingdom | EMI / PI | UK Market | Excellent | Very High (FCA) | 9–15 months |
| Seychelles / Curaçao | PSP / Offshore | Limited | Weak–Moderate | Low–Medium | 3–6 months |
| Mauritius | PSP / Payment Intermediary | Regional (Africa/Asia) | Moderate | Medium | 6–9 months |
| Georgia | PSP / VASP | Non-EU | Moderate | Medium | 6–12 months |
Practical Considerations for Setup
Engage early with regulators and maintain transparent communication. Demonstrate local substance through management presence and office space. Build banking relationships before licensing to avoid delays. Design a scalable compliance framework and use professional advisers who can align your structure, AML manuals, and technology with regulatory expectations.
Which Jurisdiction Fits Your Strategy?
Choose Malta if your goal is EU access with flexibility for gaming or fintech activities. Opt for the UK if credibility and long-term reputation are your priorities. Start offshore if you are testing a business model or raising initial capital, but plan to upgrade to a top-tier licence once sustainable.
Bottom Line
The best jurisdiction for a high-risk payment company depends on your risk appetite, funding, and market focus. Malta offers European reach, the UK provides unmatched credibility, and offshore centres deliver speed and cost advantages. Regardless of location, success ultimately depends on how compliant, transparent, and well-documented your operation is — not just where it’s registered.
If you’d like personalised guidance on choosing the right jurisdiction and structuring your high-risk payment company effectively, feel free to book a complimentary consultation with our team.
For more insights, explore our article: “Multi-Jurisdictional Business Structuring Without Red Flags”
Disclaimer
Widelia and its affiliates do not provide tax, investment, legal, or accounting advice. Material on this page has been prepared for informational purposes only and should not be relied on for such advice. You should consult your own tax, legal, and accounting advisers before engaging in any transaction. Please consult https://widelia.com/disclaimer/ for more information.
