If you run a high-risk business — like crypto, gambling, adult, or forex — you know that banking is your biggest operational challenge.
The core question in 2025:
“Should I pursue a traditional EU bank account, or just go with an EMI?”
The truth is: it depends on your goals, your risk profile, and your structure.
In this guide, we’ll break down:
- The key differences between EU banks and EMIs
- Which option is better depending on your vertical
- What compliance expects in each case
- Real-world case insights
- How to structure your business for either option — or both
What Is an EMI and How Does It Compare to a Bank?
An Electronic Money Institution (EMI) is a licensed financial institution that can:
- Issue IBANs
- Provide SEPA and SWIFT payments
- Hold client funds in safeguarded accounts
- Offer digital banking dashboards, cards, FX conversions
A bank, meanwhile:
- Can hold deposits under a banking license
- Can lend money and offer treasury management
- Is regulated by central banks (not just financial authorities)
Feature | EMI | Bank |
IBANs / SEPA transfers | ✅ Yes | ✅ Yes |
Deposit insurance | ❌ No | ✅ Yes |
Lending / overdraft | ❌ Not available | ✅ Sometimes (not for high-risk) |
Crypto tolerance | ✅ Better than banks | ❌ Very low |
Account setup speed | ✅ 7–14 days (with introducer) | ❌ 30–90+ days |
In short: EMIs offer access, banks offer stability — but most high-risk companies start with EMIs.
The 2025 Compliance Landscape for High-Risk Clients
Both EMIs and banks now follow FATF, AMLD6, PSD2, and Travel Rule obligations. But they differ in:
Area | Bank | EMI |
Risk tolerance | Very low | Moderate (crypto/gaming possible) |
Onboarding friction | High | Moderate |
UBO scrutiny | Intense | Still strict, but less rigid |
KYT / AML requirements | Mandatory, extensive | Mandatory for crypto/gambling |
Licensing preference | Yes — strongly preferred | Helpful but not always needed |
Even with similar regulations, how these institutions interpret risk varies greatly.
Pros and Cons of European Banks for High-Risk Businesses
✅ Pros
- Prestigious — enhances credibility with partners and regulators
- Real bank accounts with direct SWIFT access
- Often offer multicurrency support (EUR, USD, GBP, CHF)
- Suitable for tax residency and substance arguments
- Better for treasury and long-term reserves
❌ Cons
- Onboarding time: 30–90+ days (sometimes indefinite)
- Low tolerance for crypto, gambling, or adult activity
- UBOs from certain jurisdictions (e.g. UAE, BVI, Turkey) are automatically declined
- Compliance often requires face-to-face or in-country visit
- Unexpected account closures are still common
💡 Verdict: Choose EU banks only if you’re licensed, low-volume, or seeking long-term positioning — and can afford the wait.
Pros and Cons of EMIs for High-Risk Businesses
✅ Pros
- Fast onboarding: 7–14 days if packaged correctly
- Crypto-friendly (with KYT tools in place)
- SEPA and sometimes SWIFT access via partner rails
- Support for adult, gambling, and FX (if structured right)
- Excellent for PSP and OTC settlement accounts
- API access and fintech dashboards
❌ Cons
- No deposit insurance (your funds are “safeguarded,” not protected)
- SEPA IBANs may be sub-accounts, not issued in your name
- Subject to correspondent bank de-risking
- Risk of offboarding if flow isn’t what was declared
💡 Verdict: EMIs are perfect for operational accounts or as a first step before scaling to real banks.
Which Verticals Work Best with Banks vs. EMIs?
Industry | Best Option | Why |
Crypto OTC | EMI (Lithuania, Malta) | Fast onboarding + KYT tolerance |
iGaming | EMI (Czech, Malta) | Accept declared gambling flows |
Licensed Casino | EU Bank (with license) | If fully licensed, may access niche banks |
Forex Broker | EMI + license combo | SEPA access without banking license |
Adult Platform | EMI only | Banks rarely accept adult flows |
NFT/Metaverse | EMI first | Crypto-linked = banks decline |
Affiliate Marketing | EMI | Especially if volume is >€50K/month |
Use Cases: When You Need One, the Other — or Both
🔁 Scenario A: You Sell NFTs in the EU
- Use EMI for SEPA payouts
- Use offshore bank for crypto reserves
- Repatriate income to an EU entity only when needed
💶 Scenario B: You Run a Regulated Casino
- Use bank for operational and tax presence
- Use EMI for PSP flows and crypto exposure
🌍 Scenario C: You Offer Forex Education
- EMI alone is fine — no license required
- Add multi-EMI redundancy for volume scaling
💡 In practice, most successful high-risk firms run a hybrid model — combining banks, EMIs, PSPs, and OTC ramps across multiple entities.
Hybrid Banking Structures That Actually Work
A hybrid setup blends traditional banks, EMIs, and sometimes offshore accounts to optimize for speed, compliance, and resilience.
💡 Example: Crypto Trading Desk
Component | Jurisdiction | Purpose |
Holding company | BVI or Seychelles | Tax neutrality & flexibility |
Operating company | Czech Republic | EU EMI onboarding and PSP integration |
EMI account (SEPA) | Lithuania | EUR flows, OTC settlements |
Offshore account (USD) | Belize or Labuan | Treasury or international partners |
💡 Example: Gambling Affiliate Network
Component | Jurisdiction | Purpose |
Operating entity | Cyprus | Access to EU PSPs and legal coverage |
EMI 1 (EUR flows) | Malta or Czechia | Settlements from gambling operators |
EMI 2 (USD flows) | UK EMI or offshore | Global partner payouts |
These structures ensure:
- Flow separation (by region or risk type)
- Contingency in case one account is closed
- Greater likelihood of keeping at least one active account at all times
What Documents Are Required for Each Option
While the fundamentals are similar, the depth of scrutiny is different.
Document | EMI | EU Bank |
Passport of UBOs | ✅ Notarized preferred | ✅ Must be notarized & apostilled |
Proof of address | ✅ Simple upload | ✅ Translated, notarized |
Certificate of Incorporation | ✅ .pdf acceptable | ✅ Prefer certified copies |
Share registry | ✅ Needed | ✅ Needed |
AML/KYT policy | ✅ For crypto/gambling | ✅ Mandatory with licensing |
Business plan | ✅ 1–2 pages OK | ✅ Often requires detailed memo |
Source of funds | ✅ Declaration | ✅ Full bank statements, contract trail |
Tax documents | ❌ Not always needed | ✅ Often required |
Website and legal pages | ✅ Strongly encouraged | ✅ Mandatory |
Face-to-face or video call | ⚠️ Sometimes | ✅ Almost always |
Apply like you’re going through due diligence for a merger — not just opening a PayPal account.
Which One Is Easier to Open in 2025?
Metric | EMI | Bank |
Time to onboard | 7–14 days (with intro) | 30–90 days (or longer) |
Crypto tolerance | High | Low to none |
Adult industry access | Medium | Almost impossible |
Gambling accepted? | Yes (if affiliate or licensed) | Yes (only if licensed) |
Offshore entity OK? | Yes (with transparency) | Rarely |
Licensing required? | Optional (unless PSP/Forex) | Strongly preferred |
Best for PSP flows? | ✅ Yes | ⚠️ Risk of disruption |
Treasury holding? | ⚠️ Not ideal | ✅ Better long-term stability |
💡 In most cases, the EMI is the starting point — and banks come later, after your volumes are stable and structures are proven.
How BankMyCapital Helps Structure the Right Setup
We don’t sell banking products. But we do guide high-risk businesses to the institutions that are still onboarding clients like you — and help you succeed where others get rejected.
Here’s how we assist:
✅ Risk Profile Review
- We evaluate your business model, sector, and structure
- Identify potential red flags before you apply
✅ EMI vs Bank Strategy
- Based on your volume, jurisdiction, and activity, we advise whether to start with an EMI or aim for banking
- Where appropriate, we suggest a dual-track onboarding (apply to both types in parallel)
✅ Pre-Approval Packaging
- We help you prepare a bank-compliant business summary
- Build a flow-of-funds diagram
- Review and label your documents correctly
- Recommend KYT and AML solutions that reduce onboarding friction
✅ Introductions to Licensed Providers
- We introduce you to EMIs, PSPs, and banks that still onboard crypto, gambling, forex, and adult businesses
- All introductions are made to third-party regulated institutions which — to the best of our knowledge — operate in compliance with local laws
We don’t believe in “guaranteed” banking. We believe in realistic, transparent onboarding — structured properly.
FAQ: Banks vs. EMIs for High-Risk Industries
Q: Can I have both a bank and an EMI at the same time?
Yes — and we strongly recommend it. Use the EMI for operational flows and the bank for reserve capital and licensing credibility.
Q: Do I need a license to get an account with either?
For regulated activities (e.g., gambling, FX brokerage), yes. For others (e.g., affiliates, education, consulting, OTC), it’s about risk explanation, not licenses.
Q: Are EMI accounts real IBANs?
Yes — but some are “virtual IBANs” under a shared banking partner. They’re still usable for SEPA and SWIFT but may raise flags with ultra-conservative counterparties.
Q: Is crypto allowed at European banks in 2025?
Not directly. You’ll need an EMI or PSP for crypto ramps, and you can settle into a traditional account with clear source of funds.
Q: Should I use an EMI to collect client payments?
Yes, many crypto and gambling-friendly PSPs settle into EMIs. Just make sure your EMI understands the nature of your business to avoid freeze risk.
Final Thoughts + Next Steps
In 2025, EMIs are the gateway, and banks are the fortress.
You won’t get into the fortress without proving yourself at the gate.
Start with a reliable EMI that understands your vertical. Build transaction history. Maintain compliance. Then, if needed, graduate to a traditional bank — or keep using EMIs with offshore pairing to stay nimble.
But above all: don’t apply blindly. Package your file, tell your story, and apply through people who know what these institutions want to see.
📩 Want help deciding between a European bank or an EMI for your business?
Contact BankMyCapital for a strategy session. We’ll review your case, recommend the right setup, and guide you through the process — with introductions to vetted, regulated providers who still support high-risk industries.