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.