In 2025, high-risk businesses can’t afford to rely on just one bank. Whether you operate in crypto, gambling, forex, or adult-related industries, the risk of account freezes, arbitrary offboarding, or delayed settlements is too high.
That’s why smart operators are turning to EMIs (Electronic Money Institutions) — not as their only banking solution, but as a strategic backup that keeps their business running if their primary bank shuts down.
In this guide, we’ll show you:
- What an EMI account is (and isn’t)
- Which EMIs still onboard high-risk sectors
- What documents you need
- How to structure your business to qualify
- Why you should always set up a backup account — before you need it
What Is an EMI and How Is It Different From a Bank?
An Electronic Money Institution (EMI) is a licensed financial service provider that can:
- Open IBAN accounts (EUR and other currencies)
- Enable SEPA and SWIFT payments
- Offer prepaid debit cards and sometimes card acquiring
- Provide payment processing
- Act as a settlement layer for PSPs and crypto ramps
However, EMIs:
- Do not lend money
- Typically do not hold deposits (they “safeguard” them)
- Rely on partner banks for SWIFT access
- Are not covered by deposit insurance
Think of them as a regulated, licensed, fintech alternative to banks — ideal for day-to-day payments, PSP settlements, and managing global money flows.
Why High-Risk Businesses Need a Backup EMI in 2025
In crypto, gambling, forex, and other “taboo” sectors, the question is not if a bank account will get closed — but when.
EMIs provide:
- 🔄 Redundancy for your banking stack
- 💶 SEPA access for EUR clients
- 💱 FX accounts for multi-currency operations
- 🏦 Bridge accounts for PSP or crypto ramp settlements
- 🚨 Emergency backup if your bank gets blocked or delayed
A good EMI setup ensures your payouts, payroll, and partner transfers keep working even during compliance checks or bank issues.
Top EMI Jurisdictions That Still Onboard High-Risk Clients
| Jurisdiction | Risk-Tolerant? | Use Case Strength |
| Lithuania | ✅ Yes | Crypto, SEPA, fast onboarding |
| Czech Republic | ✅ Yes | Gambling, card acquiring, PSP flows |
| Cyprus | ⚠️ Selective | Forex, adult, Southeast Asia flows |
| Malta | ✅ Yes | iGaming, licensed operations |
| UK | ⚠️ Crypto-limited | Fintech, PSP, payout flexibility |
| Estonia | ⚠️ Narrow | Useful for support structures only |
💡 Important: Many of these EMIs only accept clients via introducers and require a pre-screened file.
Features You Get With a Well-Chosen EMI Account
| Feature | Available? | Notes |
| SEPA (EUR) Transfers | ✅ Yes | Usually with a named IBAN |
| SWIFT (USD, GBP, more) | ✅ Sometimes | Limited depending on EMI partner |
| Multi-currency balances | ✅ Often | Good for hedging flow risk |
| Crypto-fiat ramps | ⚠️ Selective | B2B only, via OTC partners |
| API Access | ✅ Yes | For integrations and automation |
| Cards or virtual IBANs | ✅ Yes | Payouts, staff, operational use |
| PSP Settlement Support | ✅ Yes | Use as client-facing settlement layer |
Step-by-Step: How to Open an EMI Account
Opening an EMI account in 2025 is faster than traditional banks — but that doesn’t mean it’s easy, especially if you operate in a high-risk vertical.
Here’s how to do it properly:
✅ Step 1: Pre-Screen Your Business
- Understand your sector risk (crypto, gambling, adult, etc.)
- Clarify if you’re licensed or unlicensed
- Determine where your clients are and what currencies you use
✅ Step 2: Choose the Right EMI
- Not all EMIs are equal — some won’t touch crypto, others love it
- Use a consultant or introducer to avoid wasting applications
- Match EMI services (SEPA, SWIFT, card issuing) with your needs
✅ Step 3: Prepare Your Application File
- UBO documents, company structure, AML/KYT policy, etc.
- Business model + flow of funds summary
- KYT tool or AML platform subscription (for crypto/gambling)
✅ Step 4: Submit File & Await Pre-Approval
- Most EMIs review internally within 2–5 days
- Expect clarification questions from compliance
✅ Step 5: Onboarding Call or E-Signature
- Some EMIs require a Zoom call with UBO
- Most finalize onboarding with DocuSign or PDF signature
✅ Step 6: Test the Account
- Send a small SEPA or SWIFT transfer
- Link to your PSP or crypto ramp
- Confirm incoming and outgoing work as expected
Full Document Checklist for EMI Onboarding
Here’s the standard compliance package you’ll need in 2025:
| Document | Required? | Notes |
| Passport of UBO(s) & Director(s) | ✅ Yes | Notarized preferred if offshore |
| Proof of address (< 3 months old) | ✅ Yes | Utility bill or bank statement |
| Certificate of Incorporation | ✅ Yes | Original or certified copy |
| Shareholder register | ✅ Yes | Even if nominee is used |
| Business model overview | ✅ Yes | What you do, how you earn, with whom |
| Website or online platform | ✅ Yes | Include link and screenshots |
| KYT tool agreement (crypto/gambling) | ✅ Yes | Chainalysis, Elliptic, etc. |
| AML/KYC policy | ✅ Yes | 2–3 pages is enough |
| Flow-of-funds diagram | ✅ Recommended | How clients pay, currencies used |
| Source of wealth (UBO) | ✅ Yes | Clean documentation: bank statements, contracts |
| PSP or Crypto Wallet IDs | ⚠️ Often | Transparency builds trust |
What EMIs Expect From Crypto, Gambling, and Forex Companies
EMIs onboard high-risk clients when they can explain and control the risk.
| Sector | What EMIs Want to See |
| Crypto | KYT tools, wallet transparency, declared flows |
| Gambling | Licensing status (Curacao, Malta, Cyprus), PSP partners |
| Adult | Platform clarity, age verification, traffic source explanation |
| Forex | Jurisdiction (Cayman? Seychelles?), licensing or education model |
| Unlicensed PSPs | Client KYC flow, transaction limits, roadmap to licensing |
💡 Don’t lie — even unlicensed models can be accepted if disclosed and structured.
Common Mistakes and Red Flags to Avoid
Even with a solid business, EMI onboarding can fail due to:
- ❌ Business model too vague (“consulting” for a crypto OTC desk)
- ❌ No KYT tools but clear crypto exposure
- ❌ Nominee directors without disclosed UBOs
- ❌ Website missing legal or compliance pages
- ❌ Volume forecasts wildly unrealistic
- ❌ No declared PSP, payment, or exchange partners
- ❌ Structure that doesn’t match flow (e.g., UAE company, but all clients are EU)
- ❌ Conflicting info submitted across documents
Each of these can instantly disqualify your application — even before the onboarding call.
Multi-EMI Structures: Diversifying Your Payment Infrastructure
For serious operators — especially in crypto, gaming, and FX — relying on a single EMI is a bad idea.
Why?
Because even if you’re approved today, policy changes, compliance reshuffles, or PSP pressure could get your account limited or closed tomorrow.
✅ Solution: Multi-EMI Structure
| EMI # | Use Case | Risk Isolation Benefit |
| 1 | Primary SEPA settlements | Daily client operations |
| 2 | Crypto off-ramp or USD flows | Risk isolated from SEPA |
| 3 | PSP settlements (gaming/adult) | Shield core account from chargebacks |
| 4 | Treasury holding / EUR reserves | Protects operational capital |
Diversification = resilience.
With two or more EMIs, you’re no longer at the mercy of one provider.
How BankMyCapital Helps with EMI Setup
We’re not a bank, and we don’t open EMI accounts directly.
But we’ve successfully helped dozens of high-risk clients get EMI accounts that work.
Here’s how we help:
- ✅ Pre-screen your business to identify red flags
- ✅ Recommend the right EMI provider based on your sector, jurisdiction, and volume
- ✅ Review all documentation before submission
- ✅ Assist in preparing flow-of-funds maps, AML statements, and business summaries
- ✅ Manage communication with compliance officers
- ✅ Coordinate onboarding and account testing
All EMIs we work with are — to the best of our knowledge — licensed in the EU or EEA and operate under PSD2 regulations.
FAQ: EMI Accounts for Risky Verticals
Q: Can I use an EMI as my main account?
Yes — for operational flows. But we recommend not using it to hold large reserves or receive non-compliant crypto funds.
Q: Can I get SEPA and SWIFT?
Yes — many EMIs provide SEPA by default, and some also provide SWIFT via partner banks (USD, GBP, etc.).
Q: Do EMIs allow crypto-related businesses in 2025?
Yes — if you disclose the crypto activity and use KYT tools to screen transactions.
Q: Do I need a license to open an EMI account?
Not always. If you’re an affiliate, educator, or OTC desk, structure and transparency often matter more than licensing.
Q: What’s the difference between EMI, PI, and PSP?
- EMI = account services, IBANs, SEPA
- PI = limited money transmission only
- PSP = merchant acquiring, not account-holding
Final Thoughts
Banking is no longer a single point of failure — it’s a stack.
And in that stack, EMIs are the agile, fast, and adaptable layer you must have if you’re in a high-risk vertical.
They won’t replace a traditional bank — but they might just save your business when your bank goes silent.
Set up your EMI before you need it. Not when it’s already too late.
📩 Need an EMI account fast — and want to avoid rejection?
Reach out to BankMyCapital for a no-obligation consultation.
We’ll review your business model, recommend a compatible EMI, and guide you step-by-step until your account is live and usable.