The client held funds for sellers between order and payout. A law firm had told them that meant an electronic money institution licence, and eighteen months of capital, hiring and drafting had followed.
Nobody had asked whether the payout ever left a regulated partner's control.
We mapped the flow of funds transaction by transaction. Money moved from buyer to a partner-held safeguarded account and out to the seller — the client never took possession.
That made an agent arrangement with an existing institution the correct perimeter, with a commercial agreement and a compliance framework instead of a licence.
Live in nine weeks. Two point one million dollars of application, capital and headcount cost released, and a path to their own licence kept open for the volume tier that would justify it.