01
LT
Lithuania.
Bank of Lithuania
- Regulatory framework
- PSD2 (Law on Payments) · EMD2 (Law on Electronic Money and Electronic Money Institutions)
- Authorisations covered
- EMI · PI
A dense Lithuanian EMI sector hosts many merchant-acquiring and e-money issuance operations. Common patterns include extended rolling reserves, pre-termination security account transfers, and contested chargeback assessments. The Bank of Lithuania operates an established complaints framework and engages substantively with documented merchant complaints.
02
IE
Ireland.
Central Bank of Ireland (CBI)
- Regulatory framework
- European Union (Payment Services) Regulations 2018 · European Communities (Electronic Money) Regulations 2011
- Authorisations covered
- PI · EMI · credit institution
Ireland hosts a number of large-scale EMI and payment platform operations passporting throughout the EEA. Files typically present significant scheme passthrough volumes, complex documentary chains, and a sophisticated counterparty legal function.
03
MT
Malta.
Malta Financial Services Authority (MFSA)
- Regulatory framework
- Financial Institutions Act · Banking Act
- Authorisations covered
- Financial institution licence (FIA) covering payment services and e-money
A sector with strong activity in card acquiring, alternative payment methods, and gaming-adjacent merchant categories. Files often present elevated rolling reserves, contested VIRP/scheme programme assessments, and undocumented internal adjustment lines.
04
CY
Cyprus.
Central Bank of Cyprus (CBC)
- Regulatory framework
- Payment Services and Access to Payment Systems Law · Electronic Money Law
- Authorisations covered
- PI · EMI · credit institution
Cyprus authorises a meaningful EMI and payment institution population, with frequent multi-merchant programmes. Recurring features include long-duration fund retention beyond contractual release windows and phantom contractual provisions cited in assessment letters.
05
GB
United Kingdom.
Financial Conduct Authority (FCA)
- Regulatory framework
- Payment Services Regulations 2017 · Electronic Money Regulations 2011
- Authorisations covered
- API · EMI · authorised credit institution
The UK regulatory regime is well-established and the FCA operates a mature complaints and supervisory engagement framework. Counsel of record is selected from the panel of senior commercial litigators with prior PSP-side or merchant-side engagement.
Outside this footprint
Counterparties authorised in other EU Member States, the EEA, or other comparable regulatory regimes are considered on a case-by-case basis. Where the structural facts are sufficiently strong, the firm will engage counsel of record in the relevant jurisdiction.
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