We build client-owned, licensed neobanks for crypto companies

Neobank is an established business term. Neobanks are regulated entities with financial licences issued by national central banks. Depending on the licensing country and region, these licences may be called EMI, PEMI, PI and so on.

A neobank can open payment accounts, process transfers, issue cards, exchange currencies, and manage the financial system and its flows. Some banking functions — deposits, lending and investments — are available to neobanks only in partnership with traditional banks.

Crypto markets are moving towards full financial regulation

Crypto companies can no longer sustainably operate in a regulated financial system while relying on anonymous infrastructure.

FATF requires crypto-asset service providers to be licensed or registered and subject to financial supervision. Countries around the world are introducing regulation.

• In 2026, 83% of jurisdictions have already adopted rules for transmitting originator and beneficiary data in crypto transfers.
• In the EU, MiCA introduced a single authorisation regime for crypto-asset service providers and requirements for ownership, governance, client protection and operations.
• From 1 July 2026, unauthorised crypto-asset service providers must cease ordinary operations with EU clients.
• In Norlerr’s assessment, other regions will undergo a similar transition within one to two years.

Strategic choice: a regulated or unregulated model

The grey-market crypto-business model is becoming unsustainable. Owners must choose between moving into the unregulated part of the market and building a transparent regulated company.

Unregulated model

In Norlerr’s assessment, most companies are not ready to operate transparently and will return from the grey zone to the unregulated market. In the short or medium term, this will create difficulties for both the companies and their UBOs.

Regulated model

Transparent ownership structure • Relevant sources of funds • Licensed operations • Risk controls • Revenue and capitalisation.

This model reduces regulatory and banking risks for the company and its owners and allows it to continue operating in markets moving towards full financial regulation.

Norlerr works only with companies that have chosen the regulated model.

• Legacy registrations are losing value. Local status no longer provides access to major markets.
• Bank accounts are unstable. Terms, limits and willingness to work with crypto companies change.
• Crypto and fiat are separated. Clients have to use different companies, accounts and interfaces for crypto and fiat operations.
• The licence and the product do not match. Licensing, technology, banking connections and transaction controls are designed separately.
• Access to the EU is closing. Without authorisation, a company cannot fully attract and serve clients or conduct operations in the EU.
• Access to other global markets is gradually closing as well. FATF is extending the EU experience to other macro-regions.
• Scaling slows down. When entering a new market, the company has to confirm its ownership structure, sources of funds, operating model and control system again.

A traditional bank alone is not enough

• A bank account does not replace crypto-asset service-provider authorisation or make crypto-asset services lawful.
• A bank services the company but usually does not create embedded fiat accounts, wallets and cards for its clients.
• A bank’s crypto-risk policy can change faster than the business can rebuild its product.
• Dependence on one bank can bring the entire fiat side of the business to a simultaneous halt.

One crypto licence is not enough: a fully regulated model requires two licensed contours — a CASP for crypto-asset services and an EMI for accounts, payments and other fiat operations.

Working with EU clients

CASP authorisation allows the company to lawfully provide crypto-asset services to EU clients. The EMI provides accounts, payments and other fiat operations.

Access to global markets

Companies licensed and regulated in the EU may find it easier to access crypto and fiat markets in other regions.

One product

Клиент работает с фиатными средствами и криптоактивами в одном интерфейсе, а не переходит между разными компаниями, счетами и сервисами.

Own payment infrastructure

The EMI contour gives the company its own payment infrastructure and reduces the dependence of fiat operations on one bank. The company manages accounts, payments, cards, limits and the movement of client funds.

Scaling

A regulated structure supports business development. Banks, partners, investors and potential buyers can assess the ownership structure, licences and control system more easily.

A foundation for launching new products

The infrastructure can support an exchange, brokerage service, wallet, custody service or crypto-payment product.

EMI becomes part of the licensed product

If a stablecoin is pegged to an official currency and qualifies as an e-money token, a standard CASP model is not enough for its issuance.

In the EU, the issuer of such a token generally must be a bank or an EMI. In this case, the EMI does more than provide payment services: it forms part of the product’s licensed crypto core.

Built from scratch

Regulated CASP and EMI structures are created within one group.

EMI for an existing crypto company

The existing crypto business remains in place. A separate licensed fiat core is created and connected to the existing crypto product.