Banking On Its Own, or With the Company and Licence
Banking is one of our three core services, alongside company formation and licensing. You can come to us for banking on its own, when you already have a company and a licence and simply need a working account, or take it together with the formation and the licence as a single, sequenced engagement. Either way we do the work ourselves: we assess your profile, confirm appetite before you apply, prepare the file, and make the introduction directly.
Why Banking Is the Hardest Part for Regulated and High-Risk Operators
Banking is the single hardest infrastructure problem for crypto, fintech, gambling and other high-risk businesses. As of May 2026, a large majority of crypto-exposed funds report significant banking difficulties, the cost premium over standard business accounts runs five to fifteen times, and entire high-risk verticals sit on the permanent margin of the financial system. Licensing has clear regulatory paths. Banking does not, which is precisely why we build it into the engagement rather than leave you to find an account on your own.
The pattern is well established. Banks classify crypto and high-risk sectors as inherently elevated risk, and regulatory pressure on the institutions that serve them, including enforcement actions on Banking-as-a-Service sponsors, compounds the reluctance. The result is a banking access gap that operates independently of business quality. Specialist EMIs accepting these businesses typically charge several times the effective rate of a standard business account once monthly fees, SEPA and SWIFT charges, card processing and rolling reserves are combined.
The Markets in Crypto-Assets Regulation (MiCA) created an inflection point but not a solution. MiCA became fully applicable on 30 December 2024, with transitional grandfathering running to 1 July 2026. Authorised CASPs now hold regulatory parity with other regulated financial firms, which should reduce bank hesitancy, but risk committees move slowly and sector-specific gating layers on top. For most operators the practical consequence is one of three things: they run on EMIs and accept the higher cost, they take suboptimal terms at a bank willing to entertain the relationship, or they relocate to friendlier infrastructure. We exist to find the institutional fit before any of those becomes the only option left, and for licensed operators that planning happens while the licence is still being scoped.
How We Arrange Your Banking
We do this work ourselves. We assess your business against the institutions we know to have current appetite for your profile, we prepare the documentation, and we make the introduction directly. The point is to know the answer before you formally apply, not to fire off applications and hope. Because we form and licence the same businesses we bank, we plan banking feasibility while the structure is still being decided, not after the licence is granted.
The engagement runs in four stages.
1
Discovery & Assessment
1–3 days
We review your business model, transaction profile, regulatory status, jurisdiction and banking objectives. Your entity type, jurisdiction of incorporation and corporate structure directly affect which institutions will accept you. We give you an honest read on which banking categories are realistic, and if we cannot place the case we tell you at this stage.
2
Checking Fit Before You Apply
3–7 days
We check your profile against the current acceptance criteria of the institutions we work with, before you submit anything formally. They confirm appetite (yes, qualified yes, or no) in advance, which avoids the rejection cycle that comes from applying to several institutions in sequence. Standard profiles take a few business days; complex profiles take longer.
3
Shortlist & Direct Introductions
1–4 weeks
A short list of institutions we have confirmed will take your business, with terms understood upfront. We make the introductions and you engage directly from there. This is a shortlist of real fits, not a longlist of institutions that might say yes.
4
Account Opening & Support
2–6 weeks
Documentation preparation, KYB pack assembly, enhanced-due-diligence response support, and account activation. We coordinate throughout and stay accountable for the outcome. Most well-prepared cases reach activation within two to six weeks of formal application; complex cases can take longer.
For specific verticals and account types, see High-Risk Business Accounts, Crypto & Fiat Settlement and Multi-Currency Accounts & IBANs.
How We Deliver: A Controlled Network
We deliver banking through a controlled network of banking relationships and licensed specialists we work with directly. Some of the work is done in-house; the rest goes to established providers we have personally vetted and continue to manage. We never hand a client to an unverified third party, and we never name a bank or payment provider publicly. The route and the introduction are the deliverable, not a directory you could have found yourself.
These relationships are active and current, not a static list. Acceptance criteria are reviewed continually; what an institution accepted six months ago is not necessarily what it accepts today. That is also why we do not publish a list of banks: such a list is out of date the moment it is printed, and it would misdirect more applicants than it helps. We keep the relationships live so that checking fit takes days rather than weeks.
What the network spans:
- Licensed EU EMIs with crypto-specific onboarding workflows.
- European neobanks operating under EMD2 and PSD2 with regulated crypto-business onboarding.
- Specialist high-risk EMIs with sector capacity in gambling, forex and other regulated high-risk verticals.
- Credit institutions and crypto-aware banks in EU and UK jurisdictions.
- Correspondent banking relationships for cross-border SWIFT settlement.
- Multi-currency payment institutions with fast account opening.
- Settlement and on/off-ramp providers for crypto-fiat conversion.
For who we are and how we work, see About Tomberg & Partners.
EMI Accounts vs. Traditional Bank Accounts
An electronic money institution (EMI) is a financial services provider licensed under the Electronic Money Directive (EMD2, Directive 2009/110/EC) to issue electronic money and provide payment services. EMI accounts offer SEPA, SWIFT and IBAN access but are not bank accounts; they operate under a safeguarding regime rather than a deposit guarantee scheme. Most crypto, fintech and high-risk businesses run on EMIs because traditional banks refuse them. We help you decide which you need and arrange both where the structure calls for it.
The distinction matters for deposit protection, credit access and operational resilience. The comparison below reflects general market conditions as of May 2026; specific terms vary by institution.
| Dimension | Traditional Bank Account | EMI Account |
|---|---|---|
| Deposit Protection | FSCS £120,000 (from 1 December 2025); DGSD €100,000; FDIC $250,000 | No deposit guarantee; client funds safeguarded at credit institution |
| Credit Facilities | Loans, overdrafts, credit cards, trade finance, FX lines | None permitted under EMD2 |
| Payment Rails | Direct membership; Faster Payments direct participation | Indirect via correspondent; TARGET direct access expanded to EMIs October 2025 |
| Card Issuance | Debit, credit, commercial | Debit and prepaid only under BIN sponsorship |
| Interest on Balances | Permitted | Prohibited under EMD2 |
| Onboarding Timeline | 8–16 weeks | 2–6 weeks |
| Crypto Business Acceptance | Selective to hostile at retail banks; available at specialists | Widely available through specialist EMIs |
| Minimum Capital | €5 million+ under CRD; higher in practice | €350,000 (EMD2 Article 4) |
| Currencies Supported | Typically 1–5 local currencies natively | 20–50 currencies via multi-currency wallet |
| Best For | Treasury management, credit needs, institutional clients | Operational payments, multi-currency flows, licensed crypto and fintech |
Deposit protection is the single most consequential difference. The Financial Services Compensation Scheme raised its limit to £120,000 effective 1 December 2025, and the EU’s Deposit Guarantee Scheme Directive maintains €100,000 per depositor per bank. Neither applies to EMI balances; EMIs instead safeguard client funds in segregated accounts at credit institutions. EMIs also cannot lend, pay interest on balances or offer overdrafts, a hard legal constraint under EMD2. Businesses needing working capital, trade finance or interest-bearing deposits therefore require a bank relationship in addition to their EMI.
What We Cover
Our banking support covers four capabilities, each with a dedicated page. Most engagements combine two or more, and the sequencing matters: banking decisions made before the licensing jurisdiction is set, or settlement choices made before the multi-currency architecture is planned, create avoidable rework. Because we also handle your formation and licensing, we sequence all three together.
High-Risk Business Accounts
An operational bank or EMI account for a business in a sector that acquirers and banks classify as high-risk: licensed gambling, forex and CFD brokers, adult entertainment, CBD and hemp products, nutraceuticals, travel operators and regulated crypto businesses. Banking for these sectors is available but narrow, and the institutions that serve them apply card-network registration, rolling reserves and chargeback monitoring that standard merchants do not face. See High-Risk Business Accounts.
Crypto & Fiat Settlement
The infrastructure that moves value between blockchain networks and traditional payment rails. Exchanges, over-the-counter desks, on-ramp and off-ramp platforms and crypto-native fintechs need reliable access to SEPA, SEPA Instant, SWIFT, Faster Payments and euro-denominated stablecoin rails. Settlement sits downstream of banking: an institution must accept the business before settlement volumes flow. See Crypto & Fiat Settlement.
Multi-Currency Accounts & IBANs
A multi-currency account holds balances in several currencies under one relationship, typically with dedicated or virtual IBANs per currency. IBAN discrimination, where counterparties refuse payments based on IBAN country code despite SEPA Regulation Article 9 prohibiting it, remains widespread across the EU. See Multi-Currency Accounts & IBANs.
Banking Aligned With Licensing
Our banking support runs in coordination with our licensing work. Banking approval is frequently conditional on licence status, and licence applications routinely require proof of an operational account. We sequence the two to avoid the circular dependency that strands unlicensed applicants outside the banking system and unbanked applicants outside the licensing system. See Crypto Licensing and Gambling Licensing.
Why Banks Reject Regulated and High-Risk Businesses
Banks decline these applications for a short list of recurring reasons. Most are structural rather than applicant-specific, which means they can be predicted and often mitigated, but not always overcome. The common mistake is treating rejection as a documentation problem: better documentation improves the odds at well-matched institutions, but it does not open doors the institution’s risk appetite has closed. Knowing the difference is most of the job, and it is why we check fit before you apply.
Regulatory uncertainty. A business operating without a licence where one is required is effectively unbankable at tier-1 institutions. Approval rates for unlicensed applicants are low across the board. The mitigation is direct: secure a recognised licence before applying, which is exactly the work we lead with.
Sector-wide de-risking. Banks exit entire sectors rather than assess individual applicants when compliance cost exceeds expected revenue. The Financial Action Task Force has stated repeatedly that wholesale de-risking is not in line with its recommendations, but the economics continue to favour it. The mitigation is to target institutions that have deliberately entered the sector rather than those that merely tolerate it, which is precisely what our relationships let us do.
Correspondent banking pressure. Non-US banks serving crypto or high-risk clients risk losing US dollar clearing access, and active correspondent relationships have declined sharply over the past decade. The mitigation is to diversify into euro and local-currency flows where correspondent pressure is lower.
Chargeback and fraud exposure. Card networks operate tiered monitoring programmes for merchant chargeback and fraud ratios, with five-year consequences for breaches. Forex brokers face structural exposure because the majority of retail CFD accounts lose money. The mitigation is robust chargeback prevention, 3D-Secure implementation and pre-application risk scoring; see High-Risk Business Accounts.
Unclear beneficial ownership. The EU’s Anti-Money Laundering Regulation, applicable from 10 July 2027, harmonises UBO thresholds and bans anonymous crypto accounts entirely. The mitigation is a transparent ownership chain with documentation for every beneficial owner.
Weak compliance infrastructure. Crypto businesses without blockchain analytics, documented Travel Rule processes and transaction monitoring are routinely declined. The mitigation is to implement the infrastructure before applying; institutions read it as a credibility signal, not a nice-to-have.
For rejection-mitigation detail by vertical, see High-Risk Business Accounts.
What Banks Require: Documentation
Bank and EMI onboarding for regulated and high-risk businesses uses standard Know Your Business documentation plus sector-specific additions. Documentation quality, not volume, determines the outcome, and assembling it correctly is part of what we do for you.
Standard KYB Documentation
Certificate of incorporation, articles of association, certificate of good standing, shareholder and director register, UBO declarations covering every beneficial owner, proof of registered address, and certified passport copies plus proof of address for every director and UBO. Financial statements for the past two years plus year-to-date, and a business plan with 12-month forecasts covering revenue, transaction volumes, geographic flows and counterparty categories.
Licensing and Regulatory Documentation
Every relevant licence certificate with jurisdiction, number, scope, issue date and current status; regulator correspondence for the past 12 months; and AML and CTF policies covering customer due diligence, transaction monitoring, sanctions screening, Travel Rule compliance, suspicious-activity reporting and record keeping. A documented compliance officer appointment is expected, and SOC 2 Type II and ISO 27001 are de facto standard for institutional-grade relationships.
Sector-Specific Additions
For crypto businesses: a blockchain analytics provider contract, wallet architecture documentation, Travel Rule implementation details, a source-of-funds policy addressing on-chain origination, and a stablecoin handling policy. For card-dependent high-risk merchants: card-network registration, a chargeback management plan with historical ratio data, and PCI DSS compliance at the applicable level. Licensed gambling and forex operators must evidence their regulatory authorisation and client-fund segregation.
Institutions weight consistency across documents heavily. A clean AML policy that contradicts the business plan reads worse than an imperfect one that reconciles with every other document in the pack. We prepare the file as a single coherent set, which is where most of the avoidable delay disappears.
Frequently Asked Questions
Can I come to you for banking on its own?
Yes. Banking is one of our three core services, alongside company formation and licensing, and you can engage us for it on its own. We help high-risk and regulated businesses open bank and payment accounts: we assess your profile, confirm which institutions currently have appetite before you apply, prepare the file and make the introduction. If you also need a company or a licence, we plan all three together so the banking has the best chance of approval.
Why don’t you publish a list of banks?
We do not name banks or payment providers publicly. Acceptance criteria change continually and a named list goes stale within months, so it would misdirect more applicants than it helps. We work directly with banking relationships across EU EMIs, specialist high-risk providers and credit institutions, and we match each business to the ones whose current appetite fits it.
Can you help businesses other firms reject?
In many cases, yes. We work with institutions across a wide range of risk appetites, from EU EMIs that onboard licensed CASPs to specialist providers that take operators with complex jurisdictional or sectoral profiles. Outcomes depend on a complete KYB pack, a credible AML/CFT manual, a documented source-of-funds trail and a business model an institution can underwrite. We tell you honestly whether your case is one we can place before any application is made.
What is the difference between an EMI account and a bank account?
An EMI account provides SEPA, SWIFT and IBAN access under EMD2 authorisation but is not a bank account. EMIs cannot lend, pay interest or offer overdrafts, and EMI balances are not covered by deposit guarantee schemes such as FSCS (£120,000 from 1 December 2025) or the EU DGSD (€100,000); instead they safeguard client funds in segregated accounts at credit institutions. Traditional bank accounts offer full deposit protection, credit facilities and direct payment-system membership, but onboarding takes 8–16 weeks versus 2–6 weeks for EMIs.
Does having a licence improve banking access?
Yes, materially. MiCA-authorised CASPs, FCA-registered UK crypto firms, FINMA-supervised Swiss firms and VARA-authorised UAE firms all face lower rejection rates than unregulated counterparts, and an EMI or Payment Institution authorisation is itself a banking credential. This is why we plan licensing and banking together rather than in sequence.
How long does it take to open an account?
Traditional bank accounts for crypto and high-risk businesses typically take 8–16 weeks; EMI accounts for the same businesses take 2–6 weeks. Because we know which institutions currently have appetite for your profile, we steer you to the routes most likely to accept the application rather than entering a long onboarding process at an institution that will ultimately decline.
Form the company, secure the licence, open the account.
We deliver formation and licensing ourselves and arrange the banking that makes the business operational. One accountable firm, one point of contact, end to end. Tell us what you are building and we will tell you honestly what we can deliver.
Related Services
- Company Formation, formation across 25 jurisdictions for regulated and high-risk operators
- Licensing, crypto, gambling, forex, EMI and other licence regimes
- Crypto Licensing, VASP, CASP and MiCA authorisation
- High-Risk Business Accounts, banking for gambling, forex, adult and other high-risk verticals
- Crypto & Fiat Settlement, on-ramp, off-ramp and payment rails
- Multi-Currency Accounts & IBANs, multi-currency banking and IBAN guidance