Sector

Payment Institutions & Electronic Money Institutions

Payment Institutions and EMIs sit at the centre of fast-moving payment flows, merchant acquiring relationships and rapid customer onboarding, under some of the most active supervisory attention in financial services.

Payment Institutions and EMIs are dealing with the same pressure in different forms: growth has outpaced governance. New products, new jurisdictions and new merchants arrive faster than onboarding, transaction monitoring and oversight can absorb. Supervisors tend to notice the gap before the firm does, and the first place they look is the file: a recent onboarding decision, a monitoring alert that should have escalated, a merchant relationship that no longer fits the original risk picture. Claritas comes in at that point. The work is reading the operation as it actually runs and telling the MLRO and Board what a supervisor will conclude when they read the same evidence.

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Perspective from Everett Morgan

Founder, Claritas Risk Advisory

Payment firms rarely fail because they lack AML controls. They struggle because those controls do not keep pace with growth. Customer onboarding accelerates, transaction volumes climb and governance quietly falls behind. Those are the gaps supervisors find first. Most of the payments work I take on begins at exactly that point, after the BWRA has aged, before the supervisor arrives.
If this sounds familiar, let's have a conversation. We'll tell you honestly whether Claritas is the right fit for your organisation, and, where the evidence supports it, we will say so plainly if existing arrangements are already appropriate or if only limited improvements are required.

Common challenges

What firms in this sector are working through.

Payment firms typically engage Claritas when one of the following is in motion:

01
Onboarding volumes that have outgrown the original control design
02
Outsourced KYC arrangements that need independent review
03
Merchant acquiring portfolios where risk concentration is changing
04
Transaction monitoring rules generating noise rather than insight
05
Agent and distributor networks where oversight has become harder to evidence
06
Cross-border payment flows attracting supervisory attention
07
MLRO annual reporting that needs to demonstrate effectiveness, not activity
08
Inspection readiness across payments, e-money and safeguarding

How Claritas helps

Judgement formed in practice.

Engagements start by reading the onboarding flow as it actually runs, sampling recent customer files across the higher-risk merchant categories, and walking through transaction monitoring alerts with the operations team. Where KYC is outsourced, we read the contract, sample the delegate's decisions and test how escalations are handled.

We sit with the MLRO on the BWRA, review the current payment typologies against what the monitoring rules actually catch, and work through merchant acquiring portfolios where risk concentration is changing. The work typically includes: