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+1 (888) 647 05 40One way of accessing the EU financial markets is by creating a brokerage in Cyprus under a CIF license that also has a payment institution authorization. This will open a direct gateway without necessarily having to start from scratch. The unified setup allows both the investment service provisions and the handling of client payment flows. In 2025, when the approvals for new permits are expected to be much tougher, capital expectations higher, and compliance scrutiny deeper from the EU regulators, it will be a very strong setup. Any firms eyeing the provision of execution services and controls on the customer deposits would structurally find a dual-licensed firm efficient and commercially sustainable.
Cyprus continues to be a very important jurisdiction in the EEA for the establishment and operation of regulated businesses with regard to the provision of financial offerings. The country allows for direct access to EU passporting for investment firms under MiFID II and for payment institutions under PSD2. A regulatory structure has indeed been put in place to cater for various types of business models – including FX and CFD brokerages working under an STP architecture, FinTechs for international money remittances and account/e-wallet services.
The CIF permit is given by the CySEC and falls under the scope of the EU’s Markets in Financial Instruments Directive II. CIFs can operate as execution-only brokers, provide investment advice, or hold client money and assets, depending on the permissions granted. In the STP model, client orders are routed directly to external liquidity providers with no internal dealing or position taking. This is categorized as a limited-scope CIF, suitable for firms that do not intend to act as market makers or principal counterparties.
On the payments side, the national bank supervises the licensing of PIs, EMIs, and AEMIs. The PI license in Cyprus permits payment execution, issuing of payment instruments, and account management. The EMI license in Cyprus expands this by allowing the issuing and redemption of electronic money. An AEMI license is a full-scope version of the EMI permit, suitable for firms intending to offer broader cross-border e-money services across the EU.
Operating under both a CIF and a payment institution license allows a firm to accept client deposits, process withdrawals, offer trade execution, and maintain full transactional oversight. These capabilities are especially relevant to FX brokers, investment platforms, and digital asset firms seeking regulated status in the boundaries of EU structure.
Regulatory requirements revolve around risk management, governance, reporting, and guarding against anything that may harm the clientele. In the STP model, a CIF needs to have the following in place: a local management presence, local and third-party auditors, compliance officers, and a risk management function independent of the revenue side of the business. This would bring us to attention-catchers such as MiFIR trade reporting, best execution policies, and transaction monitoring.
Client funds should be protected where relevant even for non-custodial firms to meet investor protection standards. Internal systems of those firms holding a Cyprus payments license must ensure abidance by AML/CTF matters, provide secure customer authentication, transaction risk analysis, and safeguard the client funds.
PIs shall open separate accounts, which shall be maintained in an approved institution in the country of its authorization, and shall conduct daily reconciliations.
Firms are reviewed by the Central Bank for operational readiness at regular intervals, through inspections, prudential returns, and thematic reviews focusing on cybersecurity, fraud controls, and consumer safeguard.
The regulatory burden has increased tremendously by 2025. ICARA under the new prudential regime for investment firms is fully enforced. Firms will need to be able to demonstrate very robust systems for risk identification and financial shock absorption. Payment institutions shall hold business continuity and liquidity shortfall scenarios as the basis of their contingency plans.
It makes the combined CIF + PI/AEMI permit structure more complex to apply for, but also more valuable when already approved.
Acquiring a functioning firm with the necessary authorizations is becoming the preferred route for market participants. This approach avoids application bottlenecks, accelerates multinational access within the EU, and enables immediate client onboarding after completion.
Firms aiming to enter European markets or expand their footprint in restricted sectors increasingly opt to buy an entity that already holds both investment and payment permissions. This often proves more efficient than building operations from the ground up.
Entities with both authorizations in place typically come with built-in infrastructure: execution systems, onboarding workflows, compliance frameworks, and internal controls that have already been tested by supervisory bodies and banking partners. This lowers friction when connecting with service providers such as payment firms and correspondent banks.
Running transaction flows and settlement functions under one umbrella also simplifies oversight. Identification, monitoring, and reporting processes can be centralized, operational costs reduced, and technical architecture kept lean. This structure is especially suited for firms dealing in remittances, wallets, or app-based financial services.
Before proceeding with acquisition, the buyer must carry out a full review of corporate governance, financials, compliance logs, regulatory correspondence, and licensing scope. It is essential to confirm that the entity remains in good standing with CySEC and the Central Bank, that all periodic reports have been submitted, and that internal policies are updated in line with regulatory circulars issued in the past two years.
A particular focus should be placed on changes to prudential rules that took effect in 2025. These include more stringent capital calculations under the IFR/IFD regime, especially for investment firms with connected entities. The CySEC now examines group structures more closely, including financial relationships with affiliates, revenue concentration, and ownership links. Any weaknesses in governance or evidence of informal control may trigger requests for re-licensing or restructuring.
On the payment side, it is critical to review safeguarding account arrangements, client fund reconciliation practices, and the quality of transaction monitoring systems. Payment firms are increasingly held liable for fraud prevention, sanctions screening, and strong customer authentication processes. The Central Bank has emphasized these areas in its 2025 supervisory priorities. Acquiring firms must guarantee continuity of key workers, access to regulated payment partners, and unbroken records of abidance.
A Cypriot regulated broker and correlated operating PI permit is viewed as a very valuable and strategic asset. The regulatory domain in 2025 is tough. However, it would still be manageable by companies orientated structurally and operationally fit. This combined licensing hence allows the firm to offer investment services through the execution of trades and payments for clients across the EU. If business owners buy Cyprus CIF STP structures, it will put them in the EEA market in a legally effective and commercially soundly founded position when entering or expanding their business.
It reduces the lead time, mitigates licensing-related risks, and brings all the tools needed to run a fully regulated broker and fintech business within Europe. However, the transaction has to be managed very tightly; light has to be focused on making relevant issues of regulatory continuity, risk controls, and day-one capital adequacy comply.
Ensures firms comply with MiFID II and AML laws.
Integrated trading and payments under one structure.
Active, with high demand for fully licensed, clean companies.
The international company Eternity Law International provides professional services in the field of international consulting, auditing services, legal and tax services.