Payment institutions

We have been successfully supporting payment institutions for years, providing them with legal and business advice.

Payment institutions

how can we help you?

Setting up a payment institution

We have many years of experience in licensing proceedings for both small and national payment institutions. We will prepare the full documentation, draft the required procedures and guide you through the entire KNF process.

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MIP / KIP

We will show you which licensing path is best for your current stage of growth and how to safely plan the next steps.

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MIP to KIP conversion

Moving from a small to a national payment institution is a complex process that requires careful preparation. We provide end-to-end support - from a readiness analysis, through documentation drafting, to representation before KNF.

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DORA

The DORA Regulation introduces demanding digital resilience standards for financial institutions. We offer proven, cost-effective implementation solutions tailored to the scale of your operations.

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AML

Effective anti-money laundering measures are a key element of every payment institution's operations. We design and implement AML procedures tailored to your organisation's risk profile.

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Training

Regular employee training is not only a legal obligation but also a cornerstone of your institution's security. We offer both dedicated in-person training and a modern e-learning platform.

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Legal support

Changing regulations, contracts, terms and conditions, correspondence with supervisory authorities - instead of juggling it all, focus on growing your business. We offer ongoing legal support on a subscription basis.

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Audits / Compliance DD

Regular audits are not only a regulatory requirement but also a safeguard against potential sanctions. We will carry out a comprehensive review of your payment institution's compliance with current requirements.

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Business advisory

We help you make the most of your payment licence. We support the design of innovative services, the creation of hybrid products and the establishment of strategic business partnerships.

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our payment institutions experts

Meet the specialists who for years have successfully helped clients secure small payment institution status and supported fintech businesses.

Tomasz Klecor

Tomasz Klecor

Managing Partner

FinTech navigator. Lawyer.

For 15 years he has helped Poland's largest and most ambitious fintechs grow safely and globally. Starting as a lawyer, he now combines law, strategy, and technology — advising founders and boards on key decisions: how to scale in compliance with regulations, how to correctly implement DORA, MiCA, or AML and prepare for PSD3/PSR, and how to avoid the regulatory killers that can stop growth in its tracks.
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Paweł Geremek

Paweł Geremek

Attorney-at-law

ISO 27001 Auditor

Attorney-at-law focused on FinTech legal support and compliance. He also represents clients in proceedings before market regulators.
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fintech brands we have worked with

Quicko
Fenalabs
Paytree
PragmaGO
Autopay
Booste
Cashbene
DPay
EasySend
Fenige
FiberPay
HotPay
idoPay
Lendi
LitPay
PayPo
Patronite
Payland Net

ongoing legal support

Changing regulations, contracts, terms and conditions, correspondence with supervisory authorities - instead of juggling it all, focus on growing your business. We offer ongoing legal support on a subscription basis, providing your payment institution with comprehensive day-to-day legal and regulatory advice.

Regulatory monitoring

We track regulatory changes affecting the payments market and payment institutions on an ongoing basis. We give you advance notice of upcoming changes and help you prepare to align your operations with the new requirements.

Preparing documentation

We draft and update contracts, terms and conditions, policies and procedures in line with the current state of the law and market best practice. We make sure your documentation ensures legal compliance and protects your business interests.

Managing the KNF relationship

We prepare responses to inquiries and demands from the Polish Financial Supervision Authority. We support the reporting process and represent the payment institution during inspections and administrative proceedings.

Contract negotiations

We support negotiations with business partners, banks, agents and other entities. We make sure your interests are protected in contracts while keeping a pragmatic business stance.

Ongoing consultations

We provide access to financial-market law specialists who will answer your questions, clarify any doubts and help you make business decisions that take legal and regulatory aspects into account.

Legal risk management

We identify potential legal and regulatory risks in your payment institution's operations and propose solutions that minimise them, supporting safe business growth.

setting up a payment institution

We have many years of experience in licensing proceedings for both small and national payment institutions. We will prepare the full documentation, draft the required procedures and guide you through the entire KNF process, enabling your firm to launch faster in the payments business.

Comprehensive documentation

We will prepare all required documents, including the business plan, procedures, policies and terms and conditions, in line with current regulatory requirements. Our experience lets us produce documentation that meets the highest KNF standards.

Process support

We provide comprehensive support throughout the licensing process - from preparing the application, through communication with the regulator, to obtaining the licence. We will also help you prepare for meetings with KNF representatives.

Process optimisation

We audit your planned business processes and help optimise them for compliance with regulatory requirements while maintaining their operational efficiency.

Systems security

We advise on technical and organisational safeguards so that your systems meet the security requirements set for payment institutions, including the DORA and PSD2 requirements.

Personnel screening

We help prepare the documentation for KNF's competence assessment of the management board and key personnel - an important part of the licensing process.

Growth strategy

We support the development of a realistic growth strategy for your payment business that will not only form part of the licensing documentation but also serve as a practical guide for the first months of operations.

MIP to KIP conversion

Moving from a small to a national payment institution is a complex process that requires careful preparation. We provide end-to-end support throughout - from a readiness analysis, through documentation drafting and adapting procedures and systems, to representation before KNF. We help deliver the transformation smoothly and to the benefit of your business.

Readiness analysis

We perform a comprehensive analysis of your firm's readiness to move up to the higher licence tier. We assess existing resources, procedures, systems and organisational structure, identifying areas that need to be adapted to KIP requirements.

Transformation strategy

We develop a detailed transformation strategy covering schedule, resources and budget. We help plan the process in a way that minimises disruption to current operations and optimises the overall project cost.

Documentation preparation

We prepare the full set of documentation required for the licensing process, including the business plan, internal procedures, descriptions of processes and IT systems, risk management policies and organisational structure.

Capital requirements

We advise on meeting the capital requirements for a KIP, including capital structure and sources. We help identify and implement appropriate solutions for financial safeguards and capital management policy.

Process alignment

We support the alignment of business and operational processes to a larger scale of operations and higher regulatory requirements. We design new solutions or improve existing ones in line with industry best practice.

IT systems

We provide support in aligning IT systems with the increased security and scalability requirements. We help identify technology solutions that ensure regulatory compliance and effective support for larger-scale operations.

Human resources

We help build the right organisational structure and team that meet KNF requirements on competencies and experience. We support the recruitment of key specialists and the preparation for the assessment of the management board and key personnel.

Representation before KNF

We provide professional representation in dealings with the Polish Financial Supervision Authority. We prepare you for meetings, help respond to inquiries and demands and support you throughout the licensing proceedings.

Partner relations

We advise on relations with business partners (banks, agents, suppliers) during the transformation period. We help renegotiate contracts and establish new business relations suited to a national payment institution.

Converting from MIP to KIP opens up new business opportunities by enabling operations without transaction limits and across a broader territorial scope. With our support the process becomes more predictable, letting you focus on growing your business rather than on regulatory challenges.

MIP / KIP

Choosing the right licence is the first step to a stable and scalable payment business. See which path matches your operating model.

MIP

For firms starting out in payment services that want a fast market entry with a limited service scope and a lower entry threshold.

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KIP

For entities planning a larger scale of operations, a broader service scope and growth without the limits typical of the MIP model.

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Business advisory

We help you make the most of your payment licence. We support the design of innovative services, the creation of hybrid products and the establishment of strategic business partnerships. Drawing on our experience, you will optimise processes and strengthen your institution's market position.

Payment services design

We help design and roll out innovative payment services that will set your firm apart in the market. We combine practical regulatory know-how with a business mindset to create unique solutions.

Building hybrid products

We combine payment services with other financial products to create comprehensive solutions that boost customer value and generate additional revenue streams for your payment institution.

Strategic partnerships

We help identify and establish cooperation with the right business partners - banks, payment institutions, technology providers - who can help extend the reach of your payment services.

Process optimisation

We analyse and optimise your business processes to make them more efficient, secure and user-friendly. We deploy market-leading practices tailored to the specifics of your payment business.

Growth planning

We support long-term growth strategy planning, including preparation for expanding the scope of payment services provided or entering new markets. We help map a growth path that takes the changing regulatory environment into account.

Competitor analysis

We deliver a detailed competitor analysis of the payment services market, identify market niches and potential competitive advantages for your payment institution and highlight market trends and directions.

Training

Regular employee training is not only a legal obligation but also a cornerstone of your institution's security. We offer both dedicated in-person training and a modern e-learning platform, providing a cost-effective way to meet training duties on AML, DORA and other compliance areas.

Training

We organise dedicated training delivered by practising experts and tailored to your payment institution's profile and the needs of different employee groups.

  • Programme tailored individually to the nature of your operations and your organisation's processes
  • Practical workshops and case studies based on real-world situations
  • Opportunity to discuss individual challenges with experts during the training
  • Comprehensive training materials for use in day-to-day work

E-learning platform

We provide access to a modern e-learning platform with courses covering all key compliance areas for payment institutions.

  • 24/7 access from any device, allowing flexible training scheduling
  • Automatic progress tracking and completion certification
  • Regular content updates in line with changing regulations
  • Interactive tests to verify understanding of the material
  • Reporting on training compliance for supervisory purposes

AML/CFT Training

Comprehensive training on anti-money laundering and counter-terrorist financing, covering identification of suspicious transactions, KYC procedures, reporting to GIIF and obliged-entity duties.

DORA Training

Training on operational resilience and cybersecurity in line with the DORA Regulation, preparing staff to recognise and respond to digital threats.

GDPR Training

Personal data protection training in the context of payment institution operations, combining GDPR requirements with sectoral regulations and obligations arising from payment transaction handling.

Management board training

Specialist training for management board members and senior management, focused on personal liability, strategic risk management and decision-making in line with regulatory requirements.

Certified training

We provide certified training recognised by supervisory authorities as proof of competence in key compliance areas, which is particularly important for AML Officers and CISOs.

International training

For institutions operating cross-border, we offer training that addresses the requirements of various jurisdictions and regulators, available in multiple languages and aligned with international standards.

Our training solutions will help your payment institution not only meet formal requirements but, above all, build a genuine compliance and security culture. As a result, you gain not just regulatory compliance but also stronger risk protection and greater trust from customers and business partners.

audits / compliance DD

Regular audits are not only a regulatory requirement but also a safeguard against potential sanctions. We carry out a comprehensive review of your payment institution's compliance with current requirements, identify areas for improvement and support the implementation of recommended changes, including the annual procedure review.

Comprehensive compliance review

We perform a detailed analysis of every aspect of your payment institution's operations for compliance with current regulatory requirements, identifying potential risks and gaps.

Compliance gap identification

We pinpoint areas where your institution may fall short of legal requirements, assessing the level of regulatory risk and the potential consequences of every identified gap.

Procedure effectiveness assessment

We verify not only that required procedures exist but also how effective they actually are in business practice. We check whether the procedures are properly implemented and applied by employees.

Annual procedure review

We perform the statutory annual review of AML procedures, including the money-laundering risk assessment and the effectiveness of implemented control mechanisms, and document the process in line with requirements.

Detailed report and recommendations

We deliver a comprehensive report covering all audit findings together with detailed, practical remediation recommendations, including an implementation plan and prioritisation.

Implementation support

We do not leave you alone with the report - we actively support the implementation of the recommended improvements, helping draft or update procedures, documentation and systems.

Inspection readiness

We prepare your institution for inspections by supervisory authorities, running mock inspections and verification audits and assisting you during the actual regulatory inspection.

Compliance Due Diligence

We carry out detailed compliance due diligence, which is invaluable for M&A transactions, strategic partnerships and entry into new business areas.

Process optimisation

Beyond ensuring compliance, we also highlight opportunities to optimise compliance processes so they are more efficient and less burdensome for the business while remaining fully aligned with the law.

Thanks to our audits you will not only avoid potential sanctions but also optimise your compliance processes, saving time and resources. A regular audit is an investment in the security and stability of your payment institution.

DORA

The DORA Regulation introduces demanding digital resilience standards for financial institutions. We offer proven, cost-effective implementation solutions tailored to the scale of your operations. We deliver regulatory compliance without excessive operational burden on your business.

Comprehensive assessment

We carry out a comprehensive assessment of your payment institution's current digital resilience. We identify gaps and areas that need to be aligned with DORA requirements, taking your business specifics into account.

Implementation strategy

We develop a practical DORA implementation strategy tailored to the scale of your business. We factor in both regulatory requirements and the real operational and budgetary capacity of your payment institution.

Effective solutions

We design and implement cost-effective solutions that boost digital resilience. We use proven tools and methods that deliver DORA compliance without unnecessary organisational burden.

Documentation and procedures

We prepare the complete documentation and procedures required by DORA - IT risk management policies, business continuity plans and incident management procedures. We make sure the documentation is practical and usable.

Training

We train your team on the new DORA requirements and procedures. We make sure staff understand their roles and responsibilities in maintaining the payment institution's digital resilience.

Resilience testing

We support the preparation and execution of the operational resilience tests required by DORA. We help design realistic test scenarios, analyse results and implement the necessary improvements.

Thanks to our pragmatic approach you will meet DORA requirements without unnecessary organisational and financial burden. We will make sure your payment institution is digitally secure and legally compliant while remaining operationally flexible.

AML

Effective anti-money laundering measures are a key element of every payment institution's operations. We design and implement AML procedures tailored to your organisation's risk profile, deliver the required training, and help you build an effective transaction monitoring system aligned with the latest legal requirements.

AML procedures

We develop comprehensive AML/CFT procedures tailored to your payment institution's risk profile. Our procedures comply with current regulatory requirements while remaining practical and ready to be deployed effectively.

Advanced KYC systems

We design and implement effective customer identification and verification systems (KYC) that meet strict legal requirements without harming user experience or operational efficiency.

Transaction monitoring

We help build an effective, risk-based transaction monitoring system that automatically flags suspicious activity and generates alerts for review by the compliance team.

AML risk assessment

We carry out a comprehensive AML risk assessment that serves as the foundation for effective procedures and systems. We update the assessment regularly to reflect changing circumstances and new threats.

Technology solutions

We advise on selecting and deploying modern technology tools that support AML processes - from screening systems, through databases, to advanced machine-learning-based solutions.

Specialist training

We run dedicated AML training for different staff groups - from basics for the whole team to specialist sessions for compliance teams and AML officers. We tailor the content to your institution's profile.

Source update

We provide regular updates of AML procedures and systems in response to regulatory changes, new financial-crime trends and the evolving operations of your payment institution.

Inspection support

We provide comprehensive support during inspections by supervisory authorities - helping prepare documentation, draft responses to inspectors' queries and implement any post-inspection recommendations.

Reporting to GIIF

We help design and implement effective reporting procedures to the General Inspector of Financial Information, including suspicious and above-threshold transaction reports, and we support communication with GIIF.

compliance / AML officer support

We provide expert support for your in-house compliance and AML teams. We help resolve complex cases, review KYC decisions, prepare reports to supervisory authorities and implement new regulatory requirements. Your specialists gain additional expertise and more time for strategic work.

Ongoing expert consultations

We provide ongoing access to consultations with financial-market law experts who will answer questions from your compliance and AML officers and help interpret regulations and make key decisions.

Complex case analysis

We support the resolution of complex anti-money laundering cases, suspicious transaction analyses and high-risk customer risk assessments, delivering detailed recommendations.

Reporting support

We help prepare and review reports to supervisory authorities, including GIIF filings, periodic reports for KNF and NBP, and explanations in response to regulators' queries.

Regulation implementation

We support your officers in effectively implementing new regulatory requirements, explaining the practical implications of legal changes and helping adapt internal procedures and systems.

KYC process review

We provide a second opinion on difficult KYC/AML decisions, especially for high-risk customers, helping balance regulatory requirements with business needs.

Developing risk assessment methodology

We help develop and update risk assessment methodologies for customers and products, factoring in the latest regulatory trends and best market practices in AML/CFT.

Process optimisation

We advise on the design and optimisation of internal compliance processes to boost efficiency and reduce administrative burden while maintaining full legal compliance.

Selecting technology tools

We advise on selecting and implementing technology tools that support compliance and AML processes, taking account of your payment institution's profile and scale of operations.

Building team competencies

We provide specialist training and workshops for your compliance and AML officers, helping them grow their skills and stay current with the latest regulatory trends.

Working with us frees up your in-house resources while giving you access to specialist knowledge and experience. Your team can focus on strategic priorities, confident that day-to-day compliance challenges are handled professionally.

contact

Our payment institutions practice is led by:

Tomasz Klecor

Tomasz Klecor

Managing Partner

FinTech navigator. Lawyer.

+48 797 711 924
fintech@legalgeek.pl

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