The idea can be interesting if you︁ find people willing to invest a minimum capital of € 100K. per head. A minimum︂ of 30 partners.
Most of the people in this forum and in many other forums︃ are looking for a bank or an EMI that somehow does not share information and︄ that is flexible within some possibilities within a framework of legality that allows them to︅ operate with some flexibility, legal businesses but that many EMIs do not accept.
For this︆ type of approach I do not think that an EMI in Europe is the most︇ interesting since it will be subject to CRS in 95% of cases. And correspondent banks︈ that are under the criteria of European compliance will not facilitate the work either.
For this type of entity that may interest many, it is best to create an IFE︉ in Puerto Rico. It is the EMI version in offshore but in a territory that︊ does not have CRS.
The OCIF establishes that the training can be done with a︋ deposit capital of $ 300K as a guarantee fund, plus $ 250K of share capital︌ initially disbursed.
The incorporation expenses with ITE , core banking, permits, governement fees, laywer fees,︍ business plan, company formation, etc., can vary between 150 and 200K. This is the real︎ first expenses
Once the license is obtained the difficult thing comes. To find a correspondent️ bank. Obviously it is not with a paid-up capital of $ 250k that they will accept to open an account. As a minimum, the company must demonstrate a minimum of $ 2M of capital reserves. If you don't want a correspondant bank and you prefer to be in the FED you will need to wait for 1 or 2 year. And with more complicated process, but you will not need to pay extra comissions to the corresponsal bank.
But it must also be said that this capital and the capital deposited as a guarantee fund are not expenses. They are deposits that can be invested︀ bonds etc.
Operating expenses with a minimum required of 5 local employees, will start from︁ 17K monthly with local, director, compliance, IT specialist, accountant, etc...
The benefits in the first︂ months/year will be negative. And founders should approach this type of setup as a corporate︃ tool for their own needs. Most of the Puerto Rican banks that are set up︄ obtain benefits with high entrance fees and consistent monthly fees as well as commissions on︅ cards, movements, etc. I know 2 banks than they ask 5000$ for entry, and per︆ account
It must be necessary to have in mind that the clientele must be very︇ well chosen and avoid, citizens of Russia, the USA (to avoid fatca problems), Venezuela, China,︈ etc ..., that in case they could shoot the red flags of the FED controls.︉
There are several IFEs that have recently had problems hosting Maduro's money.
From here the︊ topic is feasible. You just have to find 30 partners who contribute with minimum €︋ 100K.
Currently there is a bank that is waiting for a license and raised capital︌ through crowfunding. I mean arival bank.
Another one who is also waiting to receive a︍ license is zenus
The business niche is mainly found in customers in Europe who want︎ to avoid CRS and who want some flexibility in working within the limits and parameters️ set by compliance.