Electronic Money Institutions in Malta

As was the case for remote gaming and (much more recently) distributed ledger technology and cryptocurrencies, Malta was the first EU member state to publish legislation for Electronic Money Institutions under the Financial Institutions Act in 2011.

An Electronic Money Institution, or e-Money Institution (“EMI”) is a financial institution that is authorised to issue electronic, or digital (including magnetically stored) money. Said authorisation may be obtained through a licence in line with the Financial Institutions Act or through a similar grant from another EU jurisdiction in accordance with the Electronic Money Directive.

In addition, licenced EMIs may provide certain payment services and the operation of payment systems. These include:

  • Cash deposits on and cash withdrawals from a payment account
  • Payment transactions (including through a payment card or similar device)
  • Direct debits & standing orders
  • Issuing debit cards.

Since EMIs are not permitted to undertake lending or other bank related activities (hence the issuance of credit cards is not permitted), clients are not exposed to credit risk as would be the case with a normal bank. While EMIs may grant credit related to certain payment services, this is subject to the condition that any such credit shall not be granted from the funds received in exchange of e-money and held in accordance with the prescribed safeguarding requirements.

Similar to obligations imposed on licenced remote gaming companies in Malta, funds representing e-money must be ring-fenced and EMIs are liable for any shortfalls.

Fenlex Corporate Services Ltd. has a dedicated banking & compliance team with a working relationship with licenced EMIs in Malta. For more information to open an account with an EMI in Malta, kindly contact

New Update on Satabank

The MFSA has just issued another notice concerning the release of further funds of personal account holders held at Satabank. Over the past couple of weeks Satabank has contacted all personal account holders resident in Malta with deposits between €50 and €15,000. It will now start contacting non-resident personal account holders with balances between €50 and €15,000. This will be done on a staggered basis subject that clients provide the relevant information on a risk based approach.

Satabank has been working closely with the MFSA and other authorities to safeguard the interests of customers as it continues to fulfill all its capital and liquidity requirements.

Click here for the MFSA notice to find out more.

Update re Satabank status

The MFSA has just issued two other notices concerning SATA, relating to the release of customer funds and the setting up of the Corporate Hardship fund managed by the Malta Enterprise. As of this Monday the 26th of November, local Satabank customers with balances ranging from Eur 50 to EUR 15000 and who have gone through a review procedure will have their funds released first. Alternative arrangements will be made for those customers who are not residents of Malta. The Corporate Hardship Fund will be made accessible to Satabank Corporate Clients with employees resident in Malta to cover predominantly verifiable salary bills. Read the attached MFSA notices to find out more.

Updated on Satabank 22.11.2018 – Satabank Public Notice 23.11.2018

Author: Helga Moran, Senior Banking Administrator, Banking Department