How to send money internationally: choosing the right regulated route

Defining the use case

Before selecting a regulatory route, it is essential to define precisely what the product does. The relevant questions are: does the product hold a balance on behalf of users, or does it only transmit? Does it handle crypto assets at any point in the transaction chain? In which countries does it accept senders, and in which countries does it pay out?

The answers to these questions determine which of the four primary routes — PI, MSB, EMI, or crypto — applies. Each route has a distinct regulatory basis, capital requirement, and geographic scope.

PI route: payment services without stored value

A Payment Institution (PI) authorisation under PSD2 is the standard EEA route for firms that execute payment transactions, initiate payments, or provide money remittance services without issuing e-money (stored value).

A PI-licensed firm can send money domestically and cross-border across the EEA through passporting. Outside the EEA, it must rely on correspondent relationships or local registrations. The PI route does not cover crypto asset transfers. If users can hold a redeemable balance in the product, an EMI authorisation is required instead.

MSB route: money transmission and exchange

Money Services Business (MSB) registration is the standard route in the United States, Canada, and a number of other jurisdictions for money transmission, currency exchange, and remittance. In the US, MSBs must register with FinCEN and obtain money transmitter licences in each state where they operate.

MSB registration is generally faster and less capital-intensive than PI or EMI authorisation, but it does not carry passporting rights. Operating in multiple jurisdictions requires separate registrations. In Canada, MSBs must register with FINTRAC and are subject to AML/ATF reporting obligations.

EMI route: wallet and stored-value products

If the product holds a user balance — a top-up wallet that users can spend from and withdraw — then the correct EEA route is an EMI authorisation, not a PI. The legal distinction is that the balance constitutes electronic money, and issuance of e-money is exclusively an EMI permission.

EMI authorisation requires a minimum of €350,000 in own funds and a safeguarding structure for the float. It carries EEA passporting rights and covers all PI services plus e-money issuance. It does not cover crypto asset transfer or exchange.

Crypto routes: VASP, CASP, and crypto MSB

If the remittance product handles crypto assets at any point — even as an intermediary in a crypto-to-fiat corridor — a crypto regulatory licence is required in addition to (or instead of) a PI or EMI authorisation.

In the EEA, the relevant framework is MiCA, which requires CASP (Crypto Asset Service Provider) authorisation for firms providing crypto transfer or exchange services. Outside the EEA, VASP registration requirements vary by jurisdiction. In Canada, crypto MSBs register with FINTRAC alongside their general MSB registration.

A standard PI or EMI licence does not cover crypto asset transfer. Operating crypto corridors without the appropriate licence creates significant regulatory and AML risk.

Choosing between routes

Select PI if: your product sends fiat without holding a float; you are operating in the EEA; and you do not handle crypto. This is the standard route for remittance, payment initiation, and cross-border payment execution in the EEA.

Select MSB if: your primary markets are the US, Canada, or other MSB-regime jurisdictions; you are doing money transmission or currency exchange; and you do not need EEA passporting.

Select EMI if: your product has a user-facing wallet or stored-value balance; users can top up and withdraw; and you are operating in the EEA.

Select a crypto route if: your product handles crypto assets as part of the transfer or conversion flow — regardless of the end currency. Crypto routes may be in addition to PI, EMI, or MSB, not instead of them.