Regulatory counsel across the payments lifecycle.
I advise fintech companies, payment institutions and e-money issuers from the first structuring decision through to authorization, launch and ongoing supervision. Engagements range from a single regulatory opinion to leading a full licensing project before the National Bank of Romania.
Payment & e-money institution licensing before the National Bank of Romania.
End-to-end authorization projects — from strategy to a decision from the supervisor — and everything that keeps a licence in good standing thereafter.
Payment institution (PI) authorization
Full authorization projects before the National Bank of Romania (BNR) under PSD2 and its national transposition, including the licensing strategy and the regulatory positioning of the business model.
Electronic money institution (EMI) authorization & re-authorization
New authorizations and re-authorization of existing e-money issuers to meet PSD2, national law and applicable EBA Guidelines.
The authorization file
Preparation of the complete dossier: programme of operations and business plan, internal procedures and policies, governance and organizational documents, safeguarding arrangements, outsourcing framework and key contracts.
Representation before the regulator
Managing the relationship with the BNR throughout — meetings, written exchanges, and structured responses to iterative supervisory requests.
Ongoing supervision & EU passporting
Variation of authorization, changes of control and qualifying holdings, and passporting or notification of activities across the EU.
Designing products and models that fit — or fall outside — the rules.
Deciding early whether an activity is regulated, and structuring it so the answer is deliberate rather than accidental.
Legal qualification of products & business models
Assessing new propositions against PSD2 and the e-money regime to determine whether, and how, they are regulated — before commitments are made.
PSD2 exclusions & scope analysis
Structuring around the limited-network exclusion, gift cards, commercial-agent and technical-service-provider exemptions, and other cases where an activity legitimately falls outside licensing.
Formal opinions from the regulator
Building and presenting the case to obtain a formal confirmation or positive opinion from the National Bank of Romania on regulatory perimeter — as achieved for a closed-loop gift card programme.
Risk mapping & product design
Mapping legal and regulatory risk into the product from the outset, so launches are both scalable and defensible.
Issuing, acquiring, payment facilitation and MiCA-era digital assets.
The scheme rules, sponsorship structures and token frameworks behind modern card and crypto payment products.
Card issuing & acquiring
Issuing and acquiring structures and the requirements of the Visa, Mastercard and UnionPay schemes — including Principal Membership.
Payment Facilitator & program manager models
Structuring PayFac (sponsor and PayFac) and card program manager arrangements, and card-issuing sponsorship with banking partners.
Marketplaces & split payments
Split-payment and marketplace models designed to keep platforms and merchants outside unnecessary licensing obligations.
MiCA, stablecoins & Web3 payments
MiCA-aligned issuance of e-money tokens and stablecoins, CASP partnerships and Web3 wallet/card structures, read against EMD2 and PSD2.
The governance, agreements and sector permits that hold it together.
Keeping a regulated business compliant day to day — and representing it when the regulator asks questions.
AML/KYC & internal governance
Internal policies and procedures, AML/KYC frameworks, and governance arrangements aligned with regulatory expectations.
Ongoing regulatory advisory
Day-to-day counsel on new products and processes, and readiness for regulatory audits, inquiries and investigations.
Contracts & partnerships
Drafting and negotiating terms of use, partnership, acquiring and sponsorship agreements — and maintaining them through the life of the relationship.
Sector authorizations & regulator liaison
ONJN authorization for payment services to gambling operators, and liaison with the BNR, ONJN and industry stakeholders on inquiries and investigations.
Senior counsel from first call to final decision.
Any scope
From a single regulatory opinion or a scope assessment to leading an end-to-end licensing mandate — the engagement fits the question.
Commercially aware
Solutions that satisfy the regulator while preserving the business model, because compliance is the structure that lets a product scale.
Regulator-ready
Work built to anticipate the supervisor's questions — translating operations into the regulatory language the BNR expects.
Tell me where you are in the licensing journey.
tudor.nistor@payments-lawyers.comThis page describes areas of practice and is provided for general information only. It is not legal advice and does not create a lawyer–client relationship. Past matters are described in general terms; client identities and confidential details are not disclosed.