Counsel for the
regulated edge of
digital finance.

Context

Advising fintech and payments companies through the full lifecycle of obtaining authorisation as a payment institution before the National Bank of Romania (BNR) — an active, ongoing process spanning end-to-end regulatory structuring and execution.

The challenge

Bridging the gap between how a business actually operates and how the supervisor assesses risk, control and compliance — translating the client's operational, technical and governance setup into the regulatory "language" the regulator expects, while preserving the underlying business model.

My role & approach

• Designing the licensing strategy and the regulatory positioning of the business model
• Drafting the authorisation file — internal procedures and policies, organisational and governance documents, safeguarding arrangements, outsourcing and key contractual frameworks
• Aligning internal processes with EU regulations, national implementing legislation and supervisory practice
• Representing clients before BNR through meetings, written exchanges and follow-up clarifications
• Managing iterative supervisory requests and calibrating solutions to meet regulatory expectations

Focus

• Consistency, credibility and regulatory trust maintained throughout the authorisation process

Context

A Web3 venture set out to issue an e-money wallet and a Mastercard debit card, bridging crypto assets and everyday spending. The structure spanned an e-money institution, card schemes, national payment processors, AML/KYC providers and a crypto-asset service provider (CASP).

The challenge

Aligning a novel digital-asset proposition with established payments regulation, while orchestrating approvals across multiple regulated entities and two national supervisors.

My role & approach

• Led legal structuring, contract and terms-of-use drafting and negotiation across all parties
• Liaised extensively with the National Bank of Romania to expedite the approval process
• Coordinated with the CASP's regulatory teams and their EU national supervisor

Outcome

• Regulatory alignment achieved and legal risk mitigated across the partnership
• Apple Pay and Google Pay integration secured for the debit card

Context

A Romanian tech company needed formal certainty that its reloadable prepaid gift card — usable within a limited retail network — fell outside payment services and e-money legislation.

The challenge

The limited-network exclusion is narrow and fact-sensitive. Getting it wrong would have triggered full licensing obligations; getting it confirmed required convincing the regulator on first principles.

My role & approach

• Led the legal analysis and regulatory strategy against EBA Guidelines and the national transposition of PSD2
• Drafted the contractual and operational documentation supporting the exclusion

Outcome

• Obtained a formal positive opinion from the National Bank of Romania confirming the card falls outside scope
• Enabled lawful market entry of a closed-loop gift card across multiple shopping malls

Context

A client wanted to stand up an online card acquiring business and an alternative payment methods (APM) offering from scratch — serving low-, medium- and high-risk industries, including travel/airlines and gambling.

The challenge

Designing contractual and licensing structures that satisfied card scheme rules and payment-services law across very different risk profiles — without forcing merchants into licensing they could avoid.

My role & approach

• Built the contractual acquiring infrastructure for card payments and APMs
• Structured Payment Facilitator models — as both sponsor and PayFac — under Visa and Mastercard rules
• Designed split-payment models letting marketplaces avoid licensing obligations
• Opened safeguarding and settlement accounts with local and international banks

Outcome

• A compliant, scalable acquiring and APM capability ready for local and international processing

Context

Payment institutions seeking authorization, and an e-money institution facing re-authorization, all needed to align with PSD2, national law and applicable EBA Guidelines.

The challenge

Re-shaping live operations to meet new requirements within a fixed regulatory timeframe, while keeping the regulator engaged and confident.

My role & approach

• Provided end-to-end strategic counsel through the authorization process
• Reviewed existing operations, identified adaptation gaps, and formulated compliance roadmaps
• Maintained transparent liaison with the national regulator to expedite review

Outcome

• A successful re-licensing for the e-money institution and a clear path to authorization for the payment institutions

Context

Ahead of MiCA entering into force, an e-money issuer and blockchain stakeholders explored issuing stablecoins and e-money tokens (EMTs) in a compliant way.

The challenge

Building a credible compliance position on a regulation that was not yet in force — interpreting MiCA alongside EMD2 and PSD2 to design something that would survive the regulator's later scrutiny.

My role & approach

• Conducted comprehensive research aligning EMT issuance with MiCA, EMD2 and PSD2
• Designed regulatory-compliant business propositions and an actionable issuance plan
• Developed a foundational compliance framework for the next development phases

Outcome

• A defensible compliance foundation and readiness for substantive discussions with the regulator

Context

A US–EU fintech and technology company wanted to operate as a card program manager in Europe and globally, which required securing two transformative banking sponsorships.

The challenge

Navigating the intricate landscape of card-issuing sponsorships while satisfying both regulatory requirements and the standards of Visa, Mastercard and UnionPay.

My role & approach

• Led negotiation, contract drafting and regulatory compliance across the sponsorships
• Built the legal framework enabling card-issuing services across Europe and beyond

Outcome

• The client extended its financial products to a global customer base with scheme-compliant structures in place

Context

A fintech innovator and a Romanian banking institution partnered to deliver Cash-to-Card and Card-to-Card transactions (Visa Direct / MoneySend), integrated with a large self-service terminal network and a dedicated mobile app.

The challenge

Aligning two very different organisations — and their risk appetites — behind one compliant, durable commercial structure.

My role & approach

• Structured, negotiated and helped maintain the strategic partnership
• Drafted the contracts, terms and conditions underpinning transparency and accountability

Outcome

• Regulatory compliance secured and the partnership's value proposition maximised for all parties

Context

Several payment service providers needed authorization to provide payment services to gambling organizers in Romania — permits issued by the National Office for Gambling (ONJN).

The challenge

Coordinating multiple parallel authorization tracks through a specialised regulator with exacting expectations.

My role & approach

• Managed the full authorization process from information-gathering to compliance strategy
• Built a constructive working relationship with the regulatory authority

Outcome

• Necessary permits obtained, enabling the providers to serve gambling organizers lawfully

Context

An e-money institution sought a Visa Principal Membership license covering both card issuing and card acquiring.

The challenge

Meeting Visa's stringent membership requirements while satisfying regulatory mandates in parallel.

My role & approach

• Guided the institution through the Principal Membership process end-to-end
• Provided strategic counsel improving its compliance posture and operational readiness
• Liaised with Visa to address inquiries and maintain transparent communication

Outcome

• A strengthened path to Visa Principal Membership for issuing and acquiring