FintechMarket first
First PSD2-style payment institution licence in Azerbaijan
When Azerbaijan’s 2023 Law on Payment Services brought EU-style licensing to the market, there was no precedent to follow. We guided Token Azerbaijan through the process, and the company received the first payment institution licence under the new law.
- Client
- Token Azerbaijan (Odero)
- Regulator
- Central Bank of Azerbaijan
- Licence granted
- May 2024
- Jurisdictions
- Azerbaijan, Türkiye, the Netherlands, Romania
Why it mattered
Neither the regulator nor the market yet knew how the new requirements would apply. We drew on EU PSD practice to build a model that fitted the client’s product, and our proposals helped the Central Bank refine its licensing requirements for later applicants.
What we did
- Restructured own funds and increased charter capital to meet the capital requirements
- Replaced the collective executive body with a sole manager
- Drafted the full policy set: governance, internal control, risk management, AML, data protection and fraud prevention
- Adapted KYC, card storage and transaction flows to the new rules
- Gathered and prepared corporate documents from three foreign jurisdictions