How a SKY7 mandate runs

Regulators licence activities, not ideas - so scoping starts with what your product actually does with client funds and ends with one recommended route. The biggest decision is usually new authorisation versus buying a company that already holds the licence: speed, scope fit, history and banking survival all cut differently depending on the model. We run both routes side by side before you commit to either.

Scoping is also where we ask for the full UBO chain on day one. Ownership opacity is the number-one killer of both applications and acquisitions later in the process - surfacing it in week one costs a conversation; surfacing it in a regulator's question round costs months.

The dossier is judged on whether it describes your business, not whether it exists. Template and AI-generated AML programmes reliably trigger regulator follow-up rounds - FINTRAC's pre-registration clarifications are the clearest example - because the policies do not match the declared service categories or the real transaction flow. We draft every policy from your actual flow of funds, which is slower to write and much faster to approve. The pattern shows up on every route: see where Canadian MSB applications get stuck.

Entity formation, capital arrangements and document collection run in parallel here, so the file is complete when it is filed - the statutory review clocks below only start on a complete application.

Statutory review windows are measured from a complete application, and they stop whenever the regulator asks for more information. That is how the Bank of Lithuania's three statutory months become nine to twelve real ones, and how MiCA's 25-plus-40 working days become six to twelve months in practice - the mechanics are laid out in why three months becomes twelve.

We plan for at least one full round of regulator questions on every application, draft the responses with you, and treat response speed as the one timeline factor we fully control. Key-person interviews are prepared the same way: your responsible officers rehearse the file they will be examined on.

Most published licensing timelines end at approval. Real launches end at working accounts - and banking runs one to three months on most routes, so leaving it until after authorisation quietly adds a quarter to the plan. Safeguarding arrangements are also assessed as part of the application itself: an EMI file without a credible safeguarding plan is an incomplete file. How new institutions actually get those accounts is covered in the safeguarding-account guide.

Our sequence: safeguarding and operating accounts are scoped while the file is being drafted, two to three candidate banks per jurisdiction are introduced during the regulator's review, and onboarding runs in parallel - so approval day and launch day are the same quarter, not two different years.

A mandate ends one of two ways. For new authorisations: the licence is granted, reporting calendars are set, and you take over a working compliance file - not a folder of templates. For ready-made transfers the ending is a regulatory step in its own right: buyer due diligence, then regulator notification or prior change-of-control approval depending on the regime, then handover of the entity with its compliance file.

The regime sets the tempo. Under notification-based regimes a clean file typically closes in one to two weeks. Where prior approval is required - the UK's section 178 notice runs a statutory 60 working days, EU qualifying-holding assessments up to 60 working days, both interruptible by information requests - the regulatory window dominates the deal timeline. The full mechanics are in how change of control actually works.