1) "We would like to raise three issues of concern in relation to implementation of the CRS and
FATCA in Lithuania, specifically the scope of the law as it applies to Electronic Money Institutions
(“EMIs”), Payment Institutions (“PIs”), and electronic money (“e-money”) and unregulated
payment products issued by Credit Institutions (“CIs”), which we consider to be out of scope of
the CRS and FATCA." EMA letter to Lithuanian Ministry of Finance regarding FATCA and CRS | Electronic Money Association
So lithuanian EMI = no CRS
2) "This supports the view that e-money is not a deposit for the purposes of the CRS and FATCA
not only when the funds are held by an EMI but also when the funds are held by any electronic
money issuer, including a CI. The funds held in e-money accounts are small amounts, usually in
order of €30, and this tends to be the same, regardless of which type of institution the account is
with, i.e. a CI or an EMI." EMA letter to Lithuanian STI regarding FATCA and CRS | Electronic Money Association
2) UK EMI = Obviously = see letters from 1 & 2 = So WISE = No CRS
3) Malta = CRS "Entities that issue payment cards that can be pre-loaded with funds to be spent later, such as a pre-paid credit card or “e-money” are considered to be Depository Institutions. (https://cfr.gov.mt/en/inlandrevenue...Financial Account Information_Version 4.2.pdf) = Blackcatcard = “Entities that issue payment cards that can be pre-loaded with funds in excess of $50,000 to be spent at a later date, such as a pre-paid cards or “e-money” are to be considered to be Depository Institutions
4) According to CRS-related Frequently Asked Questions = It is true
FATCA in Lithuania, specifically the scope of the law as it applies to Electronic Money Institutions
(“EMIs”), Payment Institutions (“PIs”), and electronic money (“e-money”) and unregulated
payment products issued by Credit Institutions (“CIs”), which we consider to be out of scope of
the CRS and FATCA." EMA letter to Lithuanian Ministry of Finance regarding FATCA and CRS | Electronic Money Association
So lithuanian EMI = no CRS
2) "This supports the view that e-money is not a deposit for the purposes of the CRS and FATCA
not only when the funds are held by an EMI but also when the funds are held by any electronic
money issuer, including a CI. The funds held in e-money accounts are small amounts, usually in
order of €30, and this tends to be the same, regardless of which type of institution the account is
with, i.e. a CI or an EMI." EMA letter to Lithuanian STI regarding FATCA and CRS | Electronic Money Association
2) UK EMI = Obviously = see letters from 1 & 2 = So WISE = No CRS
3) Malta = CRS "Entities that issue payment cards that can be pre-loaded with funds to be spent later, such as a pre-paid credit card or “e-money” are considered to be Depository Institutions. (https://cfr.gov.mt/en/inlandrevenue...Financial Account Information_Version 4.2.pdf) = Blackcatcard = “Entities that issue payment cards that can be pre-loaded with funds in excess of $50,000 to be spent at a later date, such as a pre-paid cards or “e-money” are to be considered to be Depository Institutions
4) According to CRS-related Frequently Asked Questions = It is true
