top of page

About Us


The EMI specialist in Dormant Funds Management and Wind-Down Assurance.

Innovation in E-Money Institutions (EMIs) has been impressive. However, too many EMIs are failing to meet the standards that the FCA demands. FCA Dear CEO letters highlight inadequate wind-down plans and poor supervision of Agents & Distributors.

Wind-down planning is not easy and requires an effective facility to be available when dormant funds and card breakages are involved.

Green Swan has developed the next-generation Regulatory Audits as a Service (RAaaS) to improve Agent and Distributor supervision, and solutions that work in real life with dormant funds under a wind-down situation.

You need us if you are:

  • EMI or EMI principle looking to improve yourself or Agent and Distributor supervision 

  • EMI Agent or Distributor trying to evidence your operations are up to standard

  • EMI with dormant funds and want a wind-down plan that will work in real life.

You have dormant funds
with wind-down exposure:

You are in remediation, or

We are passionate about compliance, fighting organised crime and delivering the commercial benefits that result from this. Too many organisations unnecessarily fail to deliver on the regulatory agenda because they lack the audit insight that would allow them to focus on the right things rather than 'boiling the compliance ocean'. 

We have developed RAaaS that can also be used as a health check or internal audit to give you a 10x improvement on your Compliance, AML & CTF spending.


RAasS gives you patented* digital tools and algorithums to see where the key issues are. Allowing your teams to 'do the right things' as well as 'doing things right'. 

* Patent Number 20060206287 



We are a team of experienced EMI practitioners, technologists and compliance experts.

We have extensive first-hand experience in launching new EMI businesses and day2day EMI operations from start-ups to global enterprises

We are well-versed in the challenges of operating as an EMI principle with Agents and Distributors, and the practical limitations of being an Agent.

bottom of page