Overview of Icelandic Financial Services Licensing
Iceland offers opportunities for electronic money and FinTech businesses within a jurisdiction known for its advanced digital infrastructure and favorable conditions for technology-intensive operations. The Financial Supervisory Authority of Iceland (Fjármálaeftirlitið - FME) oversees financial services licensing, applying standards aligned with European Economic Area requirements.
Iceland has gained attention in the FinTech sector for its low electricity costs and robust internet infrastructure, which have attracted cryptocurrency mining operations and technology businesses to the country.
Regulatory Framework
Icelandic financial services regulation derives from EEA harmonization requirements:
EEA Financial Services Directives: Iceland implements EU financial services directives through its EEA membership, including the Electronic Money Directive and Payment Services Directives.
Icelandic Financial Services Legislation: Domestic laws implementing EEA requirements and establishing FME supervisory authority.
Central Bank Regulations: The Central Bank of Iceland (SeĂ°labanki ĂŤslands) maintains currency controls and monetary policy oversight that affect certain financial services activities.
Data Protection: As an EEA member, Iceland applies GDPR-equivalent data protection requirements.
Important Regulatory Considerations
Currency Restrictions
The Icelandic Central Bank maintains restrictions on exporting the national currency (Icelandic krĂłna). Companies engaged in cryptocurrency or cross-border financial activities should understand these restrictions and their implications for proposed business models.
GDPR Compliance
Companies working with EU/EEA residents must implement comprehensive data protection measures:
- •Compliance with personal data protection legislation
- •Maintenance of data processing registers
- •Data Protection Officer appointment where required
- •GDPR-compliant privacy policies
- •Privacy impact assessments for high-risk processing
- •Technical and organizational data protection measures
Licensing Process
Step 1: Company Establishment
Establish a company under Icelandic law with appropriate corporate structure for financial services activities.
Step 2: Banking Arrangements
Open a local bank account with an Icelandic financial institution for operational and capital purposes.
Step 3: Compliance Framework Development
Prepare required compliance documentation:
- •AML/CFT policies and procedures
- •Internal registers and controls
- •Risk management framework
Step 4: Business Planning
Develop comprehensive business documentation:
- •Detailed business plan
- •Financial projections
- •Operational procedures
- •Technical infrastructure plans
Step 5: Management Requirements
Ensure management meets professional standards:
- •Qualified directors with relevant experience
- •Fit and proper declarations
- •Organizational structure documentation
Step 6: Authorization Application
Submit complete application to FME:
- •Formal application for issuer status
- •Documentation of currency issuance rights (if applicable)
- •Supporting compliance documentation
Step 7: Operational Implementation
Upon authorization:
- •Implement payment processing systems
- •Establish operational infrastructure
- •Begin supervised operations
Services Under Icelandic Authorization
Depending on authorization type, licensed institutions may provide:
Electronic Money Services
- •Electronic money issuance
- •Redemption services
- •Distribution through authorized channels
Payment Services
- •Payment account operations
- •Transaction processing
- •Payment instrument issuance
Capital Requirements
Capital requirements apply based on the type and scope of authorized activities. Specific requirements are determined by FME based on the applicant's proposed business model and risk profile.
Compliance Obligations
Anti-Money Laundering
Licensed institutions must implement AML/CFT frameworks:
- •Customer identification and verification
- •Transaction monitoring
- •Suspicious activity reporting
- •Record keeping
Data Protection
- •GDPR-equivalent compliance
- •Data subject rights procedures
- •Security measures
- •Breach notification procedures
Ongoing Reporting
- •Regulatory returns to FME
- •Financial reporting
- •Compliance monitoring
Advantages of Icelandic Licensing
Infrastructure
- •Low electricity costs
- •High-speed internet infrastructure
- •Advanced digital government services
EEA Market Access
- •Access to EEA markets through passporting arrangements
- •Alignment with EU financial services standards
Technology Focus
- •Established cryptocurrency and FinTech presence
- •Technology-friendly business environment
- •Skilled technical workforce
Business Environment
- •Stable political and economic environment
- •Transparent regulatory framework
- •English widely spoken in business contexts
Practical Considerations
Currency Regulations
Understand Central Bank currency restrictions before finalizing business models, particularly for cross-border or cryptocurrency-related activities.
Professional Support
Engage appropriate local expertise:
- •Icelandic legal counsel familiar with FME requirements
- •Compliance specialists
- •Local accounting support
Language
While English is widely used in Icelandic business, certain regulatory submissions may require Icelandic language documentation.
Banking Relationships
Establishing corporate banking facilities requires standard due diligence. Early engagement with Icelandic banks advisable.
Conclusion
Iceland offers opportunities for electronic money and FinTech businesses within an EEA-aligned regulatory framework. The jurisdiction's advanced infrastructure and technology-friendly environment attract businesses, particularly those with energy-intensive operations.
Success requires understanding Iceland's specific regulatory environment, including currency restrictions and EEA compliance requirements. Companies should engage appropriate Icelandic professional support and ensure their business models align with local regulatory expectations.