Advisory on Electronic Financial Business Registration and New Payment Service Launch

A fintech company preparing a settlement service based on payment data engaged us for advice on whether the new service was subject to electronic financial business registration, and if so, under which business category it should register.

Under the plan as originally drafted, the company would have had to satisfy the requirements of two business categories simultaneously, and the resulting capital and staffing requirements exceeded the company's early-stage business plan. Rion redesigned the flow of funds, and confirmed that restructuring so that settlement funds did not pass through the company's own account would allow the service to launch under a single business category registration.

We revised the terms of service, outsourcing agreements, and internal control standards to align with the restructured setup, then submitted the registration application. Two rounds of supplementary requests were raised during the review process, and the service ultimately launched one quarter ahead of the original schedule.

Responding to financial regulation is not about drafting good documents—it is about redrawing the business structure into a form regulators can read. Legal review costs the least when it is built in from the planning stage.