Business · Chapter 08
Introducers: what they can and can't do
An introducer can help you find the right door and knock on it properly. They cannot walk through it for you - due diligence is never "skipped" through an introducer, and nobody can guarantee approval.
~3 min
The issue
In the EMI/neobank world, "introducers" (referral agents, business introducers) refer clients to an institution in exchange for a commission. The regulated entity that actually performs KYC/AML is always the EMI or bank itself; registered agents operate under its regulatory responsibility; distributors and introducers sit outside that perimeter - approved by the institution, but not regulated at EU level.
Why institutions ask
An experienced introducer can add real value when your profile is complex - multi-jurisdiction, an articulated corporate structure, a sector that's legal but borderline. They can help translate your business model into language a compliance team will understand, and point you toward institutions whose risk appetite realistically fits. What they cannot do, ever: guarantee approval, change AML/KYC rules, or hide relevant information. Final due-diligence responsibility always sits with the institution - a poorly prepared, undocumented, or inconsistent profile can be rejected with an introducer in the room.
What usually helps
The work in this plan - a clear description, consistent documents, a coherent website - is what actually gets you through, with or without an introducer. This module is educational only: it doesn't recommend introducers, and checking which institutions' published criteria fit your profile is what the eligibility wizard is for.
Your actions
If I work with an introducer, I understand they can't guarantee approval or bypass due diligence - and I haven't been asked to omit or alter any information.
Only relevant if you're considering an introducer - mark it not applicable otherwise.
These become trackable items in your checklist once your personalized plan is generated.