What regulatory licenses are required for a Paraguayan fintech to offer mobile payments and digital wallets?

Hello,

Thank you for your message. I can prepare a focused legal memo addressing the regulatory framework for launching a mobile payments and digital wallet service in Paraguay.

Engagement & Fees

• Billing basis: USD 165/hour.
• Deliverable: Written memo in English, with citations to the applicable Paraguayan laws/regulations and practical compliance steps.
• Optional: A 60-minute Q&A call to discuss the memo’s conclusions (billed at the same hourly rate).

Scope of the Memo

1. Licensing/Authorizations:
o Whether the model qualifies as an e-money issuer, payment service provider, acquirer, or other regulated entity; whether partnering with a supervised financial institution is required; corporate form and fit-and-proper expectations.

2. Registration & Supervision:
o How to register with the financial regulator (process, key forms, timelines, and typical supporting documentation).
o Participation requirements for national payment systems and settlement/operational rules (clearing, safeguarding, float handling).

3. AML/CFT & Sanctions Compliance:
o Applicable AML/CFT framework, risk-based KYC tiers, onboarding/ongoing due diligence, PEP handling, transaction monitoring, STR thresholds/format, record-keeping, audits, and ongoing reporting duties to the competent authorities.

4. Consumer & Data:
o Conduct-of-business obligations (transparency, fees, dispute resolution/chargebacks), terms and conditions essentials, advertising rules, data/privacy and cybersecurity expectations.

5. Tax Touchpoints (high-level):
o Indirect taxes on fees, retention risks, and operational tax considerations (non-tax opinion; flagged items for your tax advisor).

What I Need From You (to tailor the analysis)

• A brief description of the product flows (funding sources, storage, payments, withdrawals, P2P/P2M, remittances).
• Legal entity plan (local company vs. cross-border), target user base (retail/SME), and any bank/processor partners already identified.
• Anticipated launch timeline and jurisdictions of counterparties/vendors.
If this approach works for you, I’ll share a short engagement letter and start upon confirmation.

Please let me know if you would like me to include the Q&A call in the initial scope.

Best regards,