Our Financial Services and Compliance team advised CommonSign on obtaining a payment institution licence for the account information services (AISP) only. The AIS, which allows customers to see their payment accounts information in one app, is launched as a new type of payment service under PSD2. Instantor, the first authorised AISP in Sweden, is the most well-known player in this area. While the AISP only license issued to CommonSign is just the second license of such type issued by the Bank of Lithuania.
The company’s target market is B2C sector and further ambitions to offer to B2B clients. CommonSign will employ artificial intelligence and machine learning in their business model and will offer AIS across the EU. The end-user will give to CommonSign an explicit consent to obtain and process his or her raw transactional account data through the CommonSign engine and receive a limited view on a selection of the calculated aggregated information indicators.
As Sigita Adomaitytė, the head of the Financial Services & Compliance practice group, reveals it has been quite challenging to explain the unconventional business model of CommonSign to the Bank of Lithuania, however our team has successfully addressed all questions raised by the supervisory authority. Our work included drafting of the application documents and representation of the company in the Bank of Lithuania, yet this project is memorable because of the need of employ other than legal drafting skill such as negotiations, business acumen and financial literacy.