An own license means the company is itself authorized by its financial regulator to hold or move money. A partner license means a licensed institution holds that regulated activity and the company runs the product on top of it. In Latin America the dividing line is who holds customer funds and who answers to the central bank. It decides how fast the first customer arrives and who carries the risk.
The choice is made per country and per product, so most payments companies end up with a mix. The Brazil regulation guide has the wider picture.
What is the difference between an own license and a partner license?
It is about where the regulated activity sits, not the brand. Under an own license, the company applies, meets the capital and governance rules and answers to the regulator. Under a partner license, the partner holds the authorization and the accounts, the company contracts for access, and the regulator looks first at the partner.
The three structures a payments company can run, by who holds the authorization and who answers for the funds
Structure | Who holds the authorization | Who answers to the regulator for the money | What the company carries |
Own license | The company | The company | Application, capital floor, governance, AML program, supervision |
Partner license | A licensed partner | The partner, with the company inside the partner's contract | Product, brand and customers, plus a contract with the partner |
Both | The company in one market or product, a partner in the rest | Whoever holds the authorization where the money sits | Two sets of obligations and a clear map of which applies where |
Lumx's answer differs by country: in Brazil, the Lumx entity filed for its own authorization as a virtual asset service provider, in the US it holds its own FinCEN registration as a money services business, and the fiat accounts in Mexico, Colombia, Europe and the UK sit with banking partners that hold the license.
When a payments company needs its own license
The trigger is what the company does with other people's money. These activities call for an authorization, the company's or a partner's:
holding customer balances in local currency
issuing e-money or prepaid instruments
taking deposits or lending from its own balance sheet
initiating payments from accounts that sit elsewhere
exchanging, transferring or holding virtual assets for third parties
In Brazil, holding balances in reais is a payment institution activity under Resolution BCB 80/2021 (Art. 3), and providing virtual asset services to third parties needs the authorization of Law 14.478/2022 (Art. 5). The neobank license guide sorts the cases, and the PSAV explainer covers the virtual asset side. In Mexico, the matching type is the IFPE (Institución de Fondos de Pago Electrónico), a company authorized by the CNBV (Mexico's banking and securities regulator) to issue, administer, redeem and transmit electronic payment funds through the acts in Article 22 of the Fintech Law.
A company paying its own suppliers through an authorized provider needs none of these.
Lumx handles this at onboarding. KYB (know your business, the verification of a company and its owners) asks every customer to disclose what it does with funds. The docs treat money services, payment processing and virtual asset providers as high-risk, with Enhanced Due Diligence, and prohibit unlicensed money services, so a company that needs an authorization and has neither its own nor a partner's is turned away.
What does a partner license cover, and where does it stop?
A partner's license covers the partner's own authorized activities, for the parties the partner has onboarded and can see. It stops in three places: money pooled for people the partner never verified, activities outside the partner's authorization such as lending or deposits, and any virtual asset leg handled by a counterparty that is not authorized.
The rule in Brazil shows the shape. The Central Bank's rules for Pix (Brazil's instant payment system) let a participant hire third parties by a specific contract, and the participant stays directly responsible for what they do (Pix Regulation, Art. 90, §3). Article 90-A limits which parts of Pix can be assigned to a third party.
The nested payments rule in the Lumx docs draws the same line from the provider side: a Lumx account cannot process, facilitate or transmit payments for any party whose identity or activity Lumx cannot see. A marketplace onboards each seller as its own customer and collects its fee through a partner fee. A payroll provider has each employer hold its own account. A structure that looks nested needs written approval from compliance@lumx.io.
How Brazil, Mexico and Colombia split the question
Each market licenses a different thing, so ask per leg.
What each market licenses for fiat and for virtual assets, and the partner type behind a partner model
Market | Regulator | Fiat balances and payments | Virtual assets | Partner type used for the local account |
Brazil | Central Bank of Brazil (BCB) | Payment institution (Resolution BCB 80/2021) or bank | SPSAV (Sociedade Prestadora de Serviços de Ativos Virtuais, the company type that holds a PSAV authorization), under Law 14.478/2022 and Resolution BCB 520/2025 | Banking partner behind named BRL accounts |
Mexico | CNBV and Banxico | IFPE, authorized by the CNBV | No virtual asset license: Banxico decides which assets institutions may operate with | IFPE |
Colombia | Superintendencia Financiera | Entities it supervises, such as a compañía de financiamiento | Crypto-asset rules, not a stablecoin law | Compañía de financiamiento, through a sponsored program |
In a sponsored program (FBO model), the partner opens accounts in the clients' names under its own license. The Colombia guide and the Mexico guide explain the local rules, and the local entity guide and the multi-currency accounts guide cover whether a foreign company needs one to hold accounts.
Lumx's docs say an account is issued by a banking partner, in the customer's name where available, and the partner holds the funds. BRL, MXN, EUR and GBP accounts are named in the customer's own name and active right after approval. SPEI (Mexico's instant payment system) carries the MXN one. The COP leg runs under the banking partner's license, through its sponsored program, and not under one of Lumx's own. The operator map shows which regulated entity handles which step, and supported countries lists where Lumx onboards.
Time and capital in Brazil
An own license costs capital and calendar time before the first customer. A partner license costs the partner's standards and a contract, and approval time depends on the partner. The figures are Brazil's only.
In Brazil, the capital floor for a payment institution comes from Joint Resolution 14 of November 3, 2025: R$2 million for each category of operational activity reported, plus R$5 million when the services depend on data and network infrastructure, capped at R$10 million for that component, plus an activity-based portion. For time, Resolution BCB 81/2021 sets no number for a payment institution. For a bank, Resolution BCB 108/2021, rewritten by Resolution BCB 594 of September 30, 2026, caps the decision at 540 days from a complete file. For an SPSAV, the BCB has up to 360 days for phase one and 720 for phase two.
Lumx targets a one-business-day KYB review. BRL, MXN, EUR and GBP accounts activate right after approval, a USD account takes up to one business day, and an API integration takes two to three weeks to reach go-live.
Model fit by kind of company
Typical fit by company profile, a starting point for counsel
Company | What it does with funds | Usual fit | Why |
Neobank launching in one market | Shows balances, may issue cards | Partner license first | The partner holds the accounts while the product finds its shape |
Marketplace paying sellers | Splits buyer payments between sellers | Partner license, every seller onboarded | Funds stay in each seller's own account |
Payment processor for many merchants | Moves funds for merchants it onboards | Own license, or a written structure approved by the partner | It is the intermediary the regulator looks at |
FX broker or remittance company | Exchanges and transmits for the public | Own license | The activity is the regulated one |
Company paying its own suppliers | Moves its own money | Neither, a licensed provider | It is the provider's client |
App that lets users hold stablecoins | Holds or converts virtual assets for users | Authorized provider, or own authorization | Article 5 of Law 14.478 may reach the app itself |
I recommend that a payments company entering a Latin American market start on a partner's license and file for its own only when the product shows which accounts it must run itself. The reason is sequence: the capital floor and governance work come due before the first user, and a partner lets the user arrive first. Before signing I would ask for the account holder of record on each balance, what the partner needs from your onboarding and monitoring, and what happens to the balances if the partnership ends. A company that cannot answer the third has not chosen a model yet.
A neobank can be a Lumx customer without its own BCB authorization when it runs on a licensed partner, and each of its users onboards as a Lumx customer with their own KYC (know your customer, the verification of an individual).
When a partner license is the wrong tool
A partner license is the wrong tool when the product must hold or lend money beyond the partner's authorization. A payment institution partner does not take deposits, so a product that promises interest needs a bank partner or a bank of its own.
It is also the wrong tool when one partner is the only path: if it loses its license or its own bank, every flow stops, so the contract needs an exit sequence and a second route for key corridors. And it is wrong when the company is the intermediary, because a processor moving funds for merchants its partner has never seen can amount to acting as an unlicensed payment institution, because the facts of the flow decide, not the contract label.
An own license is the wrong tool when the company only pays its own suppliers or collects its own sales, or when volume does not justify a capital floor.
Under the nested payments rule, a customer that routes funds for parties Lumx has not onboarded is rejected or suspended under the nested payments rule, and the standard contract covers the sequence for returning funds on exit, export of history and addresses, and a liability cap.
What to ask a partner before you build on its license
Which legal entity holds which authorization, in which country, for which activity?
Who is the account holder of record on each balance, and whose name does the payee see?
What does the partner need from your onboarding and monitoring, and who files the reports?
What happens to your balances and flows if the partnership or the partner's authorization ends?
Does the contract give the regulator access to your documents and let the partner end it, as Pix Regulation Art. 90 §2 requires of a Pix participant's third parties?
Is there a second partner for the corridors you cannot lose?
Lumx answers the first questions in public: the entity for each leg is on the operator map, the docs say accounts are issued in the customer's name where available, and a transaction RFI (request for information, a compliance hold that asks for a document before a transaction clears) opens a 24-hour window.
What own and partner licenses look like inside Lumx
Lumx is stablecoin payments infrastructure for businesses that move money between Latin America and the rest of the world: one API to collect, hold, convert, and pay out in BRL, MXN, COP, USD, EUR, and GBP or in USDC and USDT, over local rails such as PIX, SPEI, PSE, Bre-B, ACH, FEDWIRE, SEPA, and Faster Payments, with SWIFT and on-behalf-of payments and collections (POBO and COBO) in USD, EUR, and GBP, plus named virtual accounts, custodial wallets, and KYB/KYC built in.
In Brazil the entity is Lumx Sociedade Prestadora de Serviços de Ativos Virtuais Ltda. It acts as a virtual asset service provider, filed its SPSAV authorization request with the Central Bank on October 27, 2026, and operates under the Article 88 transition regime of Resolution 520/2025 until the BCB decides. The filing is not an authorization. A third-party custodian contracted by Lumx holds the virtual assets, and Lumx is not a bank.
For fiat, Lumx works through banking partners. The Mexican partner is an IFPE and the Colombian one a compañía de financiamiento, and in Europe and the UK the banking partner is an EMI authorized by the FCA and a financial institution authorized by the MFSA. In the United States, Lumx launches with a sponsor bank, which the sponsor bank guide covers. Lumx US OP LLC is a FinCEN-registered money services business (MSB), a federal registration filed within 180 days of establishment and renewed every two years.
What the customer sees is a named virtual account (a local account number issued in the customer's own name), a wallet and a KYB file, and the partner's license stays behind the account. The VASP explainer covers the international category.
Methodology and sources
Lumx's behavior comes from docs.lumx.io pages on nested payments, prohibited activities, accounts, POBO and COBO and supported countries, read on November 6, 2026. The IFPE definition and the Article 22 reference come from the CNBV page on financial technology institutions, read on November 6, 2026, and the MSB filing terms from FinCEN's registration page, read the same day. The Brazilian norms (Resolutions BCB 1 (the Pix Regulation, Art. 90 and 90-A), 80, 81, 108, 520, 594, Joint Resolution 14 and Law 14.478/2022) come from the texts read for our neobank license and PSAV explainer guides on November 1 and 6, 2026, because bcb.gov.br serves only a JavaScript shell to a plain request. The Mexico and Colombia rows of the market table rest on the two linked regulation guides (the Mexico guide verified November 1, 2026, the Colombia guide September 25, 2026). Lumx's entity details come from the footer of lumx.io.
Verified on November 6, 2026. Operational context, not legal, tax, or investment advice. Mexican electronic payment fund institutions checked against the CNBV page on November 6, 2026. FinCEN MSB registration checked against fincen.gov on November 6, 2026.
Cover photo: Nhan Hoang on Unsplash.
What is the difference between an own license and a partner license?
An own license makes the company the regulated party: it applies, meets the capital rules and answers to the regulator. A partner license lets a licensed institution hold the regulated activity while the company builds the product and carries a contract with that partner. Lumx works both ways: it has filed its own Brazilian authorization request and holds its own US MSB registration, and the fiat accounts run on banking partners' licenses.
Can a company start on a partner license and get its own later?
Yes, and it is the common path: the partner holds the accounts while the product shows which activities the company must run itself. Lumx's Brazilian entity operates under the Central Bank's transition regime while its filing is reviewed, with partners behind the fiat accounts.
Does a partner license cover everything a payments company does?
No. It covers the partner's authorized activities for the parties it has onboarded. Pooling money for parties the partner cannot see, lending or deposits outside its authorization, and virtual asset legs with unauthorized counterparties fall outside it. The Lumx nested payments rule bars moving funds for parties Lumx has not onboarded, unless compliance approves the structure in writing.
Who answers to the central bank when a company runs on a partner's license?
The partner answers for the activity it is authorized to carry out. In Brazil, the Pix Regulation keeps a participant directly responsible for the third parties it hires (Article 90, paragraph 3) and Art. 90 §2 makes the contract give the BCB access to the third party's documents, a Pix rule and not a general one. On Lumx, the customer is onboarded under KYB and the banking partner holds the funds and runs the rails.
Do you need your own license to pay suppliers with stablecoins?
Not when the company pays its own suppliers through an authorized provider, because it is the provider's client. A company that lets its own users hold or convert stablecoins may need an authorization of its own or an authorized provider behind it. At Lumx, a company pays its own suppliers from its wallet after KYB.
