We advised SIA IBC INVEST on its successful authorisation as an investment firm under the MiFID framework in Latvia. The project involved navigating a highly demanding regulatory authorisation process, which is generally regarded as one of the most complex licensing processes in the financial services sector, second only to obtaining a credit institution licence. The engagement covered comprehensive legal and regulatory support throughout the licensing process, including regulatory analysis, the preparation of licensing documentation, and engagement with Latvijas Banka.

The investment firm licence represents a significant milestone for the client and marks the first successful investment firm licensing project for the Sorainen Latvia team. It was also our first genuine “from zero to hero” mandate in this field, taking the client from an initial business concept all the way to a fully authorised and operational investment firm, and allowing us to demonstrate our exceptional know-how and experience in investment platforms. The project is also one of the first of its kind for Sorainen on a pan-Baltic level.

SIA IBC INVEST is now authorised to provide the following investment services:

  • reception and transmission of orders in relation to one or more financial instruments,
  • execution of orders on behalf of clients,
  • dealing on own account,
  • portfolio management,
  • placing of financial instruments without a firm commitment basis.

And the following ancillary investment services:

  • holding of financial instruments,
  • provision of services related to the underwriting of financial instruments.

Supporting a complex licensing process

The project required comprehensive legal, regulatory and compliance support across all key aspects of the investment firm authorisation process, including MiFID, corporate governance, capital adequacy, AML/CTPF and sanctions compliance, risk management, and ICT governance.

Our services included advising on the business model and licensing strategy, preparing the application package and supporting documentation, developing governance and compliance frameworks, drafting MiFID, DORA and AML/CTPF-specific policies and procedures, coordinating communication with Latvijas Banka, and assisting the client in addressing the regulator’s comments and requests.

Ieva Narbute, CEO of SIA IBC INVEST, comments: “The investment firm licence is the foundation on which we can build a successful and sustainable fintech business. Getting there is not only a matter of ambition, but of meeting very detailed regulatory expectations, and having experienced legal counsel beside us throughout the process made the difference. The Sorainen team understood both the regulatory framework and our business, and guided us through every step of the authorisation.”

Ramona Miglāne, partner at Sorainen, adds: “Every new licensed investment firm strengthens the fintech ecosystem in Latvia and across the Baltics. Helping clients to move from an idea to a fully authorised and well-governed financial institution is exactly the kind of work that builds a deeper, more competitive and more trusted financial market here, and we are glad to support ambitious clients on that path.”

Santa Rubīna, counsel at Sorainen and the lead of the project, notes: “A licensing process of this scale succeeds or fails on project management. It brings together regulatory analysis, governance, capital, AML/CTPF, ICT and a constant dialogue with the regulator, and all of it has to move in parallel and to a clear timeline. Keeping the workstreams, the client’s team and Latvijas Banka’s expectations aligned was central to reaching the result.”

Our team

The project was led by our counsel Santa Rubīna, together with a partner, Ramona Miglāne. The core team also included senior associates Edvīns Draba, Jevgēnija Ziņģe, Ieva Prūse, of counsel Mārtiņš Rudzītis, counsel Inese Heinacka, lawyer Krišjānis Cercens and assistant lawyers Annika Līze Valtere, Annija Kuzma and Evija Velvele.