1 Legal and enforcement framework

1.1 In broad terms, which legislative and regulatory provisions govern the fintech space in your jurisdiction?

There is no specific legislation which governs the fintech space in North Macedonia. Fintech companies are subject to the legislation and regulations that apply to financial services companies. Fintech companies that carry out any of the regulated financial activities under the Financial Companies Act 2010 or the regulated payment services activities under the Payment Services Act 2007 must be authorised by the Ministry of Finance or the National Bank of the Republic of North Macedonia (NBRM) respectively. Regulated activities under the Financial Companies Act include the provision of loans, the issue and administration of credit cards, factoring and the issue of guarantees. Regulated activities under the Payment Services Act include issuing and distributing ‘e-money' (an electronic equivalent to cash) and intermediary services for making micro-payments.

Fintech companies are also subject to consumer protection, privacy and data protection, cybersecurity and anti-money laundering legislation, including the Data Protection Act 2020, the Consumer Protection Act 2004 and the Prevention of Money Laundering and Terrorist Financing Act 2018.

In 2019 the government prepared a draft Payment Systems Act which seeks to implement several EU legislative instruments, including:

  • the Second EU Payment Services Directive (2015/2366/EU);
  • the Second E-money Directive (2009/110/EC);
  • the EU Settlement Finality Directive (98/26/EC); and
  • the Payment Accounts Directive (2014/92/EU).

The new Payments Systems Act, which should be adopted in 2020, will be the principal legislative instrument governing the fintech space.

1.2 Do any special regimes apply to specific areas of the fintech space?

Currently, there is no special regime which applies to fintech companies in North Macedonia. Until the new Payment Systems Act is enacted (please see question 1.1), fintech companies are subject to the legislation and regulations that apply to financial services companies.

1.3 Which bodies are responsible for enforcing the applicable laws and regulations? What powers do they have?

The Ministry of Finance is responsible for oversight of financial services companies; while the NBRM is responsible for oversight of banks, e-money issuing companies and companies that act as intermediaries for micro-payments. Both the Ministry of Finance and the NBRM have vast supervisory and enforcement powers, including the power:

  • to make periodic inspection visits to financial companies/banks;
  • to request financial companies/banks to provide specified information or documents;
  • to issue warning notices;
  • to suspend the carrying out of particular activities temporarily; and
  • to impose financial penalties.

The Agency for Data Protection (ADP) is responsible for oversight and enforcement of the data protection legislation. The ADP is empowered to impose administrative penalties on a data controller/processor in breach of the rules of up to 4% of its annual worldwide turnover in the preceding financial year.

The Financial Intelligence Office (FIO) oversees the implementation of the anti-money laundering and terrorist financing legislation. The FIO is empowered to collect, process and provide information, and to impose fines on entities that are responsible for implementing know-your-customer procedures.

1.4 What is the regulators' general approach to fintech?

Both the Ministry of Finance and the NBRM are generally supportive of the fintech sector, recognising that the introduction of open banking will increase competition in the market by driving innovation in financial services and products. In particular, the NBRM recognises that the development of the fintech sector is required to open up a market that is currently dominated by complex pricing structures, difficulties in comparing products and consumer switching, and disproportionally high charges for consumers. In 2019 the NBRM launched the Innovation Gateway, a platform for communication between the fintech sector, the NBRM and other relevant supervisory and regulatory institutions. The primary purpose of the NBRM's Innovation Gateway is to facilitate, encourage and promote the development of innovation in the fintech sector. Fintech companies can use the platform to obtain from the NBRM legally non-binding guidance and guidance on existing regulatory requirements. Also, fintech companies can use the platform to make proposals to the NBRM for changes in legislation to remove or reduce any regulatory constraints on the introduction of new innovative services.

1.5 Are there any trade associations for the fintech sector?

There is no overarching trade association for the fintech sector. Alternative lending providers, as a dominant force in the fintech sector, have established the Alternative Financial Services Association of North Macedonia (AFSANM). The AFSANM represents alternative lending companies and other non-banking lending organisations that provide financial services to Macedonian consumers. Its mission is to create reliable and responsible industry practices, aimed at long-term cooperation with and positive assessment by consumers and market monitoring institutions, while at the same time explaining to the general public the various opportunities that alternative financial services can provide for the development of individuals and society as a whole.

2 Fintech market

2.1 Which sub-sectors of the fintech industry have become most embedded in your jurisdiction?

The most embedded subsector of the fintech industry in North Macedonia is alternative lending. The ability of alternative lending companies to utilise technology and provide efficient and effective lending services to underserved individuals has allowed them to successfully penetrate the retail lending market. Alternative lenders offer some significant advantages over banks and other conventional financing options, including a straightforward application process which is far less rigorous than that for bank loans and fast turnaround times, in terms of both approval and funding delivery. Alternative lenders are also generally more flexible in the packaging of loans and financing options in comparison to banks.

2.2 What products and services are offered?

Fintech companies generally offer customers a variety of loan options, including lines of credit, short-term loans, instalment loans, merchant cash advances and microloans.

2.3 How are fintech players generally structured?

Fintech players are generally structured as limited liability companies. A limited liability company is by far the most common business vehicle in North Macedonia. The main advantages of a limited liability company include the following:

  • The members/shareholders have no liability for the company's debt above the amount payable to the company when the shares are issued (nominal value).
  • Transfer of ownership is easily effected by the sale/transfer of shares.
  • Any changes to the company's ownership, details and objectives can be easily and promptly completed by electronic means.
  • Investors are usually willing to invest in limited liability companies because of their familiar capital structure and legal framework

2.4 How are they generally financed?

Generally, fintech players are financed through a combination of private equity and loans. Additionally, the government provides financing through the state-owned Fund for Innovation and Technology Development, which offers a variety of grants to innovative start-ups.

The European Union provides financing to innovative start-ups through the Western Balkans Enterprise Development & Innovation Facility (WB EDIF), a joint initiative of the European Union, international financial institutions, bilateral partners and the public institutions of the Western Balkans economies. WB EDIF offers two equity funds, one aimed at early-stage innovation companies (the Enterprise Innovation Fund (ENIF)) and one at later-stage companies in their expansion phase (Enterprise Expansion Fund (ENEF)). ENIF is a venture capital fund focusing on an investment portfolio consisting of innovative small and medium-sized enterprises (SMEs) at various stages of business development, from the seed to expansion phase, and is managed by South Central Ventures. ENEF is managed by the European Bank for Reconstruction and Development and is focused on the financing of established SMEs with high growth potential to support the development and expansion of their businesses.

2.5 How are they positioned within the broader financial services landscape?

Alternative lending companies dominate the fintech sector. They have steadily penetrated the banking industry, posing a significant threat to the incumbent banks. However, the incumbent banks remain the most innovative players in the financial services sector. Most incumbent banks have developed innovative products and services such as personal finance management applications, mobile applications and accounting services.

2.6 Do start-ups generally outsource back office functions and is there a developed market for them to access? What are the legal implications of outsourcing?

In North Macedonia, there is no developed market for outsourcing back-office functions. Therefore, start-ups have very few options to choose from.

3 Technologies

3.1 How are the following key technologies in the fintech space regulated and what specific legal issues are associated with each? (a) Internet (e-commerce); (b) Mobile (m-commerce); (c) Big data (mining); (d) Cloud computing; (e) Artificial intelligence; and (f) Distributed ledger technology (Blockchain, cryptocurrencies)

(a) Internet (e-commerce)

The Macedonian legislation governing e-commerce is dispersed in several different statutory instruments; some of these are specific to e-commerce, while others apply to all business activities. The following regulations are of particular significance:

  • The Electronic Commerce Act 2007 obliges operators of commercial websites, in particular, to provide customers with specific information about the operator and the services.
  • The Consumer Protection Act 2004 governs distance selling and unfair terms in consumer contracts. It prohibits various unfair practices by traders, such as misleading actions or omissions, and include a ‘blacklist' of prohibited commercial practices.
  • The Data in Electronic Form and Electronic Signatures Act 2001 governs electronic signatures. An electronic signature is data in an electronic form that is attached to or logically associated with other data in an electronic form and that is used by the signatory to sign.
  • The Electronic Communications Act 2014 governs direct marketing (both solicited and unsolicited) through electronic communication.
  • The Data Protection Act 2020 regulates the collection and processing of personal data by any company which collects and processes personal data, including operators of websites.

(b) Mobile (m-commerce)

M-commerce is subject to the same regulations as e-commerce (please see question 3.1).

(c) Big data (mining)

The term ‘big data' refers typically to high-volume, high-velocity and high-variety assets that demand cost-effective, innovative forms of information processing for enhanced insight and decision-making. Big data is derived by next-generation data mining techniques that use more data, faster processing and new software. Examples of big data include internet searches, credit card purchases, mobile phone traffic and location data, and data collected by vehicle sensors and wearable computing devices.

If big data involves the processing of personal data which has not been anonymised or has been pseudonymised (allowing the identification of an individual in conjunction with other data), such processing is subject to the Data Protection Act 2020. In such cases, it is important to establish the role played by the different actors involved in such processing. The qualification of actors and the distinction between a ‘controller' and ‘processor' can quickly become complicated in a big data context. Correctly assessing whether an organisation is a controller or a processor in the context of big data is therefore critical to the structuring of the relationship and to the allocation of risk and responsibility under the Data Protection Act 2020. The principal concern is that the mapping of the data value chain can be rather burdensome if there are many actors involved.

(d) Cloud computing

Cloud computing is not subject to any specific regulation. However, cloud operators must ensure compliance with regulations on consumer protection, privacy and data protection, cybersecurity and anti-money laundering legislation, just like e-commerce operators.

(e) Artificial intelligence

Artificial intelligence (AI) is not subject to any specific regulation. AI deploys machine learning to use big data to perform tasks commonly associated with human beings. Machine learning is a set of techniques that allows computers to learn by creating mathematical algorithms based on accumulated data. Accordingly, any use of AI will generally raise data protection and security concerns.

(f) Distributed ledger technology (Blockchain, cryptocurrencies)

Distributed ledger technology (DLT) is not subject to any specific regulation. The National Bank of the Republic of North Macedonia (NBRM) recognises the potential of blockchain and DLT to disrupt the financial industry. As the Macedonian legislation is technology neutral, there are no obstacles to the development and deployment of blockchain-based solutions. The trading of cryptocurrencies is also unregulated and, in the absence of specific regulation, the NBRM has advised banks and the general public that trading in cryptocurrency is prohibited. According to the NBRM, as cryptocurrencies are not backed by legal authority and are marked by high-value volatility and rather illiquid non-regulated markets, they cannot be treated as a unit of account and store of value.

4 Activities

4.1 How are the following key activities in the fintech space regulated and what specific legal issues are associated with each? (a) Crowdfunding, peer-to-peer lending; (b) Online lending and other forms of alternative finance; (c) Payment services (including marketplaces that route payments from customers to suppliers (eg, Uber and AirBnb); (d) Forex; (e) Trading; (f) Investment and asset management; (g) Risk management; (h) Roboadvice; and (i) Insurtech.

(a) Crowdfunding, peer-to-peer lending

Acting as an intermediary in crowdfunding and peer-to-peer lending is an unregulated activity. Companies that engage in such activities must ensure compliance with the requirements under consumer protection, privacy and data protection, cybersecurity and anti-money laundering legislation.

(b) Online lending and other forms of alternative finance

Lending to consumers is a regulated activity and companies that intend to engage in such activities must be authorised by the Ministry of Finance. Such companies must also ensure compliance with the requirements under consumer protection, privacy and data protection, cybersecurity and anti-money laundering legislation.

(d) Forex

A foreign currency exchange service is a regulated activity in North Macedonia which may be provided only by a bank or financial institution.

(e) Trading

Trading is a regulated activity which must be authorised by the Macedonian Securities Exchange Commission. Trading must be conducted on the Macedonian Stock Exchange (MSE) – the only regulated stock exchange in North Macedonia, which acts as a central marketplace for the admission and trading of equity, debt and other securities.

In 2014, to facilitate integration with other Southeast European markets, the MSE – together with the Bulgarian Stock Exchange and the Croatian Stock Exchange – established SEE Link. SEE Link is a special purpose business vehicle which operates an electronic system for order routing between stock exchanges in Southeast Europe. The principal objective of SEE Link was to integrate regional equities markets without merger or corporate integration, using only technology that enables participating stock exchanges to remain independent, yet complementary, and that affords investors a more accessible, more efficient approach to these markets through a local broker. Today, SEE Link has a combined equity market capitalisation of more than $50 billion, allowing order routing of almost 1,200 securities listed on exchanges in Bulgaria, Bosnia and Herzegovina, Croatia, Macedonia, Serbia and Slovenia.

(f) Investment and asset management

Investment and asset management is a regulated activity which must be authorised by the Macedonian Securities Exchange Commission. Fintech companies must ensure compliance with all sector-specific requirements to engage in the management of investments and assets.

(g) Risk management

Banks and financial services firms are subject to risk management rules and internal control requirements. These requirements will also apply to fintech companies.

(h) Roboadvice

There are no specific regulations applicable to roboadvice companies under Macedonian law. If a roboadvice company provides advice in any of the regulated activities, it will be required to obtain proper authorisation.

(i) Insurtech

Insurance (life and non-life) is a regulated activity in North Macedonia which must be authorised by the Insurance Supervision Agency (ISA). The ISA is authorised to oversee and issue authorisations to insurance brokerage companies, insurance agencies, insurance brokers and agents. Insurance companies generally offer insurance online and there are a few start-ups which provide data analysis in the insurance sector.

5 Data security and cybersecurity

5.1 What is the applicable data protection regime in your jurisdiction and what specific implications does this have for fintech companies?

The processing of personal data is regulated by the Data Protection Act 2020, which entered into force on 25 February 2020. The act is harmonised with the General Data Protection Regulation and applies to all entities that process personal data of individuals residing in North Macedonia, including foreign entities that offer goods or services to individuals in North Macedonia or monitor the behaviour of individuals in North Macedonia. The enforcement of the Data Protection Act is overseen by the Agency for Personal Data Protection (ADP).

To ensure compliance with the Data Protection Act, fintech companies must consider the following:

  • They must determine whether they process personal data in the capacity of a controller or a processor. Under the act, controllers and processors have different statutory obligations. However, they are jointly liable before individuals and the ADP if they fail to comply with their specific obligations.
  • Fintech companies must have adequate policies and procedures in place, and maintain accurate records of processing activities.
  • The consent of individuals to the collection and processing of their data must be specific, informed, unambiguous, verifiable and given freely. Fintech companies cannot infer consent from silence or inactivity. They must separate the consent from other terms and conditions, and provide individuals with simple ways to withdraw their consent. Fintech companies relying on individuals' consent to process their data must ensure that the consent meets the standards of being specific, granular, clear, prominent, opt-in, properly documented and easily withdrawn.
  • Fintech companies must revise existing personal data protection policies and procedures to reflect the new requirement to provide individuals with the right to data portability. The right to data portability applies only to personal data that an individual has provided to a controller, when the processing is based on the individual's consent or for the performance of a contract and when processing is carried out by automated means.
  • Fintech companies must also revise how they communicate their privacy policies and ensure that they contain concise, easy to understand and precise information on:
    • the lawful basis for the processing of personal data;
    • the data retention periods; and
    • the right of data subjects to complain to the ADP if they feel that their data has been mishandled.

The ADP is empowered to impose administrative penalties on a controller/processor in breach of the Data Protection Act of up to 4% of its annual worldwide turnover in the preceding financial year. Additionally, an individual who has suffered harm as a result of the unlawful processing of his or her personal data has the right to seek compensation from the controller or processor for the harm suffered.

5.2 What is the applicable cybersecurity regime in your jurisdiction and what specific implications does this have for fintech companies?

Fintech companies must implement and maintain data security measures that meet the standards required by the financial services regulation and data protection regulation. The financial services regulators (the National Bank of the Republic of North Macedonia (NBRM)) and the data protection regulator (the ADP) have the power to take action in relation to cybersecurity breaches. In broad terms, fintech companies must:

  • have appropriate data security measures in place, including (where necessary) in relation to the back-up of data and regular testing of security;
  • assess security risks relating to the processing or control of data;
  • adhere to the requirements and standards of the NBRM and the ADP relating to the management of risks and controls, business continuity, outsourcing and notification of material events; and
  • depending on the materiality and nature of a breach, notify the ADP and individuals when a cyber breach occurs.

Non-compliance with the cybersecurity requirements of the DPA may result in the imposition of penalties of up to 2% of an undertaking's total worldwide annual turnover.

6 Financial crime

6.1 What provisions govern money laundering and other forms of financial crime in your jurisdiction and what specific implications do these have for fintech companies?

The Prevention of Money Laundering and Terrorist Financing Act 2018 requires fintech companies to conduct customer due diligence (know-your-customer), and to monitor and report suspicious transactions to the Financial Intelligence Office – in particular, where certain transactions involve parties who are based in high-risk countries or exceed a certain threshold.

7 Competition

7.1 Does the fintech sector present any specific challenges or concerns from a competition perspective? Are there any pro-competition measures that are targeted specifically at fintech companies?

Macedonian competition law applies to the fintech sector, as to any other sector. However, since the fintech sector is still in its early stages, the competition authority has not yet reviewed transactions from a merger control standpoint and has not yet investigated fintech companies for potentially anti-competitive behaviour.

8 Innovation

8.1 How is innovation in the fintech space protected in your jurisdiction?

Certain types of innovations and inventions in the fintech space that fall within the categories set out below may be protected under IP laws.

Copyright: Copyright is a significant form of IP right for software, and thus also for innovations and inventions in the fintech space. Copyright comes into existence immediately upon the production of the work in a ‘tangible medium of expression' and is automatically afforded to all works that meet its requirements. There are no formalities under Macedonian law to obtain copyright protection. Copyright protection may extend to certain types of databases if they are original in the sense that, as a result of the selection or arrangement of their contents, they constitute the author's own intellectual creation.

Generally speaking, evidence of copying is needed to demonstrate copyright infringement. It is often difficult to obtain such evidence, because copying source code requires access to the source code. Access to source code is not easy to obtain, because generally executable code is provided and cloud-based deployments are used.

Another critical point is that copyright does not protect against independent development of the same software. If a party independently develops software which has the same functionality as software developed by another party, it cannot use its copyright to prevent that party from going ahead (since there has been no copying).

Database rights: Database rights can protect certain databases which have been compiled using skill and effort. In the fintech field, an example of such a database might be a compilation of price data from a financial exchange, together with event data from news feeds. As with copyright, there are no formalities in North Macedonia to obtain database rights and protection is automatically available if the database meets certain requirements. Database rights can usually be obtained if a substantial investment has been made in obtaining, verifying or presenting the data in a database. The owner of these rights enjoys protection from data being extracted or reused without its consent. However, the data can still be used for non-commercial purposes (ie, scientific research).

Patents: A computer program is not patentable if it does not have the potential to cause a ‘further technical effect', which must go beyond the inherent technical interactions between hardware and software. Consequently, a computer-implemented invention that does not meet this criterion will not meet the general patentability requirements, as inventions in other fields cannot be patented in Europe. In this regard, computer programs and computer-implemented inventions can be patented only if they meet the following criteria:

  • They have a technical character and solve a technical problem;
  • They are new; and
  • They involve an inventive technical contribution to the prior art.

Patents provide protection for 20 years from the date of filing for new inventions, provided that the renewal fees are paid.

Design rights: Design rights can protect the visual elements of a computer program, such as graphics, icons and screen displays. These may be registered and protected.

Trademarks: A trademark can protect a brand or logo for a firm. This can protect against other firms passing off or attempting to copy the branding of a fintech firm. However, it cannot protect the firm's products from being copied. Trademark rights may be renewed indefinitely.

8.2 How is innovation in the fintech space incentivised in your jurisdiction?

The government provides financing to fintech start-ups through the state-owned Fund for Innovation and Technology Development (FITD). The mission of the FITD is to encourage and support the innovation activities of micro enterprises and small and medium-sized enterprises (SMEs), to achieve more dynamic technological development based on knowledge transfer, development research and innovations that contribute to job creation, economic growth and development, while simultaneously improving the business environment for the development of companies' competitive capabilities.

The European Union provides financing to innovative start-ups through the Western Balkans Enterprise Development & Innovation Facility (WB EDIF), a joint initiative of the European Union, international financial institutions, bilateral partners and the public institutions of the Western Balkans economies. WB EDIF offers two equity funds, one aimed at early-stage innovation companies (the Enterprise Innovation Fund (ENIF)) and one at later-stage companies in their expansion phase (Enterprise Expansion Fund (ENEF)). ENIF is a venture capital fund focusing on an investment portfolio consisting of innovative SMEs at various stages of business development, from the seed to expansion phase, and is managed by South Central Ventures. ENEF is managed by the European Bank for Reconstruction and Development and is focused on the financing of established SMEs with high growth potential to support the development and expansion of their businesses.

9 Talent acquisition

9.1 What is the applicable employment regime in your jurisdiction and what specific implications does this have for fintech companies?

The principal employment legislation in North Macedonia is the Labour Act 2005. Under the Labour Act, employees are entitled:

  • to equal treatment and pay;
  • to a statutory notice period of at least one month;
  • not to be unfairly dismissed;
  • to a safe and healthy work environment; and
  • to various types of leave, such as annual leave and maternity leave.

The Labour Act allows employees and employers to agree on a non-compete clause in the employment contract for a period of up to two years. During that time, the employee will receive 50% of his or her salary for observing the non-compete obligation.

9.2 How can fintech companies attract specialist talent from overseas where necessary?

The employment and work of foreigners is governed by the Employment and Work of Foreigners Act 2015. Any foreigner who intends to work in North Macedonia must obtain a temporary residence permit from the Ministry of Internal Affairs. The temporary residence permit is a single integrated permit for both work and residence of foreigners in North Macedonia. Foreigners who have obtained a temporary residence permit for work are allowed to reside in North Macedonia for work only. A temporary residence permit for work may be issued to a foreigner only if the Employment Agency issues a positive opinion that he or she meets the requirements set out in the Employment and Work of Foreigners Act. A temporary residence permit may be issued for up to one year and may subsequently be renewed for up to two years.

A foreign company may temporarily transfer its employees from the location of their permanent employment abroad to a branch office or subsidiary in Macedonia for work. In such case the company must apply on behalf of each transferred employee and obtain a temporary residence permit for him or her. The issue of temporary residence permits to transferred employees is subject to quotas which are set by the government on an annual basis. Additionally, the government has a discretionary right to impose limitations on the number of temporary residence permits issued to foreigners in different categories (eg, job positions, industries or regions and municipalities), if it considers that such limitations would benefit the public and/or commercial interests of the Macedonian labour market. A foreign company that intends to transfer its employees in North Macedonia must also consider the following:

  • Temporary residence permits are granted only to employees who have been employed with the foreign company for at least one year.
  • The temporary residence permits of transferred employees may be renewed for an additional period of up to one year by applying for renewal at least 30 days before the expiry of the temporary residence permits.
  • The foreign company must register the start and the end of the work of the transferred employees with the Employment Agency. The registration should be carried out before the transferred employees begin working.

10 Trends and predictions

10.1 How would you describe the current fintech landscape and prevailing trends in your jurisdiction? Are any new developments anticipated in the next 12 months, including any proposed legislative reforms?

In 2019 the government prepared a draft Payment Systems Act which seeks to implement several EU legislative instruments, including:

  • the Second EU Payment Services Directive (2015/2366/EU);
  • the Second E-money Directive (2009/110/EC);
  • the EU Settlement Finality Directive (98/26/EC); and
  • the Payment Accounts Directive (2014/92/EU).

The draft Payments Systems Act aims to open up the payments market and govern payment-related activities that are currently unregulated. These include money remittance, the operation of a payment account, the execution of payment transactions and the issue or acquisitions of payment instruments. In particular, the draft act covers the following three types of services:

  • account information services, which allow third-party providers to pull digitised transaction data from a payment account that is operated by another payment service provider to give consumers and businesses an overview of their financial situation by consolidating information across the different payment accounts they may have with one or more payment service providers;
  • payment initiation services, which allow third-party providers to initiate a push payment, such as a bank transfer, from an account operated by another payment service provider. This assists consumers in making online payments and informs the merchant immediately of the payment initiation, allowing for the immediate dispatch of goods or immediate access to services purchased online; and
  • the issuance of card-based payment instruments by third-party payment service providers that request confirmation of the availability of funds from the payment service provider servicing the account.

Under the draft act, all third-party payment services providers must be authorised by the National Bank of the Republic of North Macedonia (NBRM), which is empowered to regulate, monitor and supervise their activities. To this end, the NBRM is competent to enact bylaws for technical standards on strong customer authentication and common and secure open standards of communication, as well as regulations on incident reporting and bylaws on security measures for operational and security risks. Parliament is expected to enact the draft act in 2020.

11 Tips and traps

11.1 What are your top tips for fintech players seeking to enter your jurisdiction and what potential sticking points would you highlight?

Fintech companies wishing to enter the Macedonian market should seek guidance on all regulations that will apply to their business and whether they will be required to obtain a licence for their activity. From the very outset, fintech companies should seek guidance on anti-money laundering, data protection and cybersecurity regulations, as the regulatory penalties for non-compliance in these areas can be very high. Also, fintech companies are advised to approach the regulators as early as possible to understand their approach to their particular mode of business.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.