What should I check before buying a UK EMI for a higher-risk payments business?

I would begin with a compatibility review before committing substantial money to the acquisition. The question is whether this particular EMI can support the business you intend to run after completion.

Review the current permissions, restrictions, business plan, and programme of operations. Then compare them with your proposed customers, industries, countries, currencies, and transaction volumes. The FCA's requirements cover governance, management, financial resources, financial-crime controls, and safeguarding, among other matters. FCA EMI requirements

For a higher-risk model, such as payments involving gambling businesses, I would pay particular attention to:

• Whether the compliance team and transaction-monitoring systems can handle the proposed activity.
• Whether the banking and safeguarding partners will support the new model and ownership.
• Which technology, contracts, staff, and operational arrangements are actually included in the sale.
• Whether there are historical compliance issues, liabilities, or remediation costs.
• Whether the proposed changes require further regulatory engagement or changes to permissions.

Existing banking relationships and software should never be assumed to be included or available on unchanged terms. Get the documentation and verify the position.

The acquisition must also follow the applicable FCA change-of-control process, with approval obtained before completion. Build preparation and information requests into the timetable rather than relying only on the formal assessment period. FCA change-of-control guidance

My comparison would include the purchase price, regulatory work, banking compatibility, technology, management, remediation, and time to become operational. A lower-priced EMI that requires rebuilding most of its operation may offer less value than one that already fits your intended business.