I want to tell you about a market that changed faster than almost anyone saw coming.
In 2017, you could launch a securities brokerage in Europe for under a million euros. A regulated Lithuanian EMI - the kind of entity that lets you move money across borders legitimately - could be acquired for under €350,000. The fintech space felt genuinely open. Not easy, but open. The kind of open where a well-organised small team with the right idea could actually compete.
That window closed. And it closed quickly.
"When Zitadelle AG started in 2017, there were a lot of start-ups in Europe for fintech businesses because the entry prices were not huge," says Aleksandr Kazak, one of the firm's directors. "Now the prices for a new start-up application plus staff costs have risen above €2-3 million - ideally €5 million - and Lithuanian EMI companies cost from €2-3 million to acquire, plus associated costs." The sister HR platform HRFinease grew out of exactly this environment - as the compliance and staffing costs rose, so did the need for proper people infrastructure alongside the licensing work.
What happened in between? The simple answer is: Revolut. Wise. N26.
When Scale Changes Everything
When companies operating at that level entered European markets and started competing aggressively on price, distribution, and brand - the economics for smaller operators collapsed. The cost of maintaining regulatory standing in a tier-one European jurisdiction, staffing a compliance function, keeping up with reporting requirements - none of it made sense anymore at sub-scale.
The natural response was to look elsewhere. Less saturated jurisdictions. Markets where entry costs were lower and the regulatory environment more accessible.
It worked, sometimes. But it introduced a different problem.
"Foreign markets are sometimes easier to enter," Kazak notes, "but due to lack of regulation or market practice, some operations are left in the grey area - resulting in regulatory friction." Moving jurisdiction to reduce costs can be the right call. Moving jurisdiction without proper guidance tends to trade one set of problems for another.
Diversification as Survival
Zitadelle AG's own trajectory tells the story of the market it operates in.
The firm started helping clients with licenses in Labuan, Malaysia, Mauritius, and Cyprus. It now covers Curaçao, Estonia, the UK, and the Netherlands - each expansion driven by where client demand was actually moving, not where it had been. A fintech marketplace at financiallicensemarket.com rounds out the offering, giving entrepreneurs a transparent view of what regulated structures are actually available and at what cost.
The broader point is this: the consultancies that have survived this shift aren't the ones that mastered one jurisdiction or one license type. They're the ones that stayed close enough to the market to move when the market moved.
In fintech, that's not a strategy. It's a survival requirement.