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Where to establish Crypto exchange licensed?

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lrotter

Active Member
Hello All!
After new regulations in Estonia with their financial authority they require personal visits of UBO/AML officer to meet the regulator.
It makes impossible for the companies with "hired" UBO to be registered.
Any suggestions where to register LICENSED crypto exchange instead?
 

Sols

Staff member
Mentor Group Gold
If you want to stay within EU, you might want to take a look at Malta and their regime for licensing. But expect having to set up an office in Malta with actual employees. The MFSA and the law firms acting as compliance checkers for virtual currency licenses like on-site visits and audits.

A license isn't just something sensible jurisdictions throw around to anyone who passes a few checkboxes and pays the application fee. To some degree, the jurisdiction is staking its reputation on licensed entities being real businesses.

The same goes for other jurisdictions that license crypto, such as Japan and Philippines.

I always question the validity of a financial services business which can't present its UBO and show a real operation. What are you hiding and why?

It's one thing to hide UBO from open public record, but to disclose it to the government should be fine for any financial service provider.
 

OffCap

Active Member
If you can't have someone visit in person that sounds like a nonstarter. If you're using a hired UBO pay for them to travel.

This being said an interesting upcoming option is San Marino, which is working on a new regime. Otherwise do you need to be in Europe? What's the objective of the set up?
 

lrotter

Active Member
Yes, we need to stay on Europe, as offshore licensing (eg. Seychelles) gives a lot of trouble during operations and applications to any providers.
The UBOs we have will not pass the interview with the regulator, this is our main concern.
 

Sols

Staff member
Mentor Group Gold
If your UBOs can't pass screening by a regulator, you're not going to get a license in EU.

Unless you go for the dodgy solution of hiring someone else to act as UBO. I'm not talking about a mere nominee. This is illegal and can land you in some hot water, but it's not entirely uncommon for shady UBOs to put up a front. The screening processes for crypto licenses thus far have not as diligent as those for financial institutions, so you might get by for a while.
 

bothe

Corporate Services
Business Angel
Entrepreneur
Hello All!
After new regulations in Estonia with their financial authority they require personal visits of UBO/AML officer to meet the regulator.
It makes impossible for the companies with "hired" UBO to be registered.
Any suggestions where to register LICENSED crypto exchange instead?
What's the problem to go there in person????
 

LicensedBison

New member
There are those options already. Also, your "nominee director/aml officer" most probably gets asked to visit the FIU in Estonia because he has a weak CV, holds this position in various companies (even worse) or your AML policies/ Website / Structure is somewhat shady. So its better to invest money into a director and AML, hire those properly, pay those proper salaries and let them be part of your team/company. If you want to be licensed, you also want to have a team on ground.
But on the other side: Honestly speaking, I dont see a problem to give your "nominee director" a crash course in Crypto Assets or AML processes. It will pay off.
 

LicensedBison

New member
Hello All!
After new regulations in Estonia with their financial authority they require personal visits of UBO/AML officer to meet the regulator.
It makes impossible for the companies with "hired" UBO to be registered.
Any suggestions where to register LICENSED crypto exchange instead?
Also, I'd say it depends on your budget. I saw here Malta, which has comparably expensive overheads. Estonia, is probably still one of the easier jurisdictions, if you have someone who is leading you through the process. Hit me up if you have questions about that
 
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