Last Reviewed in November 2022
Licence
The company is licenced in their target market countries
Regulatory authority warnings or fines
The company should not be subject to fines or warnings. If the company has been subject to fines or warnings, then it must demonstrate a proper action plan and/or remediation taken to address these issues
Fit and proper management and owners
Company management and owners must have a trustworthy background and sufficient experience (e.g. in finance, AML etc.) to properly manage the risks involved
The management's background should be validated through public sources
Ownership structure and UBOs
Company ownership structure and UBOs must be reasonable and understandable, in particular, any complex structures involving offshore entities, trusts, funds etc
Bearer shares in ownership structure are prohibited
Sufficient staffing and office(s)
The company should have operational offices sufficiently staffed with competent personnel.
The establishment country and office location of the company should be logical and clear.
Public background
If the company is already operational, it should have trustworthy public information, such as a proper website, and social media profiles (Twitter, Linkedin etc.).
AML / KYC policies
The company should have proper AML / KYC policies which refer to their actual business, customers and risk mitigation in place.
Screening /monitoring solutions
The company should have deployed adequate software solutions to ensure sufficient sanctions and PEP screening and transaction monitoring of its customers
In particular, crypto service providers should have deployed crypto-specific blockchain monitoring tools
Crypto service providers
Crypto-specific blockchain monitoring tools must be deployed
Coin acceptance policy needs to be in place
Facilitating the exchange of anonymous cryptocurrency (e.g. Monero) is prohibited
Unlicenced facilitation of security tokens is prohibited (tokens that have characteristics akin to traditional securities instruments like shares, debentures or units in a collective investment scheme)