How to obtain a cryptocurrency license in Luxembourg

Regulation of the cryptocurrency market is constantly becoming stricter. Nowadays jurisdictions impose high regulatory and risk management requirements on virtual asset service providers.

Despite this, we always manage to find a solution that suits the client. All the time our team provides research of the market and regulations on various markets to find the best jurisdiction. Not so long ago we have made the global overview of the VASP regulation in EEA and ready to share information with our future and existing clients. Today we will look at the features of obtaining a cryptocurrency license in Luxembourg.

Tax Summary:

  1. Personal income tax – from 0% to 42%
  2. Corporate income tax – 17% and municipal business tax 6.75%  – 10.5%

What law/s governs VASP activities?

  1. The Law of 12 November 2004 on the fight against money laundering and terrorist financing

What activities are included in VASP services?

  1. Exchange between VA and fiat currencies, including the service of exchange between virtual currencies and fiat currencies.
  2. Exchange between one or more forms of VA.
  3. Transfer of VA.
  4. Safekeeping or administration of VA or instruments enabling control over VA. including custodian wallet service.
  5. Participation in and provision of financial services related to an issuer’s offer or sale of VA.

Who is the VASP regulator?

  1. La Commission de Surveillance du Secteur Financier (CSSF)

What is the procedure for registering a VASP for a local company?

Entities established in Luxembourg or providing services in Luxembourg cannot offer virtual asset services without registration with CSSF, as provided for in Article 7-1(1) of the Law of November 12, 2004, “On the Fight against Money Laundering and Terrorist Financing” (“AML/CFT Law”). According to Articles 1(20c) and 7-1(1) of the AML/CFT Law, organizations established or providing services in Luxembourg must register with CSSF if they offer one or more services listed as VASP services on behalf of or for their clients. Any organization, including those already licensed/registered with the competent authority, especially licensed financial institutions, offering or intending to offer any VASP services from March 30, 2020, onward must:

  1. Pre-register as a VASP.
  2. Comply with the professional obligations and conditions outlined in the AML/CFT Law with amendments.  

Procedure:

  1. The registration procedure generally starts with a meeting at the CSSF premises aiming to present the applicant and its project. Depending on the activities of the project, registration as a VASP may be necessary.
  2. In case the applicant submits a formal registration file to the CSSF for registration, it must include all the documents and information required by using the relevant forms made available on the CSSF website (application).
  3. The registration file shall exclusively be provided to the CSSF in an electronic form via the MFT (Managed File Transfer) system of the CSSF, for which the required link will be provided to the applicant by the CSSF (upon request to the following email address ipig@cssf.lu). The CSSF then examines the registration file.
  4. The registration is effective upon inclusion of the applicant in the CSSF register. After the registration has been completed, the registered entity is published in the national public register maintained by the CSSF.
  5. If, after the registration, significant changes to the activities or to the key function holders notified upon registration occur, the registered entity has to immediately inform the CSSF in writing.   

The request for registration to the CSSF shall include the following information:

  1. For an applicant legal person:
    1. The name of the applicant.
    2. The precise address of the central administration of the applicant.
    3. A description of the activities performed, in particular, a list of the types of virtual asset services envisaged and their relevant qualification.
    4. A description of the money laundering and terrorist financing risks to which the applicant will be exposed and the internal control mechanisms established by the applicant in order to mitigate these risks and to comply with the professional obligations defined in this law and in Regulation (EU) 2015/847, or in their implementing measures. 
    5. At least two persons must be responsible for the management of the virtual asset service provider and entitled to effectively determine the policy of the business. These persons shall possess adequate professional experience.

Is there any specific authorization required for a VASP from another EU member state to provide services in this jurisdiction?

Any person, natural or legal, who is established in Luxembourg and/or provides in Luxembourg any of the VA-related services on behalf of customers or for its customers, must register as a VASP in the CSSF register.

What is the liability for the activities of a VASP from another EU member state without local registration/authorization in this jurisdiction?

Pursuant to the Section 2 – Administrative enforcement, Article 8-4 of the Law of 12 November 2004 on the fight against money laundering and terrorist financing

The supervisory authorities have the power to impose administrative sanctions and to take other administrative measures laid down in paragraph 2 with respect to the professionals subject to their respective supervisory powers in accordance with (….) 7-1(2) or their implementing measures, as well as with respect to the members of their executive bodies, effective directors (dirigeants, members of the authorized management) or other persons responsible for the non-compliance by the professionals with their obligations. 

In the event of a breach referred to in paragraph 1, the supervisory authorities shall have the power to impose the following administrative sanctions and to take the following administrative measures: 

  1. A warning.
  2. A reprimand.
  3. A public statement which identifies the natural or legal person and the nature of the breach.
  4. Where the professionals are subject to “registration” or authorisation“, initiate the procedure for” the withdrawal or suspension of that “registration or” authorisation.
  5. A temporary ban, imposed by the CSSF and the CAA, for a period not exceeding 5 years:
    1. To exercise a professional activity of the financial sector or to carry out one or several transactions with respect to the persons subject to their respective supervisory powers in accordance with Article 2-1.
    2. To exercise managerial functions within the professionals subject to their respective supervisory powers in accordance with Article 2-1 with respect to any person discharging managerial responsibilities within such professionals or any other natural person held liable for the breach.
  6. Maximum administrative fines of twice the amount of the benefit derived from the breach, where that benefit can be determined, or EUR 1,000,000 at the most.

Manimama Legal & Growth Agency provides a gateway for the companies operating as the virtual asset wallet and exchange providers allowing to enter to the markets legally. We are ready to offer an appropriate support in obtaining a license with lower founding and operating costs. We offer KYC/AML launch, support in risk assessment, legal services, legal opinions, advice on general data protection provisions, contracts and all necessary legal and business tools to start business of virtual asset service provider.


The content of this article is intended to provide a general guide to the subject matter, not to be considered as a legal consultation. 

How to obtain a cryptocurrency license in Liechtenstein

Regulation of the cryptocurrency market is constantly becoming stricter. Nowadays jurisdictions impose high regulatory and risk management requirements on virtual asset service providers.

Despite this, we always manage to find a solution that suits the client. All the time our team provides research of the market and regulations on various markets to find the best jurisdiction. Not so long ago we have made the global overview of the VASP regulation in EEA and ready to share information with our future and existing clients. Today we will look at the features of obtaining a cryptocurrency license in Liechtenstein.

Tax Summary:

  1. Personal income tax –  3% – 24%
  2. Corporate income tax – 12,5%

What law/s governs VASP activities?

  1. Act on Tokens and TT Service Providers (“TVTG”)
  2. Ordinance on Tokens and TT Service Providers (“TVTV”)
  3. Due Diligence Act (“DDA”)
  4. Due Diligence Ordinance (“SPV”)
  5. FMA Guidelines
  6. Others FMA Instructions and Forms

What activities are included in VASP services?

Virtual asset service providers in Liechtenstein are called TT service providers. Trustworthy technologies (TT) are defined as technologies through which the integrity of tokens, the clear allocation of tokens to a TT identifier, and the transfer of tokens can be ensured.

Pursuant to Article 12 TVTGthe following persons must be registered with the FMA:

  1. Token Issuers: persons professionally offering tokens to the public in the name of third parties (Article 12(1) TVTG). This includes, for example, trading venues that carry out ICOs for their clients. Persons who publicly offer tokens in their own name (own issuance) or who publicly offer the tokens in the name of third parties, but do not do so on a professional basis, must also register if the value of the tokens issued during twelve months exceeds or will exceed CHF 5 million.
  2. Token Generators: persons who create original tokens on behalf of third parties.
  3. TT Key Depositaries and TT Token Depositaries:  persons who safeguard tokens or private keys for third parties, e.g. in a safe or a collective wallet. This also includes the execution of transactions for third parties. These services are typically provided by crypto exchanges or wallet providers.
  4. TT Protectors: persons who hold tokens on TT systems in their own name on account of third parties (note: a license under the Professional Trustees Act is obligatory in this case).
  5. Physical Validators: persons who ensure the enforcement of rights in accordance with the agreement, in terms of property law, to goods represented in tokens on TT systems.
  6. TT Exchange Service Providers: persons who exchange legal tender for tokens and vice versa as well as tokens for tokens. Typically this includes ATMs at which cryptocurrencies can be exchanged, but also persons who offer exchanges against their own book exclusively online.
  7. TT Verifying Authorities: persons who verify the legal capacity and the requirements for the disposal over a token. This includes, for example, services that ensure that only persons of legal age or those with a specific authorisation can purchase certain tokens.
  8. TT Price Service Providers: persons who provide TT system users with aggregated price information on the basis of purchase and sale offers or completed transactions. This includes persons who publish independently calculated prices for tokens.
  9. TT Identity Service Providers: persons who identify the person in possession of the right of disposal related to a token and who record it in a directory.  
  10. TT Agents: persons professionally distributing or providing TT services in the name of and for the account of a foreign TT service provider in Liechtenstein.

Who is the VASP regulator?

  1. Financial Market Authority of Liechtenstein (“FMA”)

What is the procedure for registering a VASP for a local company?

Natural and legal persons who have a registered office or place of residence in Liechtenstein and who wish to provide TT services in Liechtenstein on a professional basis must apply to the FMA for entry into the TT Service Provider Register (Article 23).

To be authorized in the TT register it is necessary to:

  1. Submit an online application which must contain:
    1. The name and address of the company in Liechtenstein.
    2. Information on the type of services the applicant intends to offer.
    3. Information on the legal form of the applicant.
  2. The application must be accompanied by evidence of the existence of the requirements under Articles 13-17:
    1. Proof that the directors are capable of acting independently.
    2. Proof that the directors/shareholders/beneficiaries are reliable and professionally qualified.
    3. Proof that the company has a registered office or the place of residence of the management of the company is in Liechtenstein.
    4. Proof that the company has a minimum statutory capital according to the type of activity the company has chosen (e.g. for TT token custodians €100,000, for physical validators €250,000 , for issuers €250,000).
    5. Evidence that the applicant has an appropriate organizational structure with defined areas of responsibility and a procedure for managing conflicts of interest.
    6. Evidence that the applicant has written internal procedures and controls appropriate to the type, scope, complexity and risks of the translation services provided and ensures that they are adequately documented.
    7. Evidence that the applicant holds an additional license/permit, if such a permit is necessary in view of the services offered.
    8. If requested by FMA, additional information and documents must be provided to the extent necessary to evaluate the application for registration.

The application fee for a single license is €1,500, which is non-refundable if the application is rejected. In the case of an application for several licenses, the first one costs €1,500 and the application for each additional licence costs €700.

Is there any specific authorization required for a VASP from another EU member state to provide services in this jurisdiction?

The Liechtenstein regulator, FMA, indicates that registration under the TVTG is effective exclusively in Liechtenstein, passporting according to the model of European financial market laws is therefore not possible.

If a service provider wishes to operate on a cross-border basis and, for example, advertise abroad or approach clients abroad, the service provider must therefore independently clarify in advance whether the service is subject to licensing in the chosen country.

The FMA’s position applies to VASPs from Liechtenstein but does not apply to VASPs from other EU members. Part 1, Article 12 states that natural and legal persons who have a registered office or place of residence in Liechtenstein must be authorized. Part 3 of the article mentions that foreign persons who wish to offer physical ATM services must obtain authorisation. Other types of services are not explicitly mentioned as requiring authorization for foreign persons. 

The FMA has provided a questionnaire that can help determine whether a person needs a license in Liechtenstein. According to the questionnaire, if neither the headquarters/residence nor the target market (the target market can be determined by the focus of your business – offering advertising to a certain region or citizens of a certain country, offering services exclusively to certain citizens or having privileges for such citizens) are located in Liechtenstein, then it is unlikely that a license or registration will be required.

The above means that a foreign VASP is exempted from the need to obtain authorization from the FMA if it does not have any physical presence in Liechtenstein or its promotional activities/direction are not targeted at the Liechtenstein market.

What is the liability for the activities of a VASP from another EU member state without local registration/authorization in this jurisdiction?

According to Article 47 TVTG the district court shall impose a penalty of imprisonment for a term of up to 1 year or a fine of up to 360 daily rates to any person who:

  1. Provides funds transfer services subject to registration, contrary to Art. 12.
  2. Contrary to Art. 24 uses a designation indicating activity as a provider of TT services.
  3. Received registration as a TT service provider based on false information or other illegal means.
  4. As a provider of TT services systematically and seriously breaches its statutory duties.

In accordance with Article 19 StGB, the daily rate shall be calculated according to the personal circumstances and financial capacity of the offender at the time of the judgment of the court of first instance. However, the daily rate is set at a minimum of CHF 15 (€15) and a maximum of CHF 5,000 (€5,000).


Manimama Legal & Growth Agency provides a gateway for the companies operating as the virtual asset wallet and exchange providers allowing to enter to the markets legally. We are ready to offer an appropriate support in obtaining a license with lower founding and operating costs. We offer KYC/AML launch, support in risk assessment, legal services, legal opinions, advice on general data protection provisions, contracts and all necessary legal and business tools to start business of virtual asset service provider.


The content of this article is intended to provide a general guide to the subject matter, not to be considered as a legal consultation. 

How to obtain a cryptocurrency license in Latvia

Regulation of the cryptocurrency market is constantly becoming stricter. Nowadays jurisdictions impose high regulatory and risk management requirements on virtual asset service providers.

Despite this, we always manage to find a solution that suits the client. All the time our team provides research of the market and regulations on various markets to find the best jurisdiction. Not so long ago we have made the global overview of the VASP regulation in EEA and ready to share information with our future and existing clients. Today we will look at the features of obtaining a cryptocurrency license in Latvia.

Tax Summary:

  1. Personal income tax –  20/23/31%
  2. Corporate income tax – 20%

What law/s governs VASP activities?

  1. Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing (“LPMLTPF“)
  2. Amendments to the Law on Prevention of Money Laundering and Terrorism and Proliferation Financing (“Amendments”)

What activities are included in VASP services?

Section 1 of the LPMLTPF states that virtual currency service provider (“VCSP“)  – the person providing virtual currency services, including the provider of services of exchange of the virtual currency issued by other persons, which provides the users with the possibility to exchange the virtual currency for another virtual currency by receiving commission for it, or offer to purchase and redeem the virtual currency through a recognised legal means of payment.

In addition, Section 1 of the Amendments provides that cryptoasset service provider’ means a person who, in the course of his professional or commercial activity, performs one or more of the following activities on behalf of, or for the benefit of, a client:

  1. The exchange of crypto-assets for currency issued by national central banks.
  2. The exchange between one or more types of crypto-assets.
  3. The transfer of crypto-assets.
  4. Holding or managing crypto-assets or instruments that provide control over crypto-assets.
  5. The provision of financial services and participation in the provision of financial services in connection with an issuer’s offering or sale of crypto-assets.

Who is the VASP regulator?

  1. Latvijas Banka
  2. State Revenue Service (“SRS“)

What is the procedure for registering a VASP for a local company?

In Latvia, there is no specific regulatory framework for establishing cryptoassets business. Additionally, there is no requirement or prohibition on obtaining a cryptolicense.

VCSPs are subjects of the LPMLTPF, meaning that they are required to: 

  1. Register with the SRS as subjects of the LPMLTPF, including appointing a responsible person.
  2. Conduct and document the assessment of the money laundering and terrorism and proliferation financing risks.
  3. Establish an internal control system.
  4. Report unusual and suspicious transactions.

Is there any specific authorization required for a VASP from another EU member state to provide services in this jurisdiction?

Latvian law does not contain any relaxation in the definition of persons who must register with the SRS as obligated persons under the LPMLTPF.

Thus, foreign entities must follow the general registration procedure even if they hold a VASP license issued by another EU member state.

What is the liability for the activities of a VASP from another EU member state without local registration/authorization in this jurisdiction?

Section 78 of the LPMLTPF:

  1. The following sanctions may be imposed on the subject of the LPMLTPF for the violation of the laws and regulations in the field of the prevention of money laundering and terrorism and proliferation financing, including in relation to the customer due diligence, monitoring of the business relationship and transactions, reporting of suspicious transactions, provision of information to the supervisory and control authority or the Financial Intelligence Unit of Latvia, refraining from execution of a transaction, freezing of funds, internal control system, storage and destruction of information:
  • to express a public announcement by indicating the person liable for the violation and the nature of the violation;
  • issue a warning;
  • to impose a fine on a person (natural or legal) liable for the violation in double the amount of the profit obtained as a result of the violation (if it can be calculated) or another fine up to EUR 1 000 000;
  • to suspend or discontinue the activity (including to suspend or cancel the license (certificate) or to cancel the entry in the relevant register, to suspend economic activity, to apply a prohibition on changes in the registration in the commercial register for reorganization of a commercial company and change of shareholders) and to give orders to credit institutions or payment service providers regarding partial or complete suspension of settlement operations of the subject of the LPMLTPF;
  • to set a temporary prohibition on a person liable for the violation to fulfill the obligations specified for him or her by the subject of the LPMLTPF;
  • to impose an obligation to perform certain action or refrain therefrom;
  • to impose an obligation on the subject of the LPMLTPF to dismiss the person liable for the violation from the position held.
  1. If it is laid down in laws and regulations that in order to perform an economic or professional activity it is necessary to receive a special permit, for example, a license, or to register in a register, but the subject of the LPMLTPF has not done it and laws and regulations do not provide for administrative liability for failure to fulfill this obligation, the supervisory and control authority is entitled to apply to the subject of the LPMLTPF the sanctions specified in Paragraph one of this Section.

Manimama Legal & Growth Agency provides a gateway for the companies operating as the virtual asset wallet and exchange providers allowing to enter to the markets legally. We are ready to offer an appropriate support in obtaining a license with lower founding and operating costs. We offer KYC/AML launch, support in risk assessment, legal services, legal opinions, advice on general data protection provisions, contracts and all necessary legal and business tools to start business of virtual asset service provider.


The content of this article is intended to provide a general guide to the subject matter, not to be considered as a legal consultation. 

How to obtain a cryptocurrency license in Italy

Regulation of the cryptocurrency market is constantly becoming stricter. Nowadays jurisdictions impose high regulatory and risk management requirements on virtual asset service providers.

Despite this, we always manage to find a solution that suits the client. All the time our team provides research of the market and regulations on various markets to find the best jurisdiction. Recently we have made the global overview of the VASP regulation in EEA and ready to share information with our future and existing clients. Today we will look at the features of obtaining a cryptocurrency license in Italy.

Tax Summary:

  1. Personal income tax – from 23 to 43%
  2. Corporate income tax – 27.9% 

What law/s governs VASP activities?

  1.  Decree no. 125 of 2019 
  2. Decree no. 90 of 2017 
  3. Decree No. 141 of 13 August 2010
  4. Decree 13 January 2022

What activities are included in VASP services?

Decree 13 January 2022 (art. 1) applies to two categories of activities regarding virtual assets – VASP and e-wallet providers:

  1. VASPs are defined as providers of services related to the use of digital currency, i.e., individuals and legal entities that provide to third parties, online and on a professional basis, services concerning digital currencies. This includes the use, exchange or custody of digital currencies or their conversion into fiat currencies or other digital representations of value, including those convertible into other digital currencies. It also includes the issuance, offer, transfer and offsetting, or any other service useful for the purchase, trade or brokerage of digital currencies.
  2. Digital wallet service providers: i.e., any natural person or legal person who provides third parties, on a professional basis, including online, with services for the safeguarding of private cryptographic keys on behalf of their clients, to hold, store and transfer virtual currencies.

Who is the VASP regulator?

  1. Ministry of Economy and Finance 
  2. Organismo per gli agenti e mediatori (“OAM“)

What is the procedure for registering a VASP for a local company?

In order to legally provide VASP services in Italy, it is necessary to be registered in a special crypto-registry maintained by the OAM. In order to enter the registry it is necessary (for legal entities, in accordance with the Decree of 13 January 2022, art. 3):

  1. Have a registered company (LLC).
  2. Have a physical address of the company (no minimum capital requirements for registration).
  3. Send an electronic application in a satisfactory form to the OAM stating the following:
    • Name of the company.
    • The legal form of the company.
    • Tax code/VAT number, if assigned.
    • Location of the physical address.
    • Surname, name, place and date of birth, tax number, if assigned, and details of the document identifying the legal representative.
    •  E-mail address for communication between the provider and OAM.
    • Indication of the type of activity performed as a service provider (VASP or e-wallet).
    • Indication of the type of services listed in Annex 2.
    • Appointment of a local AML officer.
    • The means of carrying out the service, indicating the number and address of the physical points of activity, while including any ATMs (automated teller machines) and/or online transactions, indicating the web address through which the service is carried out.
  4. The application shall be accompanied by a copy of the document identifying the person, legal representative, as well as the company’s statutory documents.

Is there any specific authorization required for a VASP from another EU member state to provide services in this jurisdiction?

In accordance with the Decree of 13 January 2022, art. 3 – VASP from another EU Member State may provide its services in Italy only after registration in the OAM register under the general conditions, specifics:

  1. VASP with a registered office in another EU Member State does not need to establish a separate legal entity, it is sufficient to have a branch (permanent establishment in the territory of the Republic).
  2. The application procedure is the same as for a local company described in the previous section.

What is the liability for the activities of a VASP from another EU member state without local registration/authorization in this jurisdiction?

In accordance with article 17 of Decree No. 141/2010 VASPs and e-wallet providers that fail to comply with registration requests or rejected applications by the OAM must cease operations.

Otherwise, they will be considered abusive and may face penalties from 2 500 EUR to 10,329 EUR and/or investigation if they continue to operate without registration.


Manimama Legal & Growth Agency provides a gateway for the companies operating as the virtual asset wallet and exchange providers allowing to enter to the markets legally. We are ready to offer an appropriate support in obtaining a license with lower founding and operating costs. We offer KYC/AML launch, support in risk assessment, legal services, legal opinions, advice on general data protection provisions, contracts and all necessary legal and business tools to start business of virtual asset service provider.


The content of this article is intended to provide a general guide to the subject matter, not to be considered as a legal consultation. 

How to obtain a cryptocurrency license in Ireland

Regulation of the cryptocurrency market is constantly becoming stricter. Nowadays jurisdictions impose high regulatory and risk management requirements on virtual asset service providers.

Despite this, we always manage to find a solution that suits the client. All the time our team provides research of the market and regulations on various markets to find the best jurisdiction. Recently we have made the global overview of the VASP regulation in EEA and ready to share information with our future and existing clients. Today we will look at the features of obtaining a cryptocurrency license in Ireland.

Tax Summary:

  1. Personal income tax – from 20% to 4%
  2. Corporate income tax – from 12,5% to 33%

What law/s governs VASP activities?

  1. Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (“CJA“)
  2. Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act 2021
  3. Central Bank of Ireland Instruction Manual and Guidance Note for entities seeking to register as a Virtual Asset Service Provider (“Guidance“)

What activities are included in VASP services?

VASPs are companies that provide the following services:

  1. Exchange between virtual assets and fiat money.
  2. Exchange between one or more types of virtual assets.
  3. Virtual asset transfer (performing a transaction on behalf of another person that moves a virtual asset from one virtual asset address or account to another).
  4. Providing purses for custodians.
  5. Participation in the provision or provision of financial services related to the offer of an issuer or the sale of a virtual asset.

Who is the VASP regulator?

  1. Central Bank of Ireland

What is the procedure for registering a VASP for a local company?

In order to legally provide their services in Ireland, companies need to be authorized on the Central Bank of Ireland’s crypto registry. This requires:

  1. Establish a local company.
  2. Have a registered local office.
  3. One of the senior employees must be physically located in Ireland and act as a point of contact.
  4. Submit a pre-registration form to the Central Bank, the purpose of the form is to contact representatives of the Bank to discuss the provision of services in Ireland.
  5. After meeting with the Bank’s representatives, submit a full registration form, which should include: the firm’s details, including the firm’s proposed VASP activities, business model, structure, and regulatory history, the firm’s shareholdings and senior management, including direct and indirect shareholders, partnerships, and management, information about the AML officer (no residency requirements), information about the contact person, the firm’s AML/CFT governance, including the firm’s risk assessment, policies and procedures/procedures, the firm’s AML/CFT governance, including the firm’s risk assessment, policies and procedures.
  6. The following documents must be attached to the registration statement: AML policies, AML officer CV, proof of the company’s physical address in Ireland, business plan, and individual questionnaire for shareholders and top managers of the company.

Is there any specific authorization required for a VASP from another EU member state to provide services in this jurisdiction?

VASPs from other EU member states are not free to provide their services in Ireland and must register with the Central Bank, have a local office, and at least one local staff member to contact the regulator. The registration procedure is described in the previous section. An additional requirement is that such a VASP must provide proof of registration/license in another EU member state.

What is the liability for the activities of a VASP from another EU member state without local registration/authorization in this jurisdiction?

According to the art. 106E of Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act 2021, conducting business without authorization from the Central Bank is punishable by a fine not exceeding 500 000 euro or imprisonment for a term not exceeding 5 years or both.


Manimama Legal & Growth Agency provides a gateway for the companies operating as the virtual asset wallet and exchange providers allowing to enter to the markets legally. We are ready to offer an appropriate support in obtaining a license with lower founding and operating costs. We offer KYC/AML launch, support in risk assessment, legal services, legal opinions, advice on general data protection provisions, contracts and all necessary legal and business tools to start business of virtual asset service provider.


The content of this article is intended to provide a general guide to the subject matter, not to be considered as a legal consultation. 

How to obtain a cryptocurrency license in Hungary

Regulation of the cryptocurrency market is constantly becoming stricter. Nowadays jurisdictions impose high regulatory and risk management requirements on virtual asset service providers.

Despite this, we always manage to find a solution that suits the client. All the time our team provides research of the market and regulations on various markets to find the best jurisdiction. Recently we have made the global overview of the VASP regulation in EEA and ready to share information with our future and existing clients. Today we will look at the features of obtaining a cryptocurrency license in Hungary.

Tax Summary:

  1. Personal income tax –  15%
  2. Corporate income tax – 9%

What law/s governs VASP activities?

  1. Act LIII of 2017 on Preventing and Combating Money Laundering and Terrorist Financing (“AML Act“)

What activities are included in VASP services?

The following services fall under the scope of the Hungarian AML Act (Section 1):

  1. Providers of exchange services between virtual currencies and fiat currencies, and between different types of virtual currencies.
  2. Custodian wallet providers.

Who is the VASP regulator?

  1. Pénzmosás és Terrorizmusfinanszírozás Elleni Iroda (“PTEI”)
  2. Nemzeti Adó- és Vámhivatal (“NAV“)

What is the procedure for registering a VASP for a local company?

There is no licensing or authorization for VASPs in Hungary. VASPs must fulfill only the minimum requirements related to AML regulation if such VASP is established in Hungary or serves customers in Hungary. 

In order to fulfill its AML obligations, a VASP must (paragraph 9, Section 69 of the AML Act):

  1. Demonstrate compliance with AML legislation by sending its internal AML documentation to PTEI.
  2. Provide information about the employee who will fulfill the role of AML officer, including his/her name, position in the company and contact details.

Is there any specific authorization required for a VASP from another EU member state to provide services in this jurisdiction?

The requirements for a VASP from another EU country are the same as for a local company. There are no special requirements (no branch or local staff requirements) for such VASPs, they only need to fulfill the minimum requirements stipulated by the AML regulation (Section 60 of the AML Act).

What is the liability for the activities of a VASP from another EU member state without local registration/authorization in this jurisdiction?

As there are no authorization or licensing requirements in Hungary, the only fines foreseen for VASPs are fines for violations of AML legislation (failure to submit reports, failure to introduce AML measures, etc.). Such fines, depending on the offense, can range from 20,000  to 400 million Hungarian Florian (50 EUR to 1 million EUR).


Manimama Legal & Growth Agency provides a gateway for the companies operating as the virtual asset wallet and exchange providers allowing to enter to the markets legally. We are ready to offer an appropriate support in obtaining a license with lower founding and operating costs. We offer KYC/AML launch, support in risk assessment, legal services, legal opinions, advice on general data protection provisions, contracts and all necessary legal and business tools to start business of virtual asset service provider.


The content of this article is intended to provide a general guide to the subject matter, not to be considered as a legal consultation. 

How to obtain a cryptocurrency license in Greece

Regulation of the cryptocurrency market is constantly becoming stricter. Nowadays jurisdictions impose high regulatory and risk management requirements on virtual asset service providers.

Despite this, we always manage to find a solution that suits the client. All the time our team provides research of the market and regulations on various markets to find the best jurisdiction. Recently we have made the global overview of the VASP regulation in EEA and ready to share information with our future and existing clients. Today we will look at the features of obtaining a cryptocurrency license in Greece.

Tax Summary:

  1. Personal income tax – from 9 to 44%
  2. Corporate income tax – 22 % 

What law/s governs VASP activities?

  1. Law 4021/2011 – law regarding regulation of financial services providers
  2. Law 4514/2018 – law regulating financial instruments
  3. Law 4734/2020 – law implementing Directive (EU) 2018/843 (L 156) and Article 3 of Directive (EU) 2019/2177 (L 334)
  4. HCMC`s Decision 5/898/3.12.2020 – establishing a register of virtual asset services providers
  5. Law 4557/2018 – AML law

What activities are included in VASP services?

Article 4 of Law 4734/2020 defines such activities of VASPs: providing exchange services between virtual currencies and fiat currencies, and providing custodial services of digital wallets.

Who is the VASP regulator?

  1. Hellenic Capital Market Commission (“HCMC”)
  2. National Bank of Greece (“NBG”)

What is the procedure for registering a VASP for a local company?

The Providers who intend to provide their services in Greece or to provide their services from Greece to other countries, to be registered in the Register of providers of exchange services between virtual currencies and fiat currencies or the Register of Custodian wallet providers kept by the Hellenic Capital Market Commission, before the commencement of their activity.

To register in these registers, companies must submit an application and all necessary documents, list of which is defined in HCMC`s guideline regarding Registration of providers of exchange services between virtual currencies and fiat currencies and custodian wallet providers,  in electronic form to the Hellenic Capital Market Commission at the email address aml@cmc.gov.gr.

The requested information includes:

  1. Legal person details (name, articles of incorporation, headquarters and branch addresses, email, phone, commercial registration number).
  2. Current Commercial Register extract for the Provider.
  3. Representative’s personal information and identification.
  4. Beneficial owner and shareholders’ details and identification.
  5. Criminal record certificates for management, beneficial owners, and shareholders.
  6. Ownership and control structure, capital, and shareholder percentage.
  7. Group membership and parent-subsidiary relationships.
  8. Provider’s business activity details, including services related to virtual currencies.
  9. Business Plan covering objectives, customers, employees, governance, financials, transactions, pricing.
  10. Organizational structure, including outsourcing.
  11. IT systems, controls, and security policies.
  12. Details of senior executive and Compliance Officer.
  13. Internal control system and policies for law compliance.
  14. ML/TF risk assessment and mitigation policies.
  15. Confirmation of the truthfulness of submitted information according to Law 1599/1986.

Is there any specific authorization required for a VASP from another EU member state to provide services in this jurisdiction?

According to part 1, article 1 of the HСMC`s Decision 5/898/3.12.2020 the following entities are obliged to submit an application to register in related registers: Providers of exchange services between virtual currencies and fiat currencies and custodian wallet providers  who intend to provide the Services in Greece or from Greece to other countries.

There is no information regarding whether there is a different process of Authorization of VASP from other countries. HSMC`s Decision 5/898/3.12.2020 and an application allows companies to submit documents which are issued by authorities from other jurisdictions. Also the Register of providers of exchange services between virtual currencies and fiat currencies and the Register of Custodian wallet providers includes companies from other EU-member states: Estonia, Spain, Malta.

Thus, foreign VASPs need to follow the general procedure for registration of a virtual asset service provider.

What is the liability for the activities of a VASP from another EU member state without local registration/authorization in this jurisdiction?

Part 3, article 1 of the HCMC Decision 5/898/3.12.2020 states, that the Hellenic Capital Market Commission imposes on the Providers who have not been registered or have not submitted the relevant application, as the case may be, the sanctions provided for in article 46 of the Law 4557/2018.

Sanctions for legal entities according to article 46 of the Law 4557/2018 includes the following:

  1. Fines up to €1 million (paragraph aa, part 1, article 46 of the Law 4557/2018).
  2. Fines up to €1 million, removal from position, or prohibition from position for responsible board members/managers (paragraph b-c, part 1, article 46 of the Law 4557/2018).
  3. Public notice stating the entity and violation (paragraph d, part 1, article 46 of the Law 4557/2018).
  4. Prohibition of certain business activities (paragraph e, part 1, article 46 of the Law 4557/2018).

Manimama Legal & Growth Agency provides a gateway for the companies operating as the virtual asset wallet and exchange providers allowing to enter to the markets legally. We are ready to offer an appropriate support in obtaining a license with lower founding and operating costs. We offer KYC/AML launch, support in risk assessment, legal services, legal opinions, advice on general data protection provisions, contracts and all necessary legal and business tools to start business of virtual asset service provider.


The content of this article is intended to provide a general guide to the subject matter, not to be considered as a legal consultation. 

How to obtain a cryptocurrency license in Great Britain

Regulation of the cryptocurrency market is constantly becoming stricter. Nowadays jurisdictions impose high regulatory and risk management requirements on virtual asset service providers.

Despite this, we always manage to find a solution that suits the client. All the time our team provides research of the market and regulations on various markets to find the best jurisdiction. Recently we have made the global overview of the VASP regulation in EEA and ready to share information with our future and existing clients. Today we will look at the features of obtaining a cryptocurrency license in Great Britain.

Tax Summary:

  1. Personal income tax – from 0% to 45%
  2. Corporate income tax – 25% 

What law/s governs VASP activities?

  1. The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (“AML act“”)
  2. Cryptoassets: AML / CTF regime – Registering with the FCA
  3. Anti money laundering supervision: detailed information
  4. Do I need to register with the FCA for carrying on cryptoasset activity? 
  5. Guidance on Cryptoassets Feedback and Final Guidance to CP 19/3
  6. PS19/22: Guidance on Cryptoassets
  7. PS23/6: Financial promotion rules for cryptoassets

What activities are included in VASP services?

Under Article 14a, the AML act VASP may provide the following services:

  1. Exchange, or arrange, or make arrangements with a view to exchange cryptoassets for money or vice versa, or one cryptoasset for another cryptoasset.
  2. Operate a machine which uses automated processes to exchange money for cryptoassets or vice versa  (e.g. an ATM).
  3. Provide custodian services for: cryptoassets on behalf of your customers and private cryptographic keys to hold, store, and transfer cryptoassets.

Who is the VASP regulator?

  1. Financial Conduct Authority (“FCA”)

What is the procedure for registering a VASP for a local company?

To legally provide cryptocurrency services in the UK, VASPs need to:

  1. Establish a local company.
  2. Have a physical office (a post office box or virtual address is not allowed).
  3. Submit an application to the FCA via the government’s Connect e-portal. As part of the application, a form must be completed. The application must include information about: the company, beneficial owners, shareholders, directors, and local contact person (the same person can be an AML officer). The following documents must be attached to the application or the information in the form must be filled in:
    • Programme of operations (description of services to be provided through cryptocurrency).
    • Regulatory Business Plan (business objectives, customers, employees, management, plans, and forecasts).
    • Structural organization chart (a description of the organization of your business, including the corporate structure, any close relationships, and group structures).
    • Jurisdictions (list of jurisdictions in which the business currently operates).
    • IT systems (details of key IT systems).
    • Criminal records and any documents that can confirm experience in the chosen business area for beneficiaries, shareholders, and directors.
    • Governance arrangements and internal control mechanisms (details of senior management responsibilities, oversight, organizational structure, budget forecasts, and finances for the first 3 financial years).
    • Anti-Money Laundering/Counter Terrorist Finance (AML/CTF) framework (description of AML/CTF schemes and mechanisms in the company, including policies).
    • Business-wide risk assessment (mechanisms for assessing the inherent risks faced by the business).
    • Financial promotions (details of business promotion/marketing policies).
    • Travel Rule (policies and procedures describing how you intend to comply with Regulations 64 A-H of the MLRs anti-money laundering rule when receiving and transmitting recipient and originator data for cryptocurrency transactions).
    • All cryptoasset public keys/wallet addresses (all cryptocurrency wallet addresses controlled by your business and used in its operations for each cryptocurrency your business operates with).
    • Customer onboarding process (details of tools/processes for screening individuals with sub-sanctions, PEP, etc).
    • Ongoing monitoring and transaction monitoring procedures (should include processes for detecting and escalating suspicious activity).
    • Record-keeping and recording procedures (must include notifying the FCA of changes to personal data)

A decision will be made within 3 months. If the application is incomplete or there are questions about business processes, structure, etc., the application may be considered for up to 12 months. Application fee: 10 000 pounds (12 000 euro).

Is there any specific authorization required for a VASP from another EU member state to provide services in this jurisdiction?

A VASP from another EEA member may provide its services to UK nationals if such VASP complies with certain restrictions.

The FCA will take into account the following factors:

  1. Commercial element: do you advertise or act in a way that suggests you are providing cryptoasset  services by way of business?
  2. Commercial benefit: do you receive a direct or indirect benefit from this service?
  3. Relevance to other business: how significant is the activity to the business’ other activities  (cryptoasset activities may be only part of the business)?
  4. Regularity/frequency: does the frequency of the activity suggest that it is being carried on as  a business?
  5. Do you have a registered or head office in the UK and do you carry on day-to-day management of these activities from this office, irrespective of where, geographically, the cryptoasset activity is conducted?
  6. Do you have any UK presence that is engaged in or facilitates cryptoasset activities?

The FCA points out that if you do not have an office in the UK or other activities in the UK (service advertising) other than having UK clients, the FCA is likely to consider that you are not carrying on a UK activity and you don’t need to register with the FCA. 

The FCA may ask you to explain why you think your activities do not need authorization. From 8 October 2023, companies advertising cryptoassets in the UK must be registered with the FCA.

What is the liability for the activities of a VASP from another EU member state without local registration/authorization in this jurisdiction?

Doing business without registering with the FCA can be punishable by up to 2 years imprisonment for top managers and an unlimited fine, which the FCA will determine on a case-by-case basis.


Manimama Legal & Growth Agency provides a gateway for the companies operating as the virtual asset wallet and exchange providers allowing to enter to the markets legally. We are ready to offer an appropriate support in obtaining a license with lower founding and operating costs. We offer KYC/AML launch, support in risk assessment, legal services, legal opinions, advice on general data protection provisions, contracts and all necessary legal and business tools to start business of virtual asset service provider.


The content of this article is intended to provide a general guide to the subject matter, not to be considered as a legal consultation. 

How to obtain a cryptocurrency license in Germany

Regulation of the cryptocurrency market is constantly becoming stricter. Nowadays jurisdictions impose high regulatory and risk management requirements on virtual asset service providers.

Despite this, we always manage to find a solution that suits the client. All the time our team provides research of the market and regulations on various markets to find the best jurisdiction. Recently we have made the global overview of the VASP regulation in EEA and ready to share information with our future and existing clients. Today we will look at the features of obtaining a cryptocurrency license in Germany.

Tax Summary:

  1. Personal income tax – from 0% to 45%
  2. Corporate income tax – 10% and 18% 

What law/s governs VASP activities?

  1. Kreditwesengesetz (Banking Law; (“KWG“))
  2. Geldwäschegesetz (Anti-Money Laundering Law; “GWG”))
  3. Kryptowertetransferverordnung (Regulation on enhanced due diligence in the transfer of crypto-assets; “KryptoWTransferV”))
  4. BaFin Guidelines for crypto custody business

What activities are included in VASP services?

KWG, unlike other European jurisdictions, does not operate under the term “virtual asset service provider”, instead the KWG identifies only one type of regulated virtual asset activity that requires authorization – the cryptocurrency custody business (paragraph 6, article 1a, section 1).

Crypto custody business is defined as the custody, management and protection of cryptoassets or private cryptographic keys used to keep, store or transfer cryptoassets for others.

The crypto custody business includes the following:

  1. Custody – taking care of crypto assets of clients, i.e. as a service to third parties.
  2. Management – is the ongoing exercise of rights derived from the cryptoasset.
  3. Security (protection) – is the storage of cryptographic keys.

Other services, such as exchange services, require general financial authorisation.

Who is the VASP regulator?

  1. Bundesanstalt für Finanzdienstleistungsaufsicht (“BaFin”)

What is the procedure for registering a VASP for a local company?

To get authorisation from BaFin you need to:

  1. Establish a local LLC with authorised capital of 150,000 euros.
  2. Have a competent and reliable director.
  3. Appoint a competent and reliable AML officer and deputy AML officer.
  4. Have a local physical office.
  5. At least one director must be local.
  6. Write AML documentation.
  7. Write IT documentation.
  8. Write a business plan.
  9. Documents that confirm the reliability of the AML officer, his/her deputy, shareholders, and directors.
  10. Make an application to the BaFin together with the above-mentioned documents and documents confirming the authorized capital, and availability of a local office. The application should also contain information about the founders, directors, and the company.
  11. A fee of 10 750 euros is required to be paid to the regulator for the application.

Is there any specific authorization required for a VASP from another EU member state to provide services in this jurisdiction?

According to the BaFin possibility of pursuing cross-border activity by means of a notification process (“European passport”) which is available to institutions in the European Economic Area for other types of banking business and financial services does not apply in case of crypto custody business.

Companies wishing to provide cryptocurrency services in Germany need to authorize the company according to local rules.

What is the liability for the activities of a VASP from another EU member state without local registration/authorization in this jurisdiction?

According to Article 54 KWG, the provision of a financial service without authorisation in accordance with Article 32 (1) (without BaFin authorisation) is punishable by imprisonment of up to five years or a fine at the discretion of BaFin.


Manimama Legal & Growth Agency provides a gateway for the companies operating as the virtual asset wallet and exchange providers allowing to enter to the markets legally. We are ready to offer an appropriate support in obtaining a license with lower founding and operating costs. We offer KYC/AML launch, support in risk assessment, legal services, legal opinions, advice on general data protection provisions, contracts and all necessary legal and business tools to start business of virtual asset service provider.


The content of this article is intended to provide a general guide to the subject matter, not to be considered as a legal consultation. 

How to obtain a cryptocurrency license in France

Regulation of the cryptocurrency market is constantly becoming stricter. Nowadays jurisdictions impose high regulatory and risk management requirements on virtual asset service providers.

Despite this, we always manage to find a solution that suits the client. All the time our team provides research of the market and regulations on various markets to find the best jurisdiction. Recently we have made the global overview of the VASP regulation in EEA and ready to share information with our future and existing clients. Today we will look at the features of obtaining a cryptocurrency license in France.

Tax Summary:

  1. Personal income tax –  0-45%
  2. Corporate income tax – 25%

What law/s governs VASP activities?

  1. LOI n° 2019-486 du 22 mai 2019 relative à la croissance et la transformation des entreprises (1) 
  2. Code monétaire et financier (“CMF“)
  3. Rules applicable to digital asset service providers (applicable from 01.01.2024)
  4. Digital assets service providers – Cybersecurity system of requirements (applicable from 01.01.2024)
  5. AMF General Regulation – Book VII (applicable from 01.01.2024)
  6. Ordonnance n° 2020-1544 du 9 décembre 2020 renforçant le cadre de la lutte contre le blanchiment de capitaux et le financement du terrorisme applicable aux actifs numériques 
  7. QUESTIONS & ANSWERS ON THE DIGITAL ASSET SERVICE PROVIDERS REGIME (“Q&A“)

What activities are included in VASP services?

According to Article L54-10-2 of the CMF digital asset services include the following services:

  1. The service of conserving digital assets or accessing digital assets on behalf of third parties, if necessary in the form of private cryptographic keys, in order to hold, store and transfer digital assets.
  2. The service of buying or selling cryptocurrencies in legal tender currency.
  3. The service of exchanging cryptocurrencies for other cryptocurrencies.
  4. The operation of a digital asset trading platform.
  5. The following services:
  • The reception and transmission of orders on cryptocurrencies on behalf of third parties.
  • Portfolio management of cryptocurrencies on behalf of third parties.
  • Advice to subscribers of cryptocurrencies.
  • Underwriting of cryptocurrencies.
  • Secured placement of cryptocurrencies.
  • Unsecured placement of cryptocurrencies.

Who is the VASP regulator?

  1. Autorité des marchés financiers (“AMF“)
  2. Autorité de Contrôle Prudentiel et de Résolution (“ACPR“)

What is the procedure for registering a VASP for a local company?

The DASP must notably comply with the following conditions:

  1. Either have professional indemnity insurance or a minimum amount of own funds.
  2. At least have one executive manager.
  3. Have sufficient human and technical resources.
  4. Have resilient IT systems.
  5. Have an internal control system.
  6. Have a claims handling procedure.
  7. Have an organization enabling it to avoid conflicts of interest.
  8. Have procedures for the prevention of money laundering and the financing of terrorism. 

To provide the services referred to in paragraphs 1-4 of Article L54-10-2 of the CMF in France, you shall mandatorily register first with the AMF. This obligation applies to DASPs established in France but also outside France.

For services specified in paragraphs 1, 2 of Article L54-10-2 of the CMF, the AMF, in conjunction with the ACPR, checks that complying with the regulations on AML/CFT. In all cases, the AMF checks the good reputation and competence of the managers and beneficial owners of your organization and seeks clearance from the ACPR.

The following four forms must be completed to apply for registration:

  1. AMF DASP Form.
  2. AMF DASP Executive Manager Form.
  3. AMF DASP Significant Shareholders Form.
  4. AMF DASP Programme of operations.

The registration application and its constituent parts shall be sent by email to the AMF at the following address: psan@amf-france.org.  

Is there any specific authorization required for a VASP from another EU member state to provide services in this jurisdiction?

When a DASP referred to in points 1 to 4 of Article L. 54-10-2 of the CMF is (i)  established in France or (ii) provides services to customers residing or established in France, it must be registered by the AMF, even if it is registered or matriculated in another Member State. DASPs should provide proof of the existence of the establishment when they make their request for registration.

What is the liability for the activities of a VASP from another EU member state without local registration/authorization in this jurisdiction?

Article L54-10-4 of the CMF states that the practice of the profession of service provider mentioned in 1 to 4 of article L. 54-10-2 is forbidden to any person who has not been previously registered by AMF.

Article L572-23 of the CMF prescribes – It is punishable by two years’ imprisonment and a fine of €30,000 for any person acting either on his own behalf or on behalf of a legal entity to disregard one of the prohibitions set out in article L. 54-10-4.


Manimama Legal & Growth Agency provides a gateway for the companies operating as the virtual asset wallet and exchange providers allowing to enter to the markets legally. We are ready to offer an appropriate support in obtaining a license with lower founding and operating costs. We offer KYC/AML launch, support in risk assessment, legal services, legal opinions, advice on general data protection provisions, contracts and all necessary legal and business tools to start business of virtual asset service provider.


The content of this article is intended to provide a general guide to the subject matter, not to be considered as a legal consultation.