Onboarding principles

Last Updated on April 8, 2022


  • 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.)

Scam warnings

  • The company should not have grounded scam warnings or negative reviews in public forums and websites

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)