4-step procedure to apply for a crypto license



This article looks at the process and procedure of applying for a crypto or cryptocurrency license in the UK, Ireland Estonia and Lithuania.



1. Obtaining the crypto license in the UK

If you wish to provide crypto services in the UK, then you must register with the FCA for the crypto license (AML/CTF crypto Registration). The registration is formally known as the FCA AML/CTF Cryptoasset Registration regime. The FCA is the anti-money laundering and counter-terrorist financial (AML/CTF) supervisor of crypto businesses based in the UK under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.


What are crypto activities under the FCA's supervision?




Cryptocurrency exchange providers

A cryptocurrency exchange provider is a firm creating or issuing cryptoassets when providing the following services:

(a) exchanging, or arranging or making arrangements with a view to the exchange of, cryptoassets for money or money for cryptoassets,

(b) exchanging, or arranging or making arrangements with a view to the exchange of, one cryptoasset for another, or

(c) operating a machine that utilises automated processes to exchange cryptoassets for money or money for cryptoassets (Regulation 14A(1) Money Laundering Regulations).

Custodian wallet providers

A custodian wallet provider is a firm providing services to safeguard or administer:

(a) cryptoassets on behalf of its customers, or

(b) private cryptographic keys on behalf of its customers in order to hold, store and transfer cryptoassets when providing such services (Regulation 14A(2) Money Laundering Regulations).

Custodian wallet providers may also offer other services. Firms merely holding and storing cryptographic keys, but not involved in their transfer are not likely to be in the scope of the definition. This includes hardware wallet manufacturers and cloud storing service providers. These are regarded as ‘non-custodian wallet providers’.



Do you need to register your crypto business with the FCA?

Your application will be considered on a case-by-case basis. Generally, the regulations are applicable if you have a physical presence in the UK through which the cryptoasset business is conducted. However, merely having UK customers does not in itself mean that such a firm would fall within the jurisdictional scope of the ML Regulations. However, a cryptoasset exchange provider that has an ATM located in the UK will be within the scope of the ML Regulations irrespective of which jurisdiction the operator is established in or where its offices are based.






2. Obtaining the crypto license in Ireland


In order to provide cryptocurrency services in Ireland, you must register with the Irish financial services regulator for cryptocurrency, namely, the Central Bank of Ireland, and register as a Virtual Asset Service Provider (VASP), under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 to 2021.

In order for the Central Bank of Ireland to consider and accept an application for registration from a VASP, you must complete the VASP AML/CFT Registration Form. In doing so, you must satisfy the Central Bank of Ireland that they are fully compliant with all relevant regulatory requirements under the CJA 2010 to 2021.


Law in Ireland for Cryptocurrency businesses

CJA 2010 to 2021 governs the law in Ireland on anti-money laundering and the countering of the financing of terrorism (AML/CFT) and for cryptocurrency businesses. The Central Bank of Ireland is the regulator in Ireland for the monitoring and supervision of crypto businesses and the compliance of their AML/CFT obligations under Part 4 of the CJA 2010 to 2021.

The requirement to register your cryptocurrency business in Ireland

You will be required to register with the Central Bank for your crypto business if you are providing any of the following services:

  1. An exchange between virtual assets and fiat currencies;

  2. Exchange between one or more forms of virtual assets;

  3. Transfer of virtual assets, that is to say, conduct a transaction on behalf of another person that moves a virtual asset from one virtual asset address or account to another;

  4. Custodian wallet provider;

  5. Participation in, and provision of, financial services related to an issuer’s offer or sale of a virtual asset or both.



Assessment areas for the cryptocurrency application in Ireland

The following will be assessed by the Central Bank of Ireland during the assessment of your crypto registration application:

  • firm details, including the proposed business activities, business model, structure and regulatory history.

  • details of shareholdings and senior management, including direct and indirect shareholders, partnerships, and management.

  • the Fitness and Probity of the beneficial owners/controllers of the firm, the firm’s principal officers, and the persons holding certain other management functions of the firm.

  • the firm's AML/CFT governance, including the firm’s risk assessment, policies and procedures, AML/CFT manual, AML/CFT training and report management information.

  • the firm's ML/TF risk profile, including the firm’s customer exposure, financial sanctions and PEPs screening, geography/country, distribution channels, and agents and branches.

  • the firm's risk-based approach, including the firm’s assurance testing, third party reliance, and outsourcing activities.


Key stages of the AML registration process

  1. Submission of the Application Form to the Central Bank.

  2. The Central Bank will issue you an email containing application information

  3. Submission of all supporting documentation through the online system.

  4. The Central Bank will acknowledge receipt of your application.

  5. The Central Bank will assess whether your application contains all required information and documentation to progress to the assessment phase. They will notify you by email.

  6. Where all the required information and documentation has been provided, the Central Bank will conduct an assessment of the registration application. Where necessary, the Central Bank will request further information and/or clarification from you.

  7. You will be provided with the opportunity to respond to the Central Bank’s request for further information and/or clarification.

  8. The Central Bank will assess the additional information provided by you and notify you of its assessment and next steps.

  9. The Central Bank will notify you of its decision to either grant or refuse the registration.




3. Obtaining the crypto license in Estonia


If you wish to provide cryptocurrency services in Estonia, you must register with the Estonian regulator, namely the Financial Supervision Authority (EFSA).

The regime for cryptocurrency licensing in Estonia is changing. All existing virtual currency service providers licensed by the Financial Intelligence Unit will have to ensure compliance with the new requirements by 1 October 2021, set by the new financial regulator, namely the Financial Supervision Authority (ESFA).



Regulatory requirements for crypto businesses in Estonia


Under the new requirements, service providers must have/provide, among other things, the following:

  • the minimum share capital of at least EUR 25,000, or a quarter of the previous year’s fixed costs;

  • a registered physical office and head office located in Estonia;

  • the management board must have an impeccable business reputation, be fit and proper, and have knowledge, skills and experience;

  • the management board must consist of at least two people;

  • a business plan;

  • financial forecasts, including your balance sheet and statement of income, expenses, profits, losses and cash flows;

  • internal rules relating to the requirements of the Estonian legislation;

  • details of your internal accounting policy and procedures;

  • details of your information technology systems, including a description of your security measures;

  • security policy and information on ensuring the security of your payments;

  • internal control rules and rules of procedure relating to the prevention of money laundering and terrorist financing;

  • a description of your organisational structure (organisational hierarchy chart);

  • details of each of your shareholder(s);

  • details of the key people e.g. managers, within your firm;

  • details of your auditor and internal audit arrangements; and,

  • certification of your own funds.



Application fee for the cryptocurrency license in Estonia

The current application fee payable is EUR 3,300. Under the new regime, the application fee will be reduced to EUR 1,000.


Timeframe to obtain the cryptocurrency license in Estonia

The EFSA must process all new applications within 3 months of receipt of all required documents if the application is complete with all the required documents submitted.





4. Obtaining the crypto license in Lithuania


If you wish to provide cryptocurrency services in Lithuania, you must register with the Lithuanian financial services regulator for cryptocurrency, namely, the Lithuanian Financial Crime Investigation Service (FCIS). ​​


Types of cryptocurrency licenses in Lithuania There are two types of cryptocurrency licenses in Lithuania. 1. Providers of a service of exchanging a virtual (cryptocurrency) against a fiat currency This license is for exchanging fiat to crypto and crypto to fiat and crypto to crypto. This license registration will permit the license holder to operate a cryptocurrency exchange in Lithuania. ​ 2. Providers of a virtual (cryptocurrency) wallet service This enables the license holder to offer a virtual currency wallet service means a service, whereby encrypted keys can be created for customers for the purpose of keeping, storing and transferring virtual currencies. ​ ​ ​ Requirements for the Lithuanian cryptocurrency license​

  • minimum of 1 shareholder. The shareholder does not need to be based in Lithuania.

  • a minimum of 1 director, who may be the same person as the shareholder. They do not need to be based in Lithuania.

  • an AML compliance officer. They may be the same person as the director and do not need to be based in Lithuania. They must however be fit and proper.

  • a local physical office in Lithuania. Virtual or shared offices are not accepted.

  • details of the shareholders must be disclosed to the regulator.

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How we can help set up your cryptocurrency business

Buckingham Capital Consulting is an international consulting firm, specialising in payment services, electronic money, banking, and investment services. We are able to advise you on the best course of action and strategy based upon your business plan and financial product or service. We can you with licensing, compliance, operational setup and related services, including, obtaining banking facilities. For more information, visit our website on www.buckinghamcapitalconsulting.com


Buckingham Capital Consulting can advise you on the most appropriate and suitable license, based on your business model and plans. We can prepare, manage and obtain your license in the country of your choice and help you understand your regulatory and legal obligations.

Our service involves the following: - Guiding you through the application preparation stage - Managing the entire application from planning to obtaining the licence - Preparing, completing and submitting the application form - Submitting your application to the financial regulator - Assisting you with any correspondence/further questions from the financial regulator after submitting your application.