Crypto-asset service provider licensing

We help crypto businesses choose the right jurisdiction and obtain authorisation — and prepare those already operating for regimes that are about to bite.

Jurisdiction selection

- Mapping target markets against the regimes that will govern them - Comparison of authorisation routes by scope, timing and substance requirements - Assessment of whether the current model falls inside or outside the perimeter, including non-custodial arrangements - Group structuring across licensed and unlicensed entities

Authorisation

- Definition of the services to be covered: custody and administration, operating a trading platform, exchange, execution and reception and transmission of orders, placement, advice, portfolio management, transfer services - Ownership structure and capital documentation - Internal policies: safeguarding of client assets, conflicts of interest, complaints handling, operational resilience, AML/CFT - Custody documentation: trust arrangements, private-key controls, reconciliation procedures - Disclosure documentation for token issuers - Application file and support through the review

Transition and remediation

- Moving from an AML-registration regime to full authorisation - Migrating from national regimes to a harmonised one - Gap analysis against a regime that has been adopted but is not yet in application

Where we work

The EU, the United Kingdom, Asia.

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Crypto-asset service provider licensing | HARLIB | HARLIB