Aug 19, 2019


Week 15, Friday 16 August 2019,


*Ongoing work for the application of Exchange limits based on the liquidity (no limits applicable from wallet to wallet as it is an internal transfer) - done; Tests will be performed next week.

*Compliance Platform (not compulsory at the beginning): Platform expected to be up and running by mid-September. It is currently in a state of development, has received approval from the security controls

and processes, API links to Worldcheck and GoAML are provided. It will be Audited by European Authority, so the Exchange company downloaded the requirements and the Risk Scoring to integrate in the platform to be in compliant with the requirements. Changes are expected to be completed by the end of next week.


Currently waiting for the exact date of the Site Visit to be communicated by the CB. Once the Site Visit is completed and, if all the small details are cleared out (ONE is approved), then the Exchange company will receive a temporary permission, allowing it to start the setup and operations.


This week the Exchange company continued sending out reminders to all countries who still have not replied to the inquiry and it will set a deadline. The Exchange company also stated if no further clarification is provided by the date set, it is going to consider the service is allowed and it is legally protected. Detailed update by countries will be provided next Friday.

Directive (EU) 2018/843 which amended the so-called Fifth Directive 2015/849 (EU) entered into force on 9 July 2018 and EU Member Countries are required to bring their national laws into line with it by January 10th, 2020.

In every member country an inter-ministerial working group has been gathered in order to implement the amendments in their national law regarding the crypto exchanges and remittance services.

It is interesting to know what every country decision is, whether only Exchanges with a registered office and address in the specific country have to be included in the government registry (which will be compulsory when the national laws come into force) or other Exchanges, not registered in the country but providing exchange and remittance services on the national market will be a subject to registration. Many governments have not taken their decision on this matter.

Remaining true to our professional acumen, we began an initiative to communicate with governments in advance.

According to the Directive and its last amendment, Exchanges and remittances’ wallets should also take measures in order to be compliant with the AML regulations, including the adoption of internal rules to control and prevent money laundering, carry out risk assessments, establish procedures and tools for identifying and verifying their customers, etc.

Currently preparing Guarantee Deposit to finalize the application for the TPFM license (Third Party Funds Management) to be able the Exchange company to manage all the funds transfers of all the clients of the exchange. The exchange is based on current accounts and wallets and no one have the right to manage these unless there is a license for third party fund management.

*European license:
✓ Criminal reports from police for the executive management has been delivered

✓ All the documentation delivered as SOW (scope of work) was reviewed and accepted except the list of currencies to be traded on the Exchange platform which will be approved after the interview. If the interview is considered successful, they will require to AUDIT the Exchange Platform. They already notified the Audit will take place 7 WD after the approval provided.

✓ Payment gateway - it will be in coordination with the bank as the API code to connect gateway needs to be provided by the bank

✓ Meeting with authorities is planned for late August 20th, 2019. Translator is appointed. If this goes to plan the Company will be able to start the Exchange after the appointed period and after a proper training of the IMA-s on mechanisms, Exchange functionalities and operations on the Exchange.

!NB If a specific coin does not have the permission to be exchanged, traded or offered - it is ILLEGAL.If there is no permission granted for a certain coin to be traded on an exchange, that exchange can only trade conventional cryptocurrencies.

Therefore, once again we would like to remind you all you should be extremely cautious in case you are contacted by ambitious entrepreneurs that have recently appeared on the market, offering fancy crypto.


The exchange Platform will allow all users to exchange the following:

o Fiat to Fiat (all Major Currencies) FF
o Crypto to Fiat (All Major approved Cryptos against Major Fiat) CF
o Fiat to Crypto (All Major Fiat against Major approved Cryptos) FC
o Crypto to Crypto (All Major approved Cryptos against major approved cryptos) CC

The process will be according to the following steps:

1- Step one: Compliance - Due Diligence - KYC
User should proceed with the following:

1.1- Register name, email and mobile. You will have to activate the email and authenticate the mobile by
1.2- Once the registration is complete. You will have to meet the KYC requirements
1.3- Once the KYC is approved, you will have a user profile created on the exchange platform
1.4- Once the profile is approved, you will have the possibility to create a current account as well as the wallet you will use
1.5- Account and wallet will be approved quickly and you will be notified for start trading and exchange

2- Step two: Exchange and Trading
You must be able to trade and exchange fiat and crypto currencies.

2.1- You should decide the type of transaction you want to execute (Buy or Sell)
2.2- You should decide which type of exchange and trade you will execute (FF/CF/FC/CC)
2.3- System will be enabled to approve the transaction after checking the allowed limits and the availability of funds in the current account or crypto in the wallet
2.4- Once the operation is confirmed the user will have to confirm the execution of transaction by OTP*
2.5- Once OTP* has been confirmed you will be notified for the flow of funds and flow of cryptos all based on DVP**/RVP***

3- Step three: Remittance Service
You can transfer fiat currency to another beneficiary

3.1- You should create the payment details as required including a Bank Account
3.2- Once a payment is created it should be confirmed by OTP*
3.3- Once OTP* confirms the payment it should be checked by Compliance
3.4- Once Compliance approves the payment, user must receive a notification for execution of remittance
3.5- Once remittance details are created, you should confirm it by OTP*
3.6- Once OTP* confirmation is entered, compliance will check the validity of data Once data validation is completed by compliance, you will receive a notification of execution. The recipient will receive a notification for reception of funds with a reference number.

*OTP is the code received by SMS to confirm the mobile number
**DVP means delivery versus payment
***RVP means receipt versus payment

Post date 16 August 2019
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