Aug 9, 2019


Week 14, 09.08.2019


*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)

*Compliance Platform (not compulsory at the beginning): Platform expected to be up and running by mid-September. It is being currently developed, has received approval of the security controls and processes, API links to Worldcheck and to GoAML provided.

The financial authority was auditing the compliance platform and they approved the first part of the authentication of applicants.

The GoAML application is a fully integrated software solution, developed specifically for usage by the Financial Intelligence Units (FIU's) and is one of UNODC's strategic responses to financial crime, including money-laundering and terrorist financing. Furthermore, its aim is to control the flow of funds internationally based in the profile of the client. Financial Intelligence Units play a leading role in any antimoney laundering regime as they are responsible for receiving, processing and analyzing reports made by financial institutions or other entities according to the requirements of domestic anti-money laundering laws and regulations.

Such reports and other information, gathered by FIUs, often provide the basis for investigations of money laundering, terrorist financing and other serious offences.

FYI: GoAML is specifically designed to meet the data collection, management, analytical, document management, workflow and statistical needs of any Finance Intelligence Unit.


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 has sent out a serious reminder to all countries who still haven’t replied to the inquiry and it will set a deadline. The Exchange company also stated that if it doesn’t receive any clarifications by the date set, it will consider that the service is allowed and that it is legally protected.

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 will each country decide - 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 also 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 still not taken a 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.

*European license:
- criminal reports from police for the executive management will be delivered at the beginning of next week.

- the whole documentation, delivered as SOW (scope of work), was reviewed and accepted with the exception of the list of currencies to be traded on the Exchange platform which will be available after the interview

- 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 set to happen after August 20th, 2019. If all goes well, the Company will be able to start the Exchange after that period and after a proper training of the IMA-s on mechanisms, Exchange functionalities and how to operate on the Exchange.

!NB If the specific coin doesn't 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 that you should be extremely cautious in case you are contacted by ambitious entrepreneurs that have recently appeared on the market, offering fancy crypto products.

Post date 09 August 2019
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