Legal services:

Comprehensive legal solutions for contracts, disputes, and compliance. Our expert team ensures legal protection and strategic guidance for your business.

AML consulting:

Specialised AML consulting to develop and maintain robust anti-money laundering policies. We assess risks, offer ongoing support and provide tailored AML services.

Obtaining a crypto license:

We offer licensing and ongoing support for your crypto-business. We also offer licences in the most popular jurisdictions.

Registration of legal entities:

Efficient legal entity registration support. We manage documentation and interaction with the authorities, ensuring a seamless process for establishing your business.

Opening bank accounts:

We facilitate the opening of bank accounts through our extensive network of partners (European banks). Hassle-free process, tailored to your business needs.

COREDO TEAM

Nikita Veremeev
Nikita Veremeev
CEO
Pavel Kos
Pavel Kos
Head of the legal department
Grigorii Lutcenko
Grigorii Lutcenko
Head of AML department
Annet Abdurzakova
Annet Abdurzakova
Senior Customer Success Manager
Basang Ungunov
Basang Ungunov
Lawyer at Legal Department
Egor Pykalev
Egor Pykalev
AML consultant
Yulia Zhidikhanova
Yulia Zhidikhanova
Customer Success Associate
Diana Alchaeva
Diana Alchaeva
Customer Success Associate
Johann Schneider
Johann Schneider
Lawyer
Daniil Saprykin
Daniil Saprykin
Head of Customer Success Department

Our clients

COREDO’s clients are manufacturers, traders and financial companies, as well as wealthy clients from European and CIS countries.

Effective communication and fast project realisation guarantee satisfaction of our customers.

Exactly
Unitpay
Grispay
Newreality
Chicrypto
Xchanger
CONVERTIQ
Crypto Engine
Pion

Regulators are tightening requirements, customers expect instant payments, and the compliance team is overloaded with alerts. Over recent years, the COREDO team has implemented dozens of KYT (Know Your Transaction) projects for fintech companies in the EU, the United Kingdom, the Czech Republic, Slovakia, Cyprus and Estonia, as well as in Singapore and Dubai. In this article I systematize the approach that has proven effective at COREDO: from architecture and risk-scoring models to legal liability and the AML team’s KPIs.

What is KYT and how does it integrate into AML processes?

Illustration for the section «What is KYT and how it integrates into AML processes» in the article «Know Your Transaction - Tools for monitoring blockchain transactions for fintech companies.»

KYT (Know Your Transaction) for fintech is the continuous analysis of blockchain transactions in real time with risk scoring at the level of each operation. Unlike KYC, which answers the question «who is the client», KYT answers the question «what is happening with their transaction right now». For payment and crypto services this is the foundation of blockchain payments compliance and the key to managing operational risk.

Our experience at COREDO has shown that integrating KYT with KYC and AML reduces regulatory and operational losses at the same time. Proper orchestration of KYC/KYT enables automating blocking, escalation and reporting scenarios, as well as reducing the costs of manual checks. As a result, fintechs gain transaction monitoring tools capable of detecting fraud networks, sanctions-related links and the use of mixers before funds are credited.

Regulatory frameworks: AMLD5/AMLD6, FATF and the Travel Rule

Illustration for the section «Regulatory frameworks: AMLD5/AMLD6, FATF and Travel Rule» in the article «Know Your Transaction - Tools for monitoring blockchain transactions for fintech companies.»

European AMLD5 and AMLD6 have shaped expectations for transaction monitoring policies, sanctions screening obligations and suspicious activity reporting. Recommendations of FATF, including the Travel Rule, require matching on‑chain and off‑chain data and transmitting payer/beneficiary attributes between providers. In practice this means the need for on‑chain sanctions screening, compliance with watchlists (OFAC, EU, UN) and automation of SAR/STR reporting.

At COREDO we build processes with GDPR in mind: storage of personal data, minimization and the legal subtleties of data transfer between jurisdictions, all of this affects the KYT architecture. It is important to ensure auditability of logs and an immutable trail to demonstrate to the regulator the quality of controls and the chain of decisions. Legal liability of payment providers for anomalies is expanding, so the risk management model and the rules for data exchange between branches must be formalized.

Architecture: from streaming to investigations

Illustration for the section «Architecture: from streaming to investigations» in the article «Know Your Transaction - Blockchain transaction monitoring tools for fintech companies.»

The solution developed at COREDO is typically built as a streaming pipeline. Block indexing and mempool parsing provide minimal latency, and data streaming (Kafka, Kinesis) delivers events to the risk-scoring core. We enrich transactions with additional data: address attribution, exchanges, OTC entities, cascades of transit wallets. This increases accuracy and reduces false positives when monitoring on-chain.

For graph analytics of transactions we often use Neo4j or TigerGraph, and for full-text search and event analytics: ElasticSearch. Such a stack delivers performance benchmarks for latency/throughput at millions of transactions per day and the ability to scale monitoring for cross-chain payments. SLAs are important for transaction monitoring: alert latency, API availability, incident handling time, and the speed of sanctions updates.

Blockchain fraud detection systems integrate via API and webhooks for alerts with subsequent processing in case management and analyst workflows. Audit trail, multi-level access control, encryption and key management form a secure perimeter. For global providers, SaaS KYT multi-tenancy and a clear policy on TCO, CAPEX and OPEX are useful when implementing KYT.

Analytics and models: a hybrid of rule-based and ML

Illustration for the section «Analytics and models: a hybrid of rule-based and ML» in the article «Know Your Transaction - Blockchain transaction monitoring tools for fintech companies.»

COREDO’s practice confirms: the best effectiveness is achieved by a hybrid of rule-based detectors and machine learning models for KYT. Heuristic rules quickly catch known patterns, while unsupervised training detects anomalies in new flows. Supervised models for risk scoring increase the prioritization of investigations and reduce the conversion of alerts into SARs where justified.

We apply graph analytics: address identification and wallet tagging, address attribution and clustering (heuristics clustering), PageRank and node centrality in the blockchain graph. This combination improves explainable AI for fintech compliance: an analyst can see the reasons for scoring, and the transaction monitoring chain becomes transparent. For model quality we use metrics such as precision, recall, F1, regular testing for false negative risk, and drift detection with model monitoring.

Feature engineering for transaction scoring takes into account the degree of connectivity to sanctions tags, the depth and breadth of paths, temporal patterns, amounts, and repeatability. Backtesting of the transaction risk-scoring model is necessary before go-live: we check metrics on historical data and stress scenarios (for example, spikes after a token listing). As a result, the client gets a reduction in alert fatigue and an increase in the operational efficiency of the AML team.

On-chain risks: DeFi, mixers and privacy coins

Illustration for the section «On‑chain risks: DeFi, mixers and privacy coins» in the article «Know Your Transaction - Blockchain transaction monitoring tools for fintech companies.»

On‑chain analytics of transactions must take DeFi specifics into account. Monitoring DeFi transactions focuses on DEX and AMM transaction patterns, bridges and token transit flows, wrapped tokens and multichain tracking. The impact of L2 and rollup on transaction monitoring is expressed in increased speed and the need to index smart contract events.

Analysis of mixers and CoinJoin requires behavioral indicators: amount splitting, short cycles and mixing of skewed time series. Mixers and Tornado Cash behavioral indicators are combined with sanctions tagging for precise assessment. Privacy coins (Monero, Zcash) are analyzed through contextual signals: on-chain bridges, entry/exit points and counterparty behavior.

We track leaked wallets and key leaks, and also build an incident response plan upon detection of money laundering. For legal investigations, chain‑of‑custody for on-chain evidence is important: immutable logs, hash fixations and procedural integrity. This simplifies interaction with lawyers and regulators and reduces the risk of disputes over the evidentiary base.

Integrating KYT into processes: from onboarding to SAR

Integration with wallets and payment gateways provides pre-credit holds and real-time operation of the KYT API. AML/KYC orchestration platforms help tie KYT to KYC and sanctions screening, and also implement automated decisioning for low-risk scenarios. Proper implementation of a transaction monitoring policy formalizes thresholds, roles, and escalations.

At COREDO we set up SAR automation and regulator reporting, which reduces manual delays and improves submission quality. SOC/AML team organization and processes include triage levels, playbooks, and SLAs for incident closure. Key metrics — alerts-to-SAR ratio, analyst efficiency, average investigation time, and repeat-alert rate.

Managing analyst workload: a separate layer. We apply deduplication rules, cluster grouping, and prioritization by risk scoring to reduce analyst burden during mass alerts. As a result, time to resolution is shortened, and compliance retains control without expanding headcount as transactions grow.

How to choose a KYT platform and assess ROI

How to choose a KYT‑platform for fintech — the question is a balance between the depth of on‑chain coverage, SLAs, security and total cost of ownership. Pilot KYT deployment: steps and success metrics include the accuracy of risk scoring, reduction of false positives, Time to Value (TTV) and integration stability. It is important to evaluate SaaS KYT pricing versus on‑prem, taking into account multi‑tenancy, data requirements and CAPEX/OPEX.

We perform Due Diligence on blockchain analytics providers, including open sources and commercial solutions, as well as open source tools for blockchain analytics as a supporting layer. It is critical to check which SLAs matter for monitoring transactions in fintech: RPO/RTO, alert latency, tag update frequency, support for new networks and the quality of customer support. Vendor comparison: this is not a feature race, but a check of alignment with your risk scenarios and jurisdictions.

What ROI metrics should you expect from KYT implementation? We assess the reduction in the cost of investigating a single incident, decreases in chargeback/fraud losses, reduction of regulatory fines and faster onboarding. The ROI of KYT implementation in a payments company appears within 3–6 months if correct KPIs are set and integration with operations is ensured. The pilot’s Time to Value depends on data maturity and the availability of an internal team, but our experience shows a rapid efficiency gain with good preparation.

Implementation plan: from pilot to production

The pilot begins with defining target risks and selecting networks/tokens. Next: configuring sanctions lists and watchlists, integrating with enrichment sources and setting up API integrations and webhooks for alerts. After that, backtesting on historical data, determining thresholds, training staff and running in parallel mode with manual oversight.

Implementing a real-time KYT API requires performance testing, latency/throughput benchmarks and fault-tolerance plans. We build in model risk governance (model governance), regular testing and rule validation, as well as drift detection and model monitoring. DevOps and MLOps for production KYT systems simplify releases, disaster resilience and traceability of changes.

After going into production, a long-term KYT roadmap and development roadmap are established: expanding networks, working with DeFi bridges and cross-chain risks, improving explainable AI and integrating with Travel Rule providers. An important block is practices for preparing for regulator inspections (audit readiness) and strategies for minimizing regulatory fines through transparent controls.

COREDO case studies: what worked in practice

  • European payments provider with expansion into the United Kingdom and Singapore. The COREDO team implemented KYT integration with internal KYC and sanctions screening, deployed on‑chain sanctions screening and SAR automation. We combined graph algorithms for on‑chain investigations with rule‑based detectors, achieving a double‑digit reduction in false positives and shortening investigation time. As a result the company accelerated PI/EMI licensing and preserved SLAs for client‑facing payments.
  • An OTC desk in Dubai with multichain flows. The solution developed at COREDO emphasized on‑chain transaction analytics to detect bridges, wrapped tokens and AMM anomalies. We set up address and wallet tracking, address attribution and clustering, as well as an incident response plan for detected money laundering. This enabled proper handling of cross‑chain flows and meeting the local regulator’s AML requirements for fintech companies.
  • Fintech in the Czech Republic/Slovakia expanding into the EU. COREDO’s practice confirmed that integrating KYT into the onboarding process speeds up KYC through dynamic risk scoring of initial transactions. We ensured compliance with AMLD5/AMLD6, correlation of on‑chain and off‑chain data and automated reporting. The company gained transparency of chains and reduced incident costs.
  • Licensing of a crypto service in Estonia and launch in the United Kingdom. The COREDO team prepared an AML policy, implemented address identification and wallet tagging, and deployed case management and workflow for analysts. A key element was explainable AI for fintech compliance: the regulator valued the transparency of scoring and the completeness of logs, which simplified the audit process.

Legal aspects: liability and cross-border data

The boundaries of liability between the payment provider and the client in cases of fraud depend on contract terms and the regulatory framework. We document them in the SLA and escalation policy to avoid gray areas. In EU countries and the United Kingdom special attention is paid to the Travel Rule and the quality of sender/receiver data matching for cross‑border transfers.
Personal data storage and GDPR risks require a clear retention, minimization and encryption policy. Multi‑jurisdictional groups face legal nuances in transferring data between jurisdictions; COREDO establishes the legal basis taking local restrictions into account. For on‑chain investigations we ensure attorney and legal requirements during investigations and chain‑of‑custody for on‑chain evidence.

Processes and team: how to avoid overload and burnout

Alert fatigue and alert optimization: an ongoing challenge. We introduce risk stratification by geography and industry, regular testing and validation of rules, as well as methodologies for testing false negative risk. KPIs for the AML analyst team should be implemented pragmatically: share of automatic closures, escalation speed, share of correctly filed SARs and quality of documentation.

Case management and workflow for analysts with investigation templates and playbooks reduce cognitive load. SOC/AML team organization and processes increase predictability and manageability of SLAs. COREDO’s experience shows that clearly defined roles, task rotation and quality control reduce turnover and increase the resilience of the AML function.

Data, vendors and security

Purchasing data and subscribing to exchange and OTC data enhance enrichment and increase the accuracy of risk scoring. Comparing analytics vendors is sensible by criteria such as network coverage, tag freshness, SLAs and the depth of forensics tools, without marketing comparisons. Estimating the costs of storing and indexing on‑chain data is important for early TCO calculation.

Multi‑tenancy of SaaS KYT and data security require segmentation, encryption, access management and monitoring. DevOps and MLOps for production KYT systems help maintain release quality and rollbacks. Log auditability and an immutable trail simplify audits and build trust with the regulator and partners.

Cross-chain and the future: L2, rollups and new risks

The impact of L2s and rollups on transaction monitoring is growing: the volume of smart contract events increases, speed rises and attribution becomes more complex. Best practices for building a blockchain monitoring pipeline include deterministic indexing, retry queues, schema versioning and consistency checks. Scaling to millions of transactions per day requires horizontally scalable shards and backup strategies.

Total on‑chain traceability versus privacy‑enhancing tech is a balance between compliance and privacy. At COREDO we follow the principle of ‘minimum necessary’ storage of personal data and maximally preserve technical signals for risk detection. Past cases of address sanctioning and lessons learned help adjust rules and models in advance for new patterns.

Practical checklist: where to start and what to measure

  • Determine target risk scenarios: sanctions, mixers, DeFi bridges, privacy coins, leaked keys.
  • Choose the architecture: SaaS KYT vs on‑prem considering CAPEX/OPEX, GDPR and multi‑jurisdictional constraints.
  • Build the pipeline: mempool parsing, streaming (Kafka/Kinesis), graph database (Neo4j/TigerGraph), search (ElasticSearch).
  • Configure sanctions lists: OFAC, EU, UN, local watchlists, and the policy for updating them.
  • Enable hybrid analytics: rule‑based detectors + ML (supervised/unsupervised), explainable AI.
  • Run a backtest: precision/recall/F1 metrics, false negative tests, drift detection.
  • Launch a pilot: TTV, SLA, reduction of false positives, alerts‑to‑SAR ratio, analyst efficiency.
  • Formalize processes: case management, playbooks, incident plan, SAR automation.
  • Prepare for audit: immutable logs, chain‑of‑custody, data‑sharing regulations between branches.
  • Plan for growth: L2/rollups, DeFi risks, new networks, regular validation of rules and models.

How COREDO supports a project from licensing to production

COREDO covers the entire cycle: from registering legal entities in the EU, the UK, the Czech Republic, Slovakia, Cyprus and Estonia, to structuring in Singapore and Dubai. We assist with obtaining licenses (crypto, payments, forex and banking), develop AML policy, design KYT architecture and implement blockchain payments compliance. This approach eliminates gaps between the legal framework, processes and technology.

For each client we define regulatory obligations, SLA requirements and AML team KPIs. Then we engage data partners, configure integrations and train analysts. Throughout the project we maintain risk model management and audit readiness so the business can scale without interruptions.

Conclusion

KYT is not just real-time analysis of blockchain transactions. It is the foundation of your license, payment speed, and market trust. When transaction monitoring is linked with KYC, sanctions screening, and clear investigation processes, fintech gains control over risk and predictable economics. COREDO’s experience in the EU, Asia, and the CIS shows: a well-designed KYT reduces operational costs, speeds time-to-market, and stands up to audits.

If you are building a payment service, a crypto platform, or expanding presence across multiple jurisdictions, start with a clear architecture, transparent metrics, and a pilot on real-world scenarios. The COREDO team has walked this path dozens of times and knows how to reconcile the requirements of AMLD5/AMLD6, the FATF Travel Rule, GDPR, and the specifics of DeFi. That way you’ll gain not just compliance but a competitive advantage—a resilient, scalable risk control built into the product.

When I launched COREDO in 2016, entrepreneurs had an obvious request: to enter new markets quickly, safely and transparently. Over the past few years the puzzle has become more complex: requirements for company registration, licensing and AML compliance have tightened. Today it is impossible to build an international business without a well-designed compliance function, and the EU AML Package 6.0, the launch of AMLA and 6AMLD are turning “due diligence” from a formality into a strategic discipline. In this article I systematize our experience and explain how to build a working AML and KYC/KYB system without losing scaling momentum.

COREDO’s practice confirms: companies that design compliance in advance get faster access to banking services, close deals more confidently and are less likely to face de-risking. The COREDO team has implemented dozens of projects in the EU, the UK, Singapore and Dubai, helping clients register legal entities, obtain financial licenses and build an effective AML framework. Below is a concentrated action plan, case studies and tools that work in 2026.

EU regulatory map: AMLA and 6AMLD

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The EU AML Package 6.0 formalizes the shift toward more unified regulation: it creates AMLA (the European Anti‑Money Laundering Agency), the provisions of 6AMLD come into force, and the main body of requirements is consolidated into pan‑European AML regulation. For businesses this means uniform technological and procedural standards across the EU and fewer gray areas in the interpretation of rules. At the same time, the role of national regulators remains: they will interact with AMLA by sharing data, coordinating inspections and harmonizing local procedures.

AMLA will receive supervisory powers over selected high‑risk credit and financial institutions, as well as a mandate for risk methodology, STR/SAR standards and information exchange with FIUs. Regulatory cooperation between the EBA, the ECB and AMLA will improve the consistency of requirements for banks and non‑bank PSPs, and will also affect cross‑border banking operations through a uniform approach to KYC/KYB, sanctions screening and transaction monitoring. Our experience at COREDO has shown that fintech companies and payment providers benefit from this predictability, especially when expanding into multiple EU countries.
A separate topic is international mutual cooperation on AML between Europe and Asia. FIU data‑exchange agreements, FATF standards and enforcement practices in the Singapore and Dubai markets form a clear roadmap for companies building cross‑border operations. The solution developed at COREDO for clients with Asian structures includes unified policies and checkpoints that take into account the requirements of the EU, the UK and key Asian regulators, which reduces fragmentation and compliance risk.

Company registration with AML considerations

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Registration of legal entities in the EU with AML requirements in mind is not just articles of association and an address. Competent preparation of a UBO dossier, analysis of source of funds, assessment of the business model from the AML-risk perspective, and the mandatory elements of the starter package. I recommend starting with a jurisdiction map: the Czech Republic, Slovakia and Cyprus are convenient for trading and holding structures; Estonia and United Kingdom — for tech and service companies; Singapore and Dubai — for regional headquarters and structures with active payment activity.

The register of beneficial owners (UBO register in the EU) and beneficiary disclosure requirements vary in depth and access regime. In some countries the register is partially public, in others special requests from “obligated persons” are required. At the registration stage we establish the corporate policy for preventing money laundering and compliance for cross-border corporate registration: we determine the documentation for banks’ and PSPs’ KYC/KYB, and design the ownership chain taking into account transparency and requirements for trusts and anonymous companies. This approach helps to expedite bank onboarding and reduces the risk of refusals.

Registration and support of companies in the EU from an AML perspective includes alignment with future licenses and banking needs. If the goal is: payment services, it is worth building in advance a functional compliance structure, the allocation of responsibilities of “obligated persons” for AML, and an initial set of CDD/EDD controls. When these elements are embedded before applying for an account or a license, the process proceeds noticeably faster.

AML Program Architecture

Illustration for the section 'AML Program Architecture' in the article 'AML Package 6.0 – analysis of the EU Directive and AMLA'
Compliance program AML for companies is a managed system of policy, procedures, a technology platform and metrics. I recommend starting with a risk-based approach: conduct an AML risk assessment, identify client and country risk profiles, determine high-risk scenarios, and then embed them in the corporate policy. It is important to describe roles and the chain of responsibility, including the director’s and corporate structure’s responsibility for AML, and an internal control plan.

Data privacy and GDPR in AML processes are a critical part of the design. We configure data retention rules and a retention policy: clear retention periods for KYC files, access logging, legal bases for processing and cross-border transfer. Integration of AML requirements into ERP and accounting systems via connectors provides a unified view of transactions, and reporting standards and compliance dashboards create managerial transparency. Such dashboards show compliance KPIs and ROI, onboarding time, the share of false positives and the conversion of CDD into successful account openings.

From a cost perspective, a cost-benefit analysis of implementing AML platforms is needed already at the RegTech selection stage. AML effectiveness metrics (KPIs and ROI) are not only about reducing fines and administrative measures for AML non-compliance, but also accelerating M&A, access to correspondent banking and reducing operating costs. Scaling AML processes as the business grows becomes a routine task when the architecture already supports new jurisdictions, languages and data sources.

How to implement KYC, KYB, CDD and EDD?

Illustration for the section «How to implement KYC, KYB, CDD and EDD?» in the article «AML Package 6.0 – analysis of the EU Directive and AMLA»
KYC and KYB requirements in the EU are based on 6AMLD and national laws, but expect the same logic: verification of identity, address, tax residency status, source of funds and UBO/BO status. For corporate clients, KYB includes checking registers, the charter, ownership structure, as well as assessing the business reputation of executives. We use automation of KYC processes and tools for VASP/PSP to reduce document collection time and minimize human errors.

CDD (Customer Due Diligence) is structured in levels: simplified, basic and enhanced. EDD (Enhanced Due Diligence) is triggered under increased risk: complex structures, PEP (politically exposed persons), transactions with high-risk jurisdictions. Sanctions and screening in the context of AML Package 6.0 include a regular reconciliation cycle against EU, OFAC and UK lists, as well as monitoring of connections. Practical implementation of UBO identification involves collecting confirmations along the chain up to individuals with a controlling interest, using cross-border counterparty screening tools and configuring repeat checks when the structure changes.
“Know-your-partner” procedures in the supply chain are useful not only for manufacturers. Payment services and fintechs often underestimate the risk of third parties: processors, outsourcers and referrers. The solution developed by COREDO includes a supplier risk matrix and standardized questions for the KYB questionnaire, which speeds up assessment and improves data quality.

Transaction monitoring and risk assessment

Illustration for the section «Transaction monitoring and risk assessment» in the article «AML Package 6.0 – analysis of the EU Directives and AMLA»
risk assessment for AML is a living document that is tied to transactional behavior models. We apply customer profiling and risk scoring, using historical and behavioral parameters: geography, average transaction amounts, types of counterparties, temporal patterns. Technologies for AML, transaction monitoring, screening, analytics: form an observation framework that operates in real time while also supporting off-chain monitoring for non-standard scenarios.

Transaction monitoring technologies require precise tuning of rules (rules tuning). Without this, a company faces an avalanche of false positives, loses operational efficiency and degrades the customer experience. Approaches to managing false positives include segmentation, adaptive thresholds, feedback from analysts and, where appropriate, the implementation of machine learning and regtech solutions for AML. We also create risk scenarios and conduct AML stress testing, simulating a surge in suspicious transactions or the loss of a data source to test the resilience of processes.

Monitoring the risks of counterparties and supply chains complements transactional rules. For cross-border companies we implement off-chain indicators: reputation in industry databases, court cases, changes in ownership structure. This layer improves the accuracy of EDD and helps promptly identify triggers for revising the risk profile.

Strategies for crypto and VASP

Regulation of virtual assets and VASP under the AMLA aligns the framework for crypto services with traditional financial institutions. Virtual asset service providers (VASP) and KYC requirements should cover customer identification, source-of-funds verification, sanctions screening, and monitoring of on-chain and off-chain transactions. Blockchain chain analysis and blockchain analytics help build a link-based risk model for addresses, wallets, and exchanges, and identify mixers, obfuscation, and connections to the darknet.

risk management when working with crypto assets requires correlating on-chain signals with off-chain customer profiles. For tokens and stablecoins, an additional layer evaluates the issuer, reserve model, and counterparties involved in redemptions. Regulatory tests and pilot projects (sandboxes) are a useful option if the market allows testing new compliance models under controlled risk. In several projects the COREDO team supported KYC pilots for VASP in the EU and Dubai, which enabled clients to obtain licenses faster and establish a dialogue with the regulator.

STR/SAR: interaction with the FIU

The obligations of obliged persons (obliged entities) under AML include detection and reporting of STR/STRs (or SAR), record keeping and cooperation with the FIU. Preparing and submitting STR/SAR requires a clear checklist: indicators of suspiciousness, escalation logic, the level of detail in the description of the pattern and attachments. We configure signal handling routes from first line to the MLRO to eliminate delays and improve the quality of reports.

Investigation of financial crimes and cooperation with the FIU is built on legal mechanisms of compelled data exchange and procedural deadlines. It is important to consider the legal risks of data transfer in AML investigations: legal bases under the GDPR, assessment of the recipient’s status and protection mechanisms, use of standard contractual clauses for cross-border exchange. financial intelligence (FIU) and information exchange in the EU and Asia are becoming increasingly structured, which reduces uncertainty and increases the predictability of regulatory interaction.

Licensing: payments, forex, crypto

obtaining financial licenses – is an assessment of the maturity of your AML system. For payment providers and PSPs, regulators assess governance, the independence of the compliance function, the quality of KYC/KYB, EDD and transaction monitoring. For forex and investment licenses, particular attention is paid to sources of liquidity, policies on high-risk jurisdictions and stress testing. Crypto licensing in the EU and Dubai integrates requirements for VASPs, blockchain analytics and counterparty risk management.

The impact of AML obligations on corporate transactions and due diligence has noticeably increased. The integration of AML requirements into M&A and corporate transformation includes audits of the client base, retrospective analysis of STRs, assessment of regulatory history and vendor due diligence. The participation of banks and non-bank institutions in AML is now assessed in the context of the single EU AML Package, and the alignment of national legislation with the AMLA reduces divergences in requirements for cross-border licensing.

Outsourcing third-party compliance

Outsourcing compliance functions and its risks are often underestimated. Outsourcing vs in-house – it’s not about “cheaper”, but about control, competencies and resilience. We usually set up a hybrid: key roles and decision-making in-house, while part of monitoring and screening is with external providers under clear SLAs and with audit rights. This approach simplifies scaling the AML infrastructure when entering new markets, while maintaining manageability.

Audit and internal control of AML programs are a mandatory practice that strengthens the chain of accountability in corporate AML governance. Staff training and certification of compliance officers improve the quality of CDD/EDD and reduce operational errors. If the system fails, fines and administrative measures for non-compliance with AML in the EU are substantial, and enforcement practice and fine cases in the EU show a trend of increasing sanctions for ineffective monitoring and weak sanctions screening.

COREDO: access to banks and de-risking

One of the recent projects was a fintech from Central Europe with a payment model for cross-border e-commerce. The client faced difficulties accessing banking services due to de-risking. The COREDO team rebuilt the compliance package: detailed suppliers’ KYB, strengthened sanctions screening, and implemented transaction profiling with adaptive thresholds. The bank reconsidered its decision, opening correspondent accounts after a pilot period with KPIs on false positives and alert handling time.

Another case: a VASP expanding into the EU and Dubai. We aligned policies with AMLA requirements and the local regulator, implemented blockchain analytics and off-chain monitoring, and ran a regulatory pilot within a sandbox. The result – accelerated licensing, a predictable dialogue with supervisors, and a ready infrastructure for scaling into new countries.
Third example: a corporate restructuring of a holding with assets in the EU and Asia. COREDO’s analysis identified bottlenecks in UBO identification and the retention policy for AML documents. We updated compliance dashboards, coordinated procedures with corporate security, and integrated AML into the ERP. This reduced the KYC re-evaluation time for counterparties from weeks to days and improved the quality of M&A due diligence.

AML Package 6.0 Compliance Plan

Every compliance officer benefits from a pragmatic roadmap. Below is the checklist we use during implementation.

  1. Conduct an AML risk assessment and record the risk appetite. Ensure that client, country, product and sales channel profiles reflect the current strategy and growth plans. Update the risk map at least once a year and after major business changes.
  2. Update the AML compliance program, roles and accountability. Define MLRO authorities, describe escalation and independence of control. Document the corporate policy on anti-money laundering and sanctions screening.
  3. Review KYC/KYB, CDD/EDD and PEP procedures. Include automation of KYC processes, regular sanctions screening and relationship checks. Clarify the practical implementation of UBO identification and the frequency of data updates.
  4. Reconfigure transaction monitoring and rules tuning. Introduce metrics for false positives, average alert handling time and the share of escalations to STR/SAR. Conduct transaction analysis in real time and off-chain monitoring for atypical scenarios.
  5. Approve the STR/SAR playbook and interaction with the FIU. Describe suspicion criteria, the quality of the evidentiary base and filing deadlines. Check legal data-exchange mechanisms and GDPR compliance.
  6. Check AML integration into ERP/accounting and dashboards. Ensure data integrity, access log audits and consistency of reporting standards. Set compliance KPIs and ROI to demonstrate business impact.
  7. Organize training and testing for staff. Run targeted modules for the front office, analysts and management every six months. External certification and participation in industry programs are useful for compliance officers.
  8. Agree the outsourcing process and third-party controls. Document SLAs, audit rights, security requirements and continuity plans. Verify vendor approaches’ compatibility with 6AMLD and local regulations.
  9. Prepare a high-risk and sanctions policy. Develop a policy for working with high-risk jurisdictions and client profiles. Clarify the approach to tokens, stablecoins and VASPs, if relevant.
  10. Plan regulatory engagement and pilots. If the product is innovative, consider participation in sandboxes and supervised pilots. This will speed up feedback and reduce regulatory uncertainty.
COREDO supports such projects “turnkey”: from diagnostics and a roadmap to RegTech selection and implementation. Our experience at COREDO has shown that phased implementation and transparent metrics reduce internal resistance and strengthen the trust of banks and regulators.

What to consider when entering new countries

AML analysis when entering the markets of Asia and the CIS must take into account local standards and the FATF’s international recommendations. Differences in access to UBO registries, document retention periods and STR formats can affect process design. The impact of AMLA on fintech and payment services in the EU makes the European part of the infrastructure more predictable, which simplifies integration with Singapore and Dubai.

Interaction with law enforcement during investigations requires a clear role for the legal function. Corporate policies on receipt and storage of documents, legal bases for data sharing and documented criteria for suspicion reduce legal risks. When all of this is described and embedded into tools, compliance stops slowing the product down and helps the business grow.

Why I support systemic compliance

Compliance is not an “insurance against fines”, but an operational discipline that increases a company’s capitalization. AML Package 6.0, the EU Directive on anti-money laundering and the launch of AMLA are creating a common playing field with clear rules, and those who adapt their processes earlier will gain an advantage. I see COREDO clients opening accounts faster, obtaining licenses with confidence, and shortening deal cycles when compliance is integrated into the business architecture.

The COREDO team has implemented projects in the EU, the UK, Singapore and Dubai, from registration and licensing to setting up monitoring and providing full AML support for companies. I continue to personally oversee complex cases and am convinced: transparency, technological sophistication and discipline deliver the best results. If you plan to scale, pursue M&A, or expand into new markets, build compliance into your growth strategy: it will save time and strengthen the trust of partners, banks and regulators.

Since 2016 I have been building COREDO as a team that turns complex regulatory challenges into working operational models. During this time we have carried out dozens of projects in the EU, the United Kingdom, Singapore and Dubai, as well as in a number of offshore and mid‑shore jurisdictions in Africa and Asia. Today entrepreneurs and CFOs increasingly come to me with one request: how to strategically choose between the Seychelles and Mauritius for a VASP license, accelerate the VASP 2026 licensing process and at the same time ensure AML/CFT compliance, bankability and a stable project economy. In this article I have compiled our practical experience, working checklists and a view of trends for 2024–2026 so that you can make an informed decision and move toward ROI without unnecessary iterations.

Choosing a VASP jurisdiction in 2026

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Regulators are increasing their focus on virtual assets, and investors — on the quality of corporate governance and operational resilience. A strong VASP license is not only a legal foundation but also a gateway to correspondent banking relationships, access to PSPs and institutional clients. The key to success: aligning VASP 2026 requirements, economic presence (substance), technological maturity and transparent AML processes.
In recent years the COREDO team has implemented projects in the Seychelles and Mauritius for exchanges and brokers as well as for custodial providers. COREDO’s practice confirms: a properly designed corporate structure for an offshore VASP, preparation for fit and proper tests and precise implementation of the Travel Rule and KYT provide a significant advantage during licensing and launch.

Comparison of Seychelles and Mauritius for VASP

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For VASP the strategic comparison of jurisdictions of the Seychelles and Mauritius focuses not so much on the attractiveness of the locations as on differences in regulation and practical compliance with requirements. Let’s review the key differences in the regulatory frameworks and approaches of the FSA and FSC to understand what risks and advantages each system carries.

Regulatory frameworks: FSA vs FSC

In the Seychelles supervision of VASPs is exercised by the Seychelles Financial Services Authority. The regulator relies on the local law on virtual asset service providers and general AML standards oriented to FATF recommendations for virtual assets. For VASP registration in the Seychelles the applicant prepares internal policies, appoints a responsible MLRO, describes custody architecture and demonstrates operational readiness.

In Mauritius Licensing is carried out by the Mauritius Financial Services Commission (FSC) under dedicated virtual assets and token services legislation. FSC requirements detail the functional classification of VASPs: exchange, broker, wallet (custodian), advisory, marketplace. For VASP registration in Mauritius the regulator expects a mature compliance program, management procedures and proven processes for sanctions screening and PEP checks.

Capital requirements and presence

VASP capital requirements in the Seychelles are structured by activity classes and are confirmed by paid-up share capital and liquid reserves. Economic presence in the Seychelles includes local control and reporting, availability of responsible persons and enforceability of service agreements.

VASP capital requirements in Mauritius depend on the licensed function and scale of operations, as well as assessment of operational risk and custody plans. Economic presence of a VASP in Mauritius is interpreted more broadly: a real office, local directors, a compliance officer and MLRO, regular board meetings on the territory, storage of key documentation and management records. In a number of projects the solution developed by COREDO provided for hiring key personnel with work permits and local SLAs for critical IT services.

Taxation, DTA and the impact of substance

Taxation for VASPs in Mauritius and the Seychelles differs significantly. Mauritius has a strong network of international double tax avoidance agreements (DTA) and a developed practice of applying OECD BEPS rules. This helps to structure inbound capital and cash flow, reduce the risks of double taxation and manage withholdings on cross-border payments. DTAs and Mauritius’s tax advantages are realized in a model with sufficient substance: real management, an office, local directors and compliance with economic tests.

In the Seychelles the tax regime is oriented toward international cooperation, participation in the CRS (automatic exchange of information) and meeting transparency requirements. The impact of economic substance on a VASP’s tax status in both jurisdictions is growing, especially in light of the Pillar Two initiatives (global minimum tax). Our experience at COREDO has shown: thorough documentation on risk management, transfer pricing and substance is the basis for a positive position in tax audits.

Banking services and bankability

Banking services for offshore VASPs are the main operational challenge. Correspondent banking relationships depend on FATF status, the bank’s understanding of the VASP model and the quality of AML/KYC/KYB processes. In Mauritius bankability is noticeably higher when holding an FSC license and providing transparent reporting, including audits and on-site inspections. In the Seychelles banking is also solvable, but more often through specialized EMIs/PSPs and a multi-layered cash flow scheme.

In COREDO projects we develop an account roadmap: an operational account in a local bank, accounts in international EMIs, escrow for custody and segregation of funds, as well as integration with payment gateways and PSPs with demonstrable compliance with the Travel Rule.

Market access (passporting) and risks

A comparison of VASP licenses in the Seychelles and Mauritius from the perspective of market access reveals an important nuance: the jurisdictions do not provide direct passporting to the EU or the UK. However, Mauritius, thanks to its ties with Africa and its status as a reliable financial center, facilitates access to African markets and interaction with institutional investors. The Seychelles follow a different strategy: focusing on flexibility, speed and the cost of compliance, which suits global digital models with a distributed client base.

The impact of MiCA on offshore VASP licenses is increasing: targeted marketing in the EU will require MiCA compliance and adherence to national regulator regimes. COREDO’s practice confirms: correct marketing policy and clauses in client documents reduce the risks of breaching local rules.

VASP License 2026: from application to go-live

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obtaining a license VASP in 2026 is a multi-stage procedure covering the path from application submission to actual go‑live and requiring coordinated work of lawyers, compliance and IT. Below we will analyze key timelines and stages in detail to help plan the process and minimize the risk of delays.

Stages and timelines

The standard route includes preliminary diagnostics, preparation of policies and procedures, gathering registration documents, submission to the FSC or FSA, responses to queries, conditional approval and the final go‑live with verification of operational readiness. Timelines and stages of obtaining a license for VASP depend on the category, custody complexity and chosen providers. In our practice in Mauritius the typical horizon is 4–6 months to conditional approval and another 1–2 months to fulfil the conditions; in the Seychelles: comparable with good preliminary preparation.

Checklist of registration documents

  • corporate documents, charter and the share capital structure;
  • disclosure of beneficiaries (UBO) for VASP, compliance with UBO register rules;
  • business plan, financial models, OPEX calculation and liquidity reserves;
  • VASP compliance program 2026, AML/CFT policies, sanctions procedures and screening;
  • technological requirements for VASP licensing: key management, custody, BCP/DRP;
  • agreements with critical providers: KYC/KYB, KYT, blockchain forensics, custody insurance.

The COREDO team structures the document package so that the regulator can see the connectivity: risks – controls, metrics – reporting.

Fit and proper, UBO and background checks

Requirements for directors and fit and proper tests imply competencies in risk management, financial reliability and relevant experience. Fit and proper procedures and background checks include verification of biographical information, conflicts of interest and sanctions lists. For UBOs, transparent tracing of ownership is important, including through trusts or foundations, as well as compliance with requirements for corporate governance.

In COREDO projects we perform an internal pre‑screen in advance to mitigate potential FSC/FSA queries and to justify the appointment of the MLRO, CTO and key functions.

AML/CFT 2026: operational control

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In the context of AML/CFT 2026 it is critical to shift the focus from drafting policies to real operational control that actually reduces risks. This requires strengthening KYC, KYB, sanctions screening and regular PEP checks at all stages of client interaction.

KYC, KYB, sanctions screening and PEP

KYC and KYB for VASP are fundamental. Regulators expect a risk‑based approach (RBA), client segmentation, geographic risk assessment and appropriate limits. Sanctions and screening in VASP operations must cover UN lists and major sanctions regimes, and PEP checks should take into account family and business ties. We usually integrate two providers for failover and to reduce false positives.

AML requirements for VASPs in Mauritius and AML requirements for VASPs in the Seychelles converge in spirit: demonstration of effectiveness, not only policies on paper. Regular AML training and employee testing with documented results help here.

Travel rule, KYT and blockchain forensics

The travel rule and its technical implementation: a sensitive element. For transmitting sender/recipient attributes we use compatible protocols and providers, taking into account privacy and local data laws. KYT (Know Your Transaction) practice is built on behavioral rules, thresholds and risk lists. For blockchain forensics and wallet attribution Chainalysis, Elliptic or CipherTrace are suitable – their correlation with SAR thresholds and internal typologies improves the quality of investigations.

AML implementation transaction monitoring for VASP relies on scenarios and manual reviews. At COREDO we set up performance metrics: escalation speed, average time to close an alert, and the share escalated to SAR.

MLRO and SAR: interaction with the regulator

The MLRO and the AML officer role include independence, access to the board of directors and the authority to stop transactions. SAR and the procedure for filing suspicious transactions are formalized with clear SLAs. In dialogue with the FSC/FSA, structured reporting, a log of decisions and regular AML/CFT 2026 effectiveness self-assessments for VASP management are helpful.

Requirements for VASP

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Technological and operational requirements for VASP define a set of standards and practices that ensure security and compliance when working with crypto assets. Special attention is paid to hot/cold wallet architecture, multi‑sig schemes, custodial governance models and insurance — these solutions form the foundation of operational resilience and client protection.

Hot/cold wallet and multi-signature architecture

Requirements for hot and cold wallets boil down to the principle of minimizing exposure and separating duties. Multi‑sig, cold wallet and hot wallet architectures are complemented by segregation of user funds and custody rules. For significant volumes I recommend custody insurance and independent cold storage audits, including a technical assessment of key protection (key management).

Custody rules and crypto asset storage imply detailed procedures for access, logging and emergency scenarios. The solution developed at COREDO often includes hardware modules, version control and regular drill tests.

Cybersecurity: SOC2, ISO27001, ISAE

Cybersecurity for crypto businesses in offshore jurisdictions: a mandatory block. SOC 2 and ISO 27001 security requirements increase trust from banks and institutions. ISAE 3000 / ISAE 3402 audits are appropriate for service providers. In COREDO projects we perform a pre‑assessment, close critical controls and plan certification together with licensing.

Operational resilience BCP/DRP

Operational resilience and BCP/DRP plans are reviewed by the regulator for plausibility: RTO/RPO, provider failure scenarios, crisis communications. Requirements for reserve capital and liquidity depend on the VASP class and risk profile. We build buffers for stress scenarios, test the failure of key systems and document the results.

Structuring and tax model

A well-designed corporate structuring directly determines the practical applicability of the chosen tax model and the level of legal risk for the business. In the following subsections we will examine in detail the options for organizing a VASP offshore, the related tax consequences and practical measures to minimize risks.

VASP structure in offshore jurisdictions

Corporate matters include the choice between exchange, custody and broker as distinctions of licenses: exchange vs custodian vs broker. Corporate governance (corporate governance) provides for independent directors, a risk committee, regular meetings and minutes. We take into account issues of hiring local personnel and work permits, especially for the CTO and compliance officer.

The administration of trust structures and foundations is possible for holding IP or reserve assets, provided there is UBO transparency and compliance with the UBO register.

Transfer pricing, CRS, BEPS, Pillar Two

CRS (automatic exchange of information) and OECD BEPS rules require proper documentation of intercompany services and rates. Transfer pricing and transactional schemes must reflect substance and market conditions. Pillar Two — the global minimum tax — becomes a factor when planning profits and royalties.

Capital, investments and exit/M&A

Structuring incoming capital and investments includes convertible instruments and pre-set investor rights. Exit strategy and preparation for M&A depend on the soundness of compliance, audits and the contractual framework. Our experience at COREDO has shown: early preparation of the data room shortens deal timelines and increases valuation.

COREDO case studies and takeaways

COREDO’s practice is based on real cases and concise extracts of experience that help quickly identify practical solutions and risks. In the first subsection we will analyze VASP registration in Mauritius and the key findings useful for similar tasks.

VASP registration in Mauritius

One client entered as a broker and exchanger with the prospect of custodial services. We built a roadmap: licensing crypto exchangers and exchanges in Mauritius, economic presence of the VASP in Mauritius, integration with two PSPs. Result – stable account openings, proper reporting, first institutional clients and a transparent ROI of the VASP license in Mauritius.

Cryptocurrency exchange licensing in the Seychelles

Another project included licensing of crypto exchanges in the Seychelles with a focus on speed and modular architecture. We accounted for AML requirements for VASPs in the Seychelles, arranged custody insurance and cold storage audits, implemented Chainalysis and sanctions screening. The client entered the Asian and African markets with a careful marketing policy without violating European regulations.

Bank servicing and integration with PSPs

In both cases we built correspondent banking relationships and banking coverage through a combination of a local bank, EMI and PSP, and also provided for restrictions on marketing and attracting EU/UK clients in accordance with MiCA and local rules. COREDO’s practice confirms: preparing a FATF compliance dossier for a VASP increases the speed of account openings.

Cost of compliance and ROI

Assessing the cost of compliance is not only about initial investments but also an ongoing burden on the budget that directly affects expected ROI. To properly calculate returns, OPEX, licensing fees and annual payments must be analyzed separately.

OPEX and annual licensing fees

The cost of compliance and operating OPEX includes the licensing fee and annual payments, audit costs, AML/KYT platforms, cybersecurity and personnel. Add office expenses, substance and external consultants. We set budgets by stages so that funding proceeds in sync with regulatory progress.

VASP license ROI in Mauritius vs Seychelles

The advantages of a VASP license in Mauritius are reflected in better banking, DTAs and attractiveness to institutions. The drawbacks of a VASP license in the Seychelles include more scrutiny from banks and the need to combine EMIs/PSPs, but there are lower entry barriers and greater flexibility. ROI analysis: the time to profitability for a VASP depends on marketing, product depth and customer acquisition cost; the right jurisdiction reduces operational frictions.

Regional expansion and scaling

Scaling operations and regional expansion require pre-planned modularity: additional licenses, the availability of regional accounts, and expansion of the compliance team. Passporting and access to African and EU markets are achieved through local licenses and partnerships, not through a “universal” offshore license.

Impact of MiCA on 2024–2026 trends

New regulatory trends during 2024–2026 are substantially changing requirements for the digital assets market, and MiCA’s influence is already setting benchmarks for enforcement and compliance. In the following subsections we will examine how these changes are reflected in European rules for VASPs and what service providers will need to take into account.

MiCA: EU rules for virtual asset service providers

MiCA and European rules for VASPs raise the bar for operational maturity: segregation of funds, customer protection, reporting and IT‑controls. MiCA’s impact on offshore VASP licenses: the need to combine offshore operations with an EU registrar or partners to work with EU residents.

Virtual assets, FATF recommendations

FATF compliance for VASPs is an informal “currency of trust”. Regulators expect a clear linkage between risks and controls, including Due Diligence providers for VASPs, scenario monitoring and SAR‑procedures. The COREDO team pays attention to country‑risk models and periodic risk reassessment.

Regulatory sandboxes and innovation

A regulatory sandbox for crypto firms in Mauritius and in a number of other countries helps test new models at a limited scale. It is suitable for stablecoin‑mechanics, on‑chain custody and integration with e‑money providers. We use the sandbox as a step toward a full license, especially for complex technology stacks.

Risk checklists

Risk management and regular checklists help to identify vulnerabilities in advance and reduce the likelihood of non-compliance during inspections. Next we’ll review compliance with FSC/FSA requirements and practical steps for preparing for on-site inspections.

On-site inspection for FSC/FSA

Regulatory reviews and on-site inspections include interviews, selective transaction reviews, testing of BCP/DRP and verification of reporting. Reporting requirements in FSC / FSA cover regular reports, audits and VASP inspections. Our checklist includes a self-assessment of key controls and readiness for spot-checks.

Nominee directors

Nominee directors and the risks of abuse are a separate topic. I recommend real directors with relevant expertise and time to perform their duties. Corporate governance issues are addressed through committee charters, authority matrices and independent audits.

Marketing restrictions in the EU and Britain

Restrictions on marketing and customer acquisition in the EU/UK require a legal opinion and correct implementation of disclaimers. Cross-border operations and VASP compliance include review of local rules, specifics of financial advertising and withholding taxes. In COREDO projects, legal memoranda and practical guides reduce the risk of violations.

COREDO Licensing Roadmap

When building the COREDO licensing roadmap, COREDO focuses on aligning business processes and technical solutions to minimize risks and accelerate engagement with regulators. Within this strategy, the choice of technology stack and vetted due diligence providers that ensure compliance and transparency at every stage is especially important.

Stack and due diligence providers

We select technology stacks for VASP (KYC/AML vendors) taking into account performance, accuracy and cost. We integrate Chainalysis / Elliptic / CipherTrace, two KYC/KYB providers, a travel-rule platform and sanctions screening. For payments: integration with PSPs, account segregation, reconciliation and limit controls.

AML training and compliance program

The VASP 2026 compliance program is built as a living system: policies, playbooks, metrics, training. AML training and employee testing are mandatory for all roles, including product and support. We prepare VASP reporting, audits and inspections in a format convenient for regulators, banks and investors.

Hybrid models: custody, broker, exchange

The functional classification of a VASP defines the scope of the license: exchange, wallet, custody. For hybrid models, boundaries of responsibility, requirements for reserve storage, cold storage audits and custody insurance are important. We also evaluate opportunities for licensing stablecoin and e‑money through partnership schemes and local licenses.

Brief risk profile Seychelles vs Mauritius

  • Seychelles: speed, flexibility, affordable compliance costs; greater focus on EMIs/PSP; important to carefully establish AML/KYT and demonstrate the effectiveness of controls.
  • Mauritius: strong DTA network, developed banking sector, focus on substance; higher requirements for an office and team; a convenient platform for Africa and institutional flows.
Reputational risks when choosing a VASP jurisdiction are reduced with a transparent structure, quality audits, and clear communication with banks and partners.

Key takeaways

Licensing a VASP is not “getting a piece of paper” but building an operating system trusted by clients, banks and regulators. Seychelles offers speed and flexibility; Mauritius: stability and a tax-treaty network. The choice depends on the product, target markets, appetite for banking and the willingness to invest in substance.

The COREDO team has gone through this journey with different models: from crypto exchanges to custodians. I see how proactive AML/CFT planning, technological discipline, a proper corporate structure and respect for regulators’ requirements transform a launch from a ‘risk’ into an ‘investment’. If you are building a VASP in 2026, start with a risk map, define target markets taking into account MiCA and FATF, assemble a strong team of directors and an MLRO, and then sequentially close out issues related to custody, banking and reporting. COREDO’s practice confirms: this approach shortens timelines, reduces OPEX and accelerates the path to sustainable ROI.

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