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

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

Illustration for the section «Choosing a VASP jurisdiction in 2026» in the article «Seychelles vs Mauritius VASP license 2026»

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

Illustration for the section 'Comparison of Seychelles and Mauritius for VASP' in the article 'Seychelles vs Mauritius VASP license 2026'
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

Illustration for the section “VASP License 2026: from application to go‑live” in the article “Seychelles vs Mauritius VASP License 2026”
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

Illustration for the section «AML/CFT 2026: operational control» in the article «Seychelles vs Mauritius VASP license 2026»
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

Illustration for the section 'Requirements for VASP' in the article 'Seychelles vs Mauritius VASP license 2026'
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.

I regularly meet executives who are ready to scale work with digital assets, but are stuck on two things: the BaFin license and the architecture of secure key storage. Since 2016 the team COREDO has supported dozens of projects for company registration in the EU and Asia, obtaining financial licenses and building compliance functions. During this time I have gathered a set of proven approaches that really save time and reduce operational risks. In this text I will systematically go through the path from legal structure to key architecture and regulatory reporting – with a focus on Germany and BaFin, but taking into account MiCA and EU requirements.

Our experience at COREDO has shown: a strong custody service doesn’t start with HSM, but with a clear regulatory model, a comprehensible operational architecture and compliance discipline. Technology is an important layer here, but without the right license, contractual framework and AML/KYC procedures the business risks getting a stop signal at the start.

Regulatory framework of Germany and the EU

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The regulatory framework of Germany and the EU increasingly shapes requirements for the handling and storage of crypto-assets, setting standards for licensing, supervision and investor protection. Below we will examine the key elements of oversight – including the role of BaFin and the specifics of regulating crypto custody.

BaFin regulation of crypto custody

In Germany, crypto custody (Kryptoverwahrgeschäft) is a licensed activity for the storage of third parties’ private keys. A BaFin license for key storage is required if you provide clients with custody of cryptocurrencies for business purposes, including corporate wallets, sub-accounts and API access. The regulator refers to the KWG (banking law), MaRisk (risk management) and BAIT (IT requirements), as well as the German AML law (GwG). Crypto-custody regulation in Germany implies segregation of client assets (segregation of client assets), clear internal controls, independent risk management and audit.
A couple of important nuances. BaFin supervision closely looks at the actual storage of private keys and operational processes, not only the legal structure. And if your model includes custodial staking, the regulator expects risk disclosures, a liquidity policy, management of slashing risk and contractual mechanisms for the allocation of rewards and costs.

MiCA: impact on BaFin custodians

The MiCA regulation forms a pan-European framework for crypto-asset service providers, including custodians. For Germany this means alignment of requirements, the possibility to passport custody services within the EU when meeting pan-European standards, and harmonization of reporting. COREDO’s practice confirms: if you build processes “according to MiCA” already at the stage of preparing for a BaFin license, subsequent expansion to other EU countries proceeds faster.
MiCA does not eliminate national specifics – BaFin will retain the right to inspections, the requirement for IT resilience and expectations for incident management. But the common language for compliance, risk-based approach and information security will become unified across the EU, which simplifies scaling.

AMLD5 and AMLD6: AML/KYC and GDPR

AMLD5 and AMLD6 set the level of control for business KYC providers, AML transaction monitoring and sanctions screening. In Germany these rules are implemented in the GwG; the regulator expects a risk-oriented approach, client segmentation, monitoring scenarios and a documented escalation methodology. In custody GDPR and key storage intersect through personal data of owners, activity logs (audit trail) and access logs. I recommend implementing data minimization and a strict role-based access model: this reduces risk and facilitates passing inspections.

BaFin license for crypto custody

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BaFin‑Licensing of crypto custody requires strict compliance with regulatory requirements and transparent documentation. Below we will examine in detail the stages and structure of obtaining the license, including the key legal, operational and technical criteria for successfully completing the process.

How to obtain a BaFin custody license

I recommend starting with the legal structure for custody in the EU (GmbH, AG). For crypto custody in Germany a GmbH is usually suitable, while mature players planning to raise capital choose an AG. Capital requirements for custody depend on the service profile; for pure storage of private keys the starting capital is usually from €125,000, and is higher when combined with payment services. The cost of obtaining a BaFin license consists of document preparation, technology implementations (HSM/MPC), hiring key personnel (MLRO, CISO, Head of Risk), certifications (ISO 27001, sometimes SOC 2 Type II), insurance and legal support.

According to COREDO’s observations, a conservative project budget often falls in the mid- to multi-million euro range, depending on scale, geography and degree of automation.

Process stages:

  • Pre-licensing gap analysis against BaFin/BAIT/MaRisk and MiCA.
  • Designing the operational model: custody vs non-custodial, cold/hot storage, MPC or multisig, key ceremony protocol and key rotation policy.
  • Building compliance: AML/KYC, sanctions screening, risk-based approach, incident management and notifications to the regulator.
  • IT and security: HSM (Hardware Security Module) or MPC (Multi-Party Computation), cold key storage infrastructure, air-gapped signing, audit trail and logging.
  • Documentation and submission: policies, regulations, client agreements, legal agreements for HSM outsourcing.
  • On-site inspections and responses to inquiries.

Checklist for preparing for a BaFin inspection

The COREDO team has conducted dozens of pre-licensing “dry” audits and compiled a checklist for preparing for a BaFin inspection:
  • Governance: qualified executives, independent risk and compliance, information security committee.
  • Policies and procedures: private key storage requirements, access management and role models in custody, key ceremony and backup, disaster recovery plan and business continuity plan.
  • IT governance under BAIT: asset inventory, vulnerability management, change management, incident response.
  • Security: BaFin HSM security requirements, description of MPC/threshold signatures, multisignature and key storage, cold wallet architecture and hot wallet risk.
  • Quality control: penetration testing and red team, bug bounty programs, security audit for crypto custody, SOC 2 Type II audit if available, ISO 27001 certification.
  • Finance: capital requirements, OPEX vs CAPEX model, ROI calculation for security investments and overall financial plan.
  • Contract framework: preparation of custody agreements for corporate clients, SLA 99.9% availability, key storage regulations and GDPR, fiduciary duty for custodians, segregation of client assets, trustee model custody.
  • Reporting: BaFin regulatory reports, security metrics for BaFin reporting, incident notification policies.

Supervision and incident reporting

BaFin expects transparent incident management and notifications to the regulator in case of material failures, breaches or risks to clients’ funds. Notification timings align with GDPR (generally within 72 hours for personal data) and internal regulations. I recommend drafting in advance a criticality matrix, an escalation procedure, a communications role model and message templates for the regulator and clients. Regular regulatory reports to BaFin include information security and operational resilience KPIs.
Enforcement action precedents show that the regulator is particularly sensitive to commingled asset storage, weak access policies and insufficient transaction monitoring. COREDO’s practice confirms: a mature audit trail, forensic readiness and automated access control simplify communication with supervision.

Key storage architecture

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Building the technological architecture for key storage defines a set of decisions responsible for the security, availability and manageability of cryptographic materials. In the following subsections we consider the role of HSMs and outsourcing options for critical components to show how different approaches affect risks and operational requirements.

Outsourcing critical components and HSM

HSMs, the de-facto standard for protecting master keys, are especially important when supporting Bitcoin and Ethereum in custody and managing corporate sub-accounts. BaFin looks at HSM certification (e.g., FIPS 140-2/3), key lifecycle management, load/unload policies and role models. Outsourcing HSMs and the legal risks must be addressed separately: agreements with providers, third-party risk management, requirements for locations and verification procedures.
The solution developed at COREDO usually combines HSMs for root secrets and MPC for operational flexibility. This approach increases resilience and simplifies scaling as the number of clients and transactions grows.

MPC, multisig and secret sharing

MPC for key storage and threshold signatures allow the signing computation to be split across multiple independent nodes, reducing the risk of a single point of failure. Multisignature and multisig key storage architectures remain relevant for Bitcoin’s UTXO model and some enterprise scenarios. Shamir’s Secret Sharing is suitable for backups and recovery procedures, but I don’t use SSS for online signing when MPC is available.
A combination of cold wallet architecture with air-gapped signing and a hot environment with limited limits increases security and operational flexibility. Key rotation policy must take L2 protocols and smart contracts into account, especially for cross-chain custody and when working with wrapped tokens. Key ceremony and backup procedures are documented in detail, with video recording and checklists.

Fault tolerance, scaling and audit

Designing a fault-tolerant key architecture includes distributed key storage for scaling, geo-replication, independent quorum channels and deterministic run-books for incidents. A multi-tenant custody platform requires strict segmentation, circuit isolation and continuous monitoring. Audit trail and logging must cover administrative actions, transactions, access to secrets and configuration changes.

I build in forensic readiness: time synchronization, immutable logs, a retention policy and regular recovery tests. Incident response and notification are practiced scenarios with roles, timers and feedback loops. This saves hours during real crises and increases client trust.

Custodial staking: risks

Staking-as-a-service for corporate clients raises questions about liquidity management, reward distribution, validator fees and slashing risk. Liquidity management in custodial staking requires buffers, transparent unbonding rules and synchronization with accounting. In contracts I record protocol risks, responsibility for validator selection and the compensation procedure for slash events.
Smart contracts, custodial vs non-custodial models, support for ERC-20 and ERC-721 and integration of layer-2 and custody (for example, rollups): all of this is reflected in risk methodologies. Our architects at COREDO form a risk profile for each network stack separately.

Assets, integrations and SLA

Support for Bitcoin (Bitcoin UTXO model) and Ethereum requires different addressing logic, monitoring and nonce/fee control. For business I set up custody API integrations with exchanges and brokers via API integration (REST, WebSocket), with restrictions by keys, IP allowlist and a fine-grained limit system. Enterprise onboarding processes include corporate client Due Diligence, issuance of sub-accounts and configuration of role models.
SLA 99.9% availability is a fair benchmark for custody, while transaction creation time and approval delays depend on the number of signatures and the limit policy. Setting SLAs for crypto custody services provides RTO/RPO for infrastructure, maintenance windows and a plan for functional degradation.

Risk management and compliance

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Effective risk management and strict compliance require a systemic approach to identifying and mitigating financial threats. In this context, AML/KYC and regular transaction monitoring become key tools to prevent fraud and money laundering.

AML/KYC: transaction monitoring

Compliance for crypto custody Germany is built on a risk-based approach: segmentation of clients by jurisdictions, types of activity and volumes. AML KYC for crypto custody requires reliable KYC providers, periodic review processes (KYC refresh), sanctions checks and transaction monitoring using behavioral and blockchain analytics. Sanctions screening and lists of high-risk wallets are better automated, but manual review should be retained for complex cases.
AML transaction monitoring should include scenarios for the microstructure of transfers, analysis of sources of funds and behavior when using mixers. I define clear rules for escalation and suspension of operations so the team does not lose time on approvals at critical moments.

Resilience and security

ISO 27001 certification for custodians and a SOC 2 Type II audit are strong arguments for BaFin and corporate clients. They are complemented by regular penetration testing and red team exercises, bug bounties and independent code reviews for custom components. Transparency through the implementation of proof of reserves for custodians and attestation reports increases trust, especially with large corporate deposits.
Security metrics for BaFin reporting and key KPIs for CTO/CISO may include: MTTR for incidents, proportion of critical vulnerabilities, average patch-management time, percentage of MFA/SSO, frequency of key rotation, share of transactions processed through expedited scenarios, and results of independent audits.

Insurance and fiduciary duties

Insurance of crypto custody assets: a separate track. Custody insurance policy and underwriting of crypto risks take into account limits for hot and cold wallets, exclusions and deductibles. How to choose an insurance product for a custodian? I assess the insurer’s financial stability, cyber-risk coverage, limits on social engineering and control requirements.

Fiduciary duty (fiduciary duty for custodians) and segregation of client assets are critical in the event of a custodian’s bankruptcy and in protecting clients. A proper contractual and operational model (for example, trustee model custody) helps separate client assets from the insolvency estate. COREDO’s experience has shown: clear ownership registers and segregation at the level of addresses/smart contracts simplify law enforcement.

Data privacy and regulations

The key storage policy and GDPR go hand in hand with data governance: minimization of personal data, encryption «at rest» and «in transit», access management and retention. Logging and observability should not disclose sensitive elements of key infrastructure, and log sizes should not exceed what is reasonably necessary. We balance this through anonymization, pseudonymization and strict telemetry control.

Strategy and economics of launching a service

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The project’s economics and the chosen strategy shape the decision-making framework during preparation and launch of the service, setting priorities for resources and the acceptable level of risk. Below we will examine in detail the cost model, required capital and key ROI metrics to build a justified go-to-market plan.

Cost model and ROI

OPEX vs CAPEX модель помогает прозрачнее коммуницировать с советом директоров. CAPEX, HSM, сети, лицензии на ПО, сертификации; OPEX – штат комплаенса и ИБ, страховки, аудит, колокации, bug bounty. Стоимость получения лицензии BaFin и последующее содержание зависят от масштаба.

The ROI estimate for launching a crypto-custody service is built on revenue from custodial services, transaction fees, staking rewards (if applicable), and cost savings from in-house risk control.
How to estimate ROI from implementing your own crypto-custody? I model scenarios along three lines: organic growth of the corporate customer base, cross-sales (for example, exchange/trading/payments) and retention thanks to high SLA and security. The ROI calculation for security investments takes into account the probability of incidents and potential damage; this is an important argument before the investment committee.

In-house vs third-party and white-label

The comparison of in-house vs third-party custody boils down to control, speed of launch, and the regulatory curve. White-label custody solutions allow faster market entry but increase dependence and requirements for third-party risk management. Migration of crypto-assets between custody providers — a scenario I plan for at the start — includes procedures for key rotation, attestation of balances and client notifications.

Outsourcing HSM legal agreements require clear SLAs, audit rights, requirements for data geography and recovery plans. Third-party risk management includes periodic assessments, stress tests and forensic clauses in contracts.

Operational resilience and SLA

Operational resilience: not only data-center redundancy, but also disaster recovery plan drills, degraded-mode business processes and client communications. SLAs should cover availability, transaction processing time, maintenance windows and RTO/RPO. I always link SLA settings for crypto-custody services to team KPIs and bonus models: this way SLA ceases to be “paper” and becomes a practical tool.

COREDO case studies: licensing and integration

In a series of COREDO case studies we show practical steps – from obtaining a license to real bank integration scenarios. Using the example of Germany, we examine BaFin’s requirements, key architecture and technical solutions necessary to comply with regulatory and banking requirements.

BaFin: license and key architecture

The COREDO team recently implemented a project for a fintech planning custody for large corporate clients. We chose a GmbH, prepared the BaFin submission package, deployed HSMs for master keys and MPC for operational signing. The client obtained ISO 27001 certification, underwent a SOC 2 Type II audit and set up proof-of-reserves methodologies with regular attestation reports. The contractual framework established segregation of client assets and a trustee-model custody, as well as terms for custodial staking and disclosure of slashing risk.

At the pre-audit stage we ran a practical checklist to prepare for the BaFin review, ‘dry’ key ceremonies, an incident response test and tuning of regulatory reports. The solution proved resilient, and the final regulatory dialogue took less time than we had planned in our risk scenarios.

EU passporting after launch

Another client launched custody in Germany with an eye on the EU. We built a model compatible with MiCA and prepared EU passporting for custody services. The legal structure and policies immediately accounted for Cyprus and Estonia’s requirements for IT resilience and staffing, which accelerated regional expansion.

Our experience at COREDO has shown: unifying policies and a single key architecture reduces total cost of ownership and simplifies change management.

Integration into a banking group

A separate case — implementing custody in a banking group with presence in the UK, Singapore and Dubai. We integrated custody into the bank’s structure via API, REST/WebSocket, supporting corporate accounts and sub-accounts. For the CTO/CISO we set up key KPIs, reports for risk committees and regular red team exercises.

Practice has shown that BAIT discipline and banking IT standards map harmoniously onto crypto custody if roles and processes are organized correctly.

Practical tools

To minimize risks when choosing a custody provider, rely on practical methods and tools that turn abstract requirements into concrete checks. Below is a compact checklist for reviewing custody providers with key criteria for security, compliance and operational reliability.

Checklist for reviewing custody providers

Reviewing custody providers: a checklist for the director

  • Licenses and supervision: BaFin license for crypto custody, MiCA plans, regulatory history, inspection precedents.
  • Security: HSM/MPC, key ceremony protocol, air-gapped signing, penetration testing, bug bounty, ISO 27001/SOC 2.
  • Operations: SLA 99.9%, incident response, disaster recovery, business continuity, audit trail.
  • Compliance: AML/KYC, sanctions screening, AML transaction monitoring, GDPR.
  • Legal: segregation of client assets, trustee model custody, insurance, outsourcing, HSM legal agreements.
  • Technology: support for Bitcoin/Ethereum, ERC-20/ERC-721, layer-2 and custody, cross-chain custody, API REST/WebSocket.
  • Economics: fees, limits, OPEX vs CAPEX, ROI assessment.
  • Migration: export of keys/addresses, proof of reserves during transition, timelines and risks.

What to include in contracts and SLAs

Preparing custody agreements for corporate clients should specify:

  • Scope of services, supported assets, custodial staking requirements.
  • Segregation of assets, fiduciary duty, insurance and limits.
  • Incident management and regulator notifications, RTO/RPO, maintenance windows.
  • Key policies: private key storage requirements, key rotation, access controls.
  • Proof of reserves and attestation reports, audit rights.
  • Management of custody operational risks and third-party risk management.

Recovery after key compromise

A key recovery plan after compromise should include:

  • Identification of the affected area and containment scenario.
  • Generation of new keys (key ceremony), transfer of assets, policy updates.
  • Communications: clients, regulator, counterparties.
  • Forensics package: collection of artifacts, preservation of logs, independent analysis.
  • Post-incident plan: lessons learned, control updates, retesting and attestations.

Frequently Asked Questions and Short Answers

Which legal structures are optimal for custody in Germany? GmbH – a flexible start; AG: for mature capital and exchange plans. In both cases consider capital requirements and governance requirements.
How to obtain a BaFin license for custody and how long does it take? The readiness of the company and the documentation package determines the timelines. Mature processes and IT significantly speed up the dialogue. Budget and team are key to predictability.
What SLA metrics are important for corporate custodian clients? Availability, signature latency, RTO/RPO, incident handling time and reporting accuracy. Plus security metrics: key rotation frequency, MFA coverage and time to patch.
How to choose an insurance product for a custodian? Look at coverage of hot/cold wallets, exclusions, limits, payout terms and control requirements. Compare underwriting criteria and the insurer’s financial stability.
How to assess the ROI of implementing your own crypto custody? Sum new revenue, risk savings, synergy with existing services and cost of capital. Don’t forget growth scenarios and stress tests.

Conclusions

Custody is not just about storing keys. It’s about trust, predictability and a mature operational model. I’ve seen projects with strong architecture and compliance discipline obtain a BaFin license for key custody and quickly scale across the EU thanks to MiCA. I’ve also seen the opposite: when savings on processes and documentation come back as delays and additional requirements.

COREDO doesn’t offer magical shortcuts. But we do have the tools, practices and experience that make this path manageable: from choosing between HSM and MPC to BaFin regulatory reports and proof of reserves. If you are planning a custody case in Germany, Czechia, Slovakia, Cyprus, Estonia, the United Kingdom, Singapore or Dubai – let’s break it down into clear modules, calculate ROI and build an architecture that will withstand both regulatory audits and the requirements of your corporate clients. COREDO’s experience shows: a systematic approach pays off faster than promises to ‘do everything in three weeks’.

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