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I have been leading COREDO since 2016 and see every day how Open Banking is changing the rules of the game for banks, fintechs and customers. Open banking APIs have moved from an idea to the infrastructure on which payment services, account aggregators, BaaS platforms and embedded finance are built. By 2026 the sector will enter a new phase, with the transition from PSD2 to PSD3, a review of payment services licensing, strengthened AML/CFT and unified API security standards. In this article I will share COREDO’s practice: how to prepare architecture, licenses and processes to not only comply with the changes but also build a sustainable business model.

The COREDO team has implemented dozens of projects to register legal entities in the EU, the UK, Singapore and Dubai, obtained licenses for PISP and AIS, helped launch e-money and payment institutions, and set up AML, SCA and GDPR. Our experience at COREDO has shown: success is formed at the intersection of licensing, technology and operational control. Below: a practical roadmap I use myself when evaluating projects.

How to prepare for Open Banking 2026

Illustration for the section “How to prepare for Open Banking 2026” in the article “Open Banking in 2026 licensing changes”

Open Banking regulation is accelerating. In the EU, the PSD3 draft and the accompanying payment regulation (PSR) aim for unified rules for access to accounts (XS2A), stricter requirements for customer authentication (SCA) and a clearer liability model for Third-Party Providers. At the same time, the transition to a single Open Finance license is unfolding – from payment accounts to investment products, insurance and pensions, which opens new streams of data and services.
Licensing of Open Banking is becoming more detailed. Regulators are clarifying the criteria for PISP and AIS licenses for 2026, introducing additional capital adequacy requirements for e-money providers and capitalization standards for PSPs in 2026. Teams are preparing for mandatory FAPI and OAuth standards in 2026, unified requirements for API governance and cross-jurisdictional audit.
Changes affect the Open Banking business model following the tightening of licenses. Profitability is now built on precise calculation of unit economics, sound pricing policy for APIs, SLAs and a scalable architecture. A solution developed at COREDO for one European fintech increased profitability by rebuilding pricing (subscription + per-call), optimizing rate limiting and introducing revenue share for partners.

From PSD2 to PSD3: Open Banking changes

Illustration for the section «PSD2 to PSD3: Open Banking changes» in the article «Open Banking in 2026 changes in licensing»

The transition from PSD2 to PSD3 in 2026 removes previous grey areas. Regulators solidify the status of TPPs, introduce clearer supervision and audit procedures for TPPs in 2026, and make consent management mechanisms with explicit consent receipts mandatory. Banks will receive clear obligations on account access, and refusals to connect for technical reasons will require documented justifications and KPIs on API availability.
What will change in PSD3 rules for Open Banking in practice? Strengthening SCA and API security, standardization of requirements for API versions, for logging and forensic readiness, as well as new regulations on customer data management in Open Banking. The regulator will tighten control over the allocation of liability between the bank and the TPP so that customers are not left hostage to complex contracts.
At the same time, a transition from PSD2 to a unified Open Finance license is taking shape. I expect a phased rollout: first payment and information services, then expansion to investments and insurance. This means a new level of Due Diligence for providers, a revision of DPIA and a re-evaluation of data disclosure risks.

Licensing PISP, AIS, e-money

Illustration for the section «Licensing PISP, AIS, e-money» in the article «Open Banking in 2026: changes in licensing»

At COREDO we often start with a licensing map: service model, jurisdiction, target markets, revenue sources and risks. banking license vs e-money license are fundamentally different in capital requirements, supervision and functionality. For many embedded finance models, e-money and/or registration of a payment institution in the EU in 2026 provide the optimal balance between speed to market and coverage.
How to obtain a license PISP in the EU after 2025? I recommend starting 6–9 months in advance: a legal entity in a suitable EU jurisdiction, a business plan with unit economics, an SCA policy, a description of API security, contractual framework with banks and processors, an AML/CTF framework, as well as operational resilience and BCM. COREDO’s practice confirms: a strong technology risk assessment and DPIA reduce regulator questions and speed up the review.
Regulators are introducing tiered licensing models and modular licensing. Limited activity / lite licenses allow testing unit economics in one market and then expanding. Sandbox licensing for Open Banking is a working tool in Singapore (MAS APIX), in certain EU countries and in the Middle East. It is important to consider regulatory sandboxes and exit criteria: clear KPIs for risks, reporting and a scaling plan.
Passporting and the ban on passporting after Brexit have changed go-to-market strategies. In the EU passporting for payment licenses retains value, while in the United Kingdom a separate FCA license is required. Equivalence regimes and mutual recognition of licenses between the EU and the CIS are applied only to a limited extent, so international Open Banking licensing almost always requires a local strategy and the structuring of cross-border data flows.

Requirements for Open Banking APIs

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Requirements for Open Banking APIs in 2026 are consolidating around FAPI (Financial-grade API), OAuth 2.0 and OpenID Connect, as well as mTLS for mutual authentication. The mandatory nature of FAPI and OAuth standards in 2026 means rebuilding security profiles and reevaluating client SDKs. The COREDO team implemented similar profiles for an AIS provider: we implemented token binding, rotatable keys and strict scope management, which increased frictionless authorization rates and reduced incidents.
Interoperability will become a licensing requirement. Berlin Group and NextGenPSD2 define the API profile in the EU, and ISO 20022 affects payment integrations and message semantics. I recommend establishing API governance and versioning with explicit deprecation rules, and also introducing API SLAs, rate limiting and throttling to provide predictability for partners.
Security, not just encryption. Tokenization of payment data, encryption at rest and in transit, centralized secret management, mandatory logging, audit trails and forensic readiness — all of these are checked by regulators as part of prudential supervision. API security testing and pentest requirements are being embedded in licensing conditions; COREDO helps clients prepare for tests, implement bug bounties and formalize a Secure SDLC. For mature players, expectations of SOC 2 and ISO 27001 increase the chances of partnerships with banks.

Data privacy and GDPR

Illustration for the section «Data privacy and GDPR» in the article «Open Banking in 2026 changes in licensing»

GDPR compliance in Open Banking is foundational. Regulators require a Data Protection Impact Assessment (DPIA), data minimization mechanisms and privacy by design, clear procedures for data portability and interbank data. Consent management and consent receipts must be readable, and consent revocation should be quick, with clear legal consequences for stopping processing and deletion.
regulatory requirements for managing client data in Open Banking are tightening. I recommend appointing a data steward, documenting a retention and deletion policy, implementing DLP and data classification. Cross-border data flows and localization require data mapping and legal bases for cross-border transfers, especially when operating in Asia and the Middle East.
The role of digital identification eIDAS in Open Banking licensing is growing, and eIDAS 2 and digital identification of customers speed up onboarding and reduce fraud. W3C Verifiable Credentials and digital wallets provide a way to verify attributes without unnecessary data exchange. A solution developed at COREDO for a client in the EU integrated eID and VC into the KYC process, which reduced CAC and sped up account activation.

AML/CFT and risk management for TPP 2026

AML/CFT requirements for TPPs include a risk-based methodology, customer segmentation, risk ratings and monitoring scenarios. KYC/KYB automation and utilities for verifying beneficial ownership form the foundation for combating money laundering and sanctions risks. At COREDO we built multi-level scenarios for PISPs, including behavioral patterns, velocity rules and geo-risk.
Operational resilience and BCM, another focus. Regulators expect resilience plans, recovery testing, incident response and mandatory notifications to the regulator. Third-party risk management and vendor oversight are enshrined in policy; a vendor due diligence checklist helps select KYC providers, cloud platforms and processors in line with supervisory requirements.
Supervision and audit procedures for TPPs in 2026 cover regular reporting, independent AML audit and IT controls, as well as change control for APIs. The increase in AML risks with open banking in 2026 requires reliance on consortium fraud signals, sharing indicators of compromise and standardized formats for SAR/STR reports. COREDO’s practice confirms: early integration with regulatory portals reduces the burden on the compliance team.

Contracts and liability insurance

The TPP liability model must be reflected in agreements with banks and merchants. The allocation of liability between the bank and the TPP should take into account SCA, processing, API SLAs and error handling. Indemnity clauses and liability insurance (professional liability, cyber) cover tail risks and partners’ requirements for coverage limits.
Contract templates for API partnerships include sections on API SLAs, rate limits, maintenance windows, versioning, audits and security requirements. The legal consequences of a data breach via the Open Banking API are becoming stricter: in addition to GDPR fines partners build in contractual penalties and mechanisms for recourse claims. At COREDO we help establish the balance: achievable obligations and verifiable metrics.

Monetization and scaling

Market entry strategy for fintech with Open Banking combines licensing, pricing and partnerships with banks. Go-to-market for BaaS and embedded finance requires a clear role: license provider, technology orchestrator, or both at once. B2B2C and B2C API monetization differ in CAC, LTV and payback period; in the first case the focus is on corporate contracts and integrations, in the second on product and marketing.
Pricing models for APIs (per-call, subscription, revenue share) affect the unit economics of payment products. I recommend calculating ROI metrics: CAC, LTV, margin per transaction, fixed compliance costs and SLA expenses. Methods for calculating ROI of Open Banking projects with licensing costs should account for annual audits, pentest, insurance, regulator fees, as well as the budget for SOC 2/ISO 27001.
Scalability requires cloud-native and multi-region deployment, microservice architecture, an API gateway and an event-driven approach. How to scale BaaS amid new licensing requirements? Split stacks by jurisdiction, standardize security, centralize monitoring and logs, and simulate stress loads. The COREDO team implemented a similar architecture in two regions — the EU and Asia — with unified controls and localized data flows.

International markets and sandboxes

MAS APIX and Asian sandboxes allow testing products with banks and TPPs, practicing SCA and KYC in a controlled environment. Open Banking Nigeria is moving toward its own standards and local regulations, where data localization and exchange with the central bank are important. The Account Aggregator (India model) demonstrates how a consent architecture and standardized exchange create a scalable ecosystem.
Regulatory sandboxes and exit criteria (supervisory sandbox exit criteria) require clear KPIs, management reporting, and a plan for compliance with a full license. Which Asian markets are adapting new Open Banking licenses faster? Singapore and Hong Kong are moving rapidly; the UAE is accelerating requirements for BaaS and digital identity; some Southeast Asian markets are taking a phased approach, starting with payments pilots.
International licensing of Open Banking is inevitably linked to cross-border data flows. At COREDO we design localization matrices, sign standard contractual clauses and structure legal entities in the EU, the UK, Singapore and Dubai for lawful data exchange and processing.

COREDO Case Studies

Case 1: license for PISP and AIS in the EU. Client: a fintech focused on multibanking and real-time payments. The COREDO team handled payment institution registration, assembled the SCA and API security package, implemented FAPI, OAuth 2.0 and mTLS, configured a Berlin Group profile and ISO 20022 payments. In agreements with banks we secured allocation of liability, agreed API SLA and versioning. Result: license and connection to 30+ banks within 9 months.

Case 2: e-money + BaaS in the UK and EU after Brexit. The client required two licenses and separation of data flows. The solution developed at COREDO separated legal entities, standardized SOC 2/ISO 27001, implemented DPIA and privacy by design, and set up vendor oversight for KYC providers. Result – rapid rollout of embedded finance B2B2C products with a transparent revenue share model.

Case 3: Singapore and digital identification. For a local AIS/TPP we integrated eKYC, eID and W3C Verifiable Credentials, connected MAS APIX sandbox and completed sandbox licensing for Open Banking. After meeting KPIs the client moved to a full license, retaining all policies for BCM, incident response and regulatory reporting.

Case 4: M&A and due diligence checklist for Open Banking assets. An investor was considering the purchase of a provider with an AIS license. COREDO’s practice included verification of the license, capital requirements, API security posture, logs and audit trails, GDPR/DPIA, AML/CFT scenarios, insurance coverage, contracts with banks and allocation of liability. The buyer received a risk map and a 180-day integration plan.

Cost, timelines and compliance plan 2026

Question: how much does compliance with the new licensing rules cost? The estimate of the cost of complying with the new Open Banking licenses consists of the regulator’s initial fees, legal preparation, technology (FAPI, OAuth, mTLS, tokenization, logging), audits (IT/AML), pentest, insurance, SOC 2/ISO 27001 and staff expenses for compliance. In our observations, for PISP/AIS in the EU the first-year budget is often comparable to 12–18 months of burn-rate on compliance and security.
Question: what are the regulators’ timelines for implementing PSD3/analogs? In 2026 a transition period is expected, when old licenses remain valid but require upgrades for SCA, APIs and data. The transition periods to the new Open Banking licenses span several quarters; combined license-and-technical projects proceed faster.
Compliance roadmap 2026 and project plan should include: licensing (PISP/AIS/e-money/payment institution), technical API foundation, GDPR/DPIA and eIDAS, AML/CFT and scenarios, BCM and operational resilience, insurance, regulatory reporting and reporting format, as well as readiness for prudential supervision. The COREDO team recommends quarterly checkpoints so the regulator can see predictable progress.

Frequently Asked Questions from Clients

Question: how is liability allocated in fraud through a TPP? Liability is allocated according to contracts and regulator rules: if the TPP correctly applied SCA and complied with the SLA, the bank covers part of the losses; if the TPP violated SCA or processed the transaction without consent, liability shifts to the TPP. I insist on clear indemnity clauses and an investigation procedure.
Question: is it worth changing the jurisdiction of registration because of the new rules? Often there is no need to migrate if the market is key. It is far more productive to fine-tune licenses, strengthen API security, rebuild the DPIA and localize data for cross-border flows. In some cases, relocation for passporting in the EU or access to a sandbox in Asia can speed things up.
Question: can third-party KYC services be used to comply with the new licenses? Yes, subject to vendor due diligence, technical and legal SLAs, AML/CFT compliance checks and data protection. At COREDO we create a vendor due diligence checklist that includes sanctions screening, SLA stress tests and failover plans.
Question: what will change in PSD3 for Open Banking? SCA will be strengthened, API requirements will be standardized, liability will become clearer, and consent management will become central. The regulator will expand oversight of TPPs, and banks will receive clear obligations regarding access to accounts, which will simplify onboarding.
Question: how will the new licensing rules affect banks and fintechs? Banks will update APIs and security, strengthen vendor controls and standardize contracts. Fintechs will invest in security, AML and architecture, but will benefit from greater predictability and higher market trust.

XS2A and API Security Checklist 2026

XS2A (account access) in 2026 means: FAPI profile, OAuth 2.0, OpenID Connect, mTLS; SCA and API security; Berlin Group/NextGenPSD2 and ISO 20022; API governance and versioning; API SLA, rate limiting and throttling; tokenization, encryption at rest/in transit; logging, audit trails and forensic readiness; API security testing, pentest; SOC 2 and ISO 27001. At COREDO we turn this list into an actionable project plan with assigned owners and timelines.

BaaS and embedded finance: risks and growth

Banking-as-a-Service provides fast access to the market but carries operational risks. BaaS licensing and compliance require transparent allocation of responsibilities, supplier controls, regular audit procedures and stress-testing of processes. How to scale BaaS under new licensing requirements? Split responsibility at the contract level, embed security into the architecture and maintain unified logging and reporting standards.
Data monetization and privacy coexist if you use privacy by design, consents and data minimization. Pricing models for APIs – from per-call to subscription and revenue share – must take into account throttling, caching layers and ISO 20022 conversion, otherwise unit economics will be “eaten” by performance costs.

Bank and TPP agreements: changes to the rules

Bank and TPP agreements in 2026 are best structured using modular templates: licenses and compliance; API and security; SLA and versioning; liability and indemnity; data and GDPR; audit and supervision. Fix allocation of liability mathematically: coverage percentages, limits, and investigation procedures. Add liability insurance (cyber, professional liability), as well as clauses on mandatory notifications and recovery timeframes.
COREDO implements contract packages with appendices for API SLAs and security profiles to reduce negotiation cycles. This approach speeds up integrations and increases predictability for all parties.

Summary for executives and directors

Open Banking 2026 is about maturity: licensing, API security, GDPR, AML/CFT and operational resilience. The business model wins when licenses and technology work together: then ROI becomes predictable and growth manageable. The COREDO team helps guide the journey from registering a payment institution to international scaling, linking regulators’ requirements with real business metrics.
If you are planning a fintech license in the EU for 2026, preparing for PISP and AIS licenses in 2026, or combining BaaS and e-money, start with a requirements map: PSD3/PSR, GDPR and DPIA, FAPI/OAuth/mTLS, AML/CFT, BCM, reporting, insurance and contracts. Next, structure jurisdictions, budget for compliance, choose API standards and prepare the team for supervision.
I believe in Open Banking that creates transparency, competition and new services. And I know from COREDO’s experience: when licensing strategy, architecture and compliance align, the market responds with trust, and the product with growth.

Since 2016 I’ve been leading COREDO through dozens of licensing processes, hundreds of registrations and thousands of pages of contracts. The greatest value for clients is not the mere fact of obtaining a license, but a stable contractual framework that lays out the rules of the game: it is the payment system’s public offer that determines user trust, the reliability of settlements and the protection of funds. Europe is now moving to a new regulatory architecture: PSD3 and PSR, and the public offer is becoming a critical document that affects the business model no less than code and processing.

The COREDO team has already adapted offers for PSPs, EMIs and technology providers in the EU, the UK, Singapore and Dubai. Our experience shows: a correct “PSD3 public offer” saves quarters of time, millions on compliance and reduces the likelihood of regulatory sanctions. In this article I provide a practical framework, examples and checklists that we use on projects, and explain how to turn the offer from a legal file into a working operational tool.

Update of the public offer for PSD3/PSR

Illustration for the section «Update of the public offer for PSD3/PSR» in the article «Public offer of the payment system under PSD3 and PSR»
PSD3 and the PSR (Payment Services Regulation) reallocate requirements between the directive and the regulation: some rules will become directly applicable, others will be harmonised through national competent authorities. This concerns client funds protection (safeguarding), strong customer authentication (SCA), open APIs for TPPs and operational resilience. The PSR public offer becomes the visible bearer of these requirements, and regulators view it not as a formality but as a reflection of risk management.

The main differences between PSD3 and PSD2 regarding the public offer: increased transparency of fees and risks, greater attention to SLAs for payment execution and incidents, as well as clear provisions on the allocation of responsibility between the PSP, the merchant and the TPP. EBA recommendations on public offers and the role of national competent authorities strengthen control over disclosures, consent mechanisms and the procedure for notifying changes to offer terms. In practice this means that the «PSD3 payment provider offer» must be synchronized with SCA, KYC/AML policies and operational procedures, rather than exist separately.

Public offer for PSP, EMI, e-money

Illustration for the section «Public offer for PSP, EMI, e-money» in the article «Public offer of a payment system under PSD3 and PSR»
I start the project by mapping risks and business processes. The solution developed at COREDO links each product feature to specific sections of the contract and internal policies. For EMI and e-money the offer must explicitly describe the funds protection regime, wallet types, limits and withdrawal operations, and the “e-money public offer and PSD3” must align with safeguarding accounts and insurance coverage.

Key blocks of the offer:

  • user consent and acceptance mechanics (click-wrap, eIDAS electronic signature where high legal enforceability is needed);
  • tariff transparency and the fee pricing model, including transaction margin and surcharges for cross-border payments;
  • SLA metrics: authorization time, settlement time, service availability, incident priority;
  • provisions on refunds and chargebacks, allocation of responsibility between PSP and merchant;
  • public offer and protection of client funds: segregation, insurance, annual safeguarding audits;
  • public offer and KYC/AML requirements: client’s obligations to provide data, blocking triggers, RBA;
  • privacy: processing of personal data and GDPR, cross-border data transfers and localization requirements.

PSD3 Offer: PSR Requirements

Illustration for the section «PSD3 Offer: PSR Requirements» in the article «Public offer of the payment system under PSD3 and PSR»

COREDO practice confirms: the «mandatory provisions of the PSD3 offer» are read by the regulator as a maturity checklist. In the offer we set out:
  • user rights and user protection in the PSD3 offer: clear information on risks, fees, limits, reimbursement rights;
  • SCA and exemptions: biometrics, trusted beneficiaries, low-risk transactions;
  • operational resilience and incident reporting: timeframes for notifying customers and the regulator, communication channels;
  • third-party outsourcing: SLAs and supplier liability, right to audit, critical dependencies;
  • independent audits, reviews and internal control: frequency, scope, remediation;
  • capital requirements for PSPs and requirements for electronic money issuers (EMIs): methodology, stress tests, buffer maintenance.

PSR requirements also strengthen disclosures on payment routing, multilateral correspondent models and access-to-account obligations under open banking. This should be reflected formally and operationally.

PISP/AISP/marketplace/white-label PSP

Illustration for the section «PISP/AISP/marketplace/white-label PSP» in the article «Public offer of the payment system under PSD3 and PSR»
For PISP and AISP the “public offer for PISP and AISP” must disclose third-party API access (TPP), the procedure for delegated consent, as well as the public offer in open banking conditions – who, when and how stores tokens, event logs and how to ensure users’ consent during API delegation. Our experience at COREDO has shown that unnecessary ambiguity here leads to complaints and loss of passporting.

For a payments marketplace, it is important to choose a model: custodian vs escrow. The public offer for a payments marketplace should explain segregation of sub-merchants’ funds, the settlement schedule and the terms for termination of service/transition of clients without the risk of funds “getting stuck”. In a white-label PSP we record the allocation of responsibilities between the licensed back-end provider and the brand, including Due Diligence when partnering with a PSP and the right to modernize the API without degrading the SLA.

AML/KYC and the risk-based approach in the offer

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A public offer and AML/KYC/CDD are not about copy-pasting from the compliance policy, but about clear rules for the client.

I set out risk-based approach (RBA): risk segments, CDD levels, triggers for enhanced due diligence, sanctions control and screening technologies. For transaction monitoring and SAR reporting, the offer establishes the right to suspend an operation, request documents, notify the FIU and national regulators.

We dedicate a separate section to data: retention periods, access, cross-border data transfers (EEA and beyond), legal bases and localization where individual countries require it. It is important for the client to understand that compliance is part of the service, not a separate obstacle. Such transparency reduces the likelihood of disputes and improves onboarding quality.

Security and technical requirements for the text

Public offer and API security: mandatory section. I recommend formalizing requirements for OAuth2, JWT, key management and HSM, as well as the minimum compliance requirements in the public offer for PCI-DSS (network perimeter, PAN data encryption, card tokenization). At the protocol level it is worth mentioning the migration to ISO 20022 and its impact on consent schemes and the format of payment details.

Incidents should be described clearly: priorities, RTO/RPO, business continuity and disaster recovery in the offer, escalation procedures. For instant payments (TIPS, RTP, FastPay) we define specific SLAs and the risks of irrevocability, as well as mechanisms for post-authorization review and anti-fraud filters. The solution developed by COREDO combines these technical standards with legal obligations without conflicts.

User Consent and Notices

User consent: the foundation. In the offer I describe the mechanics of notification and obtaining users’ consent, including logs, IP addresses, timestamps, and, where necessary: eIDAS and electronic signatures in user agreements. For TPP processes I separately define how to secure users’ consent during API delegation, token validity periods and revocation.

A notice of changes to the offer terms must include the channels (e-mail, in-app), minimum timeframes, the client’s right to terminate the agreement without penalties before the changes take effect, and the rules for handling “silent consent” where permitted. Such a design prevents disputes and increases resilience to audits.

SLA and operational metrics in the offer

SLA is the language of trust for the merchant. We establish:

  • authorization and confirmation times, the share of operations requiring re-authentication;
  • settlement time (D+0/D+1), cut-off, deduplication;
  • service availability (for example, 99.9%), maintenance window and the order of function degradation;
  • dispute management and customer support in case of chargeback: TAT, channels, escalations.

For instant-pay services it is useful to include separate SLAs: the share of payments <10 seconds, average finalization time, and fallback routes in case individual schemes are unavailable. Agreements with merchants and settlement SLAs are reasonable to place in an appendix so that metrics can be updated promptly without changing the base text.

Safeguarding and capital in the offer

The public offer, safeguarding and segregation of client funds (safeguarding) are areas of close attention. Models for safeguarding: bank accounts vs insurance, their combinations and reconciliation timelines. I specify the frequency of reconciliation, the client’s right to information about custodial banks and independent auditor confirmations.

The section on PSP capital requirements explains the calculation method, recapitalization triggers and the procedure for notifying the regulator. For marketplaces I add how to organize safeguarding for a marketplace: separate accounts for sub-merchants, escrow for disputes, temporary reserves and automatic unfreeze conditions.

Cross-border operations, passporting, banks

Passporting and restrictions on cross-border operations are a frequent source of misunderstanding.

In the offer we specify the geography of services, service currencies, country restrictions and the use of partner PSPs. Integration with correspondent banks and fees must be transparent: where correspondent banking fees may arise and who covers them.

The public offer for cross-border payments should take tax aspects into account: the public offer and taxation of payment services – who withholds taxes, how fees are treated for B2B and B2C. When operating in the EU, it is beneficial to reflect passporting and conditions for servicing non-residents; in Asia, the linkage to licenses by MAS, HKMA or DIFC/FSRA.

Disputes, refunds and chargebacks

Refund procedures and chargeback mechanics – not just links to a card scheme. I break it down step by step: timelines, required evidence, merchant’s role, allocation of PSP responsibility for infrastructure and routing errors. For A2A payments we set out separate error-resolution mechanisms, refunds at the initiative of the PISP and intervention by the account-holding bank.

Dispute resolution and an arbitration clause help avoid jurisdictional traps. Legal stipulations: applicable law and jurisdiction are chosen taking into account the license and domicile of safeguarded accounts. In the offer it is advisable to describe liability limits and indemnities: reasonable caps, exclusions for gross negligence and intent, and disclaimer in the public offer to the extent permitted by law.

Securing control in outsourcing

The public offer and the terms of subcontracting/outsourcing must specify that critical functions are transferred only to approved providers, with audit rights and security requirements. We specify third-party outsourcing: SLAs and provider liability, business continuity plans, compatible RTO/RPO. Clients must know that outsourcing does not diminish their rights, and the provider retains control.

For white-label and agency schemes and partnership models, we describe the separation between the storefront and the licensed entity, brand/license disclosure, passporting and the right to migrate to the ‘base’ provider upon termination.

Risks, TCO/ROI and compliance under PSD3

TCO and ROI assessment when adapting the offer for PSD3 is a mandatory management task. We calculate CAPEX/OPEX for API updates, legal reviews, resilience tests and independent audits. Potential fines and regulatory risks are correlated with incident probabilities and the impact on GMV and transaction margin.

Which offer terms increase merchants’ trust? Transparent SLAs, a clear responsibility matrix, flexible payment routing and clear chargeback rules. Which metrics should be tracked after updating the offer? CAC, LTV, GMV, share of successful authorizations, settlement speed, incident rate, merchants’ NPS, size of reserves and refunds.

PSD3 Roadmap: stages and timelines

The COREDO team implemented a standard roadmap for PSD3 compliance:
  1. Gap analysis: differences from the current offer affecting PSR requirements, EBA recommendations.
  2. Structure redesign: PSP public offer template, linkage to SCA, AML/KYC, BCP/DR policies.
  3. Tech and risk review: API security, PCI-DSS, OAuth2/JWT/HSM, ISO 20022, instant payments.
  4. Legal components: applicable law, jurisdiction, limits and indemnities, outsourcing, safeguarding.
  5. Communication testing: consent mechanics, notice of changes to the offer terms, UX screenshots.
  6. Internal training: operational runbooks and KRIs, compliance project KPIs and execution control.
  7. Pilot and release: independent audits, establishing SLAs, metric monitoring, adjustments.

Timelines depend on scope, but on average we typically complete within 8–16 weeks if backend policies are ready and security is confirmed.

Implementation case studies in Europe and Asia

In the EU the COREDO team adapted the public offer for PSPs in Central Europe with the move to instant payments and the launch of marketplace scenarios. We defined an SLA for TIPS, set escrow reserves, and delineated responsibilities between the platform and sub-merchants. After the release, GMV grew due to the trust of large merchants, and the incident rate dropped by one third thanks to clear procedures.

In Singapore, the solution developed by COREDO helped align the public offer for the payment infrastructure with MAS requirements and eIDAS-equivalent electronic signature standards. We integrated sanctions screening for Asian corridors and provided for cross-border data transfer with local replicas. The regulator approved the cybersecurity outsourcing model while retaining control with the licensed entity.

Public Offer Template for PSP

Example of a public offer for PSP as a “skeleton” of sections:

  • Terms and roles: PSP, merchant, user, TPP, PISP/AISP, marketplace and sub-merchants.
  • Scope of services and geography: channel/schemes, instant payments, limited jurisdictions.
  • Fees and commission model: transparent consumer information and disclosure, taxes.
  • User consent and eIDAS: acceptance mechanism, delegation via API.
  • SCA and risk management (PSD3): factors, exceptions, anti-fraud, KRI.
  • Safeguarding: bank accounts vs insurance, reconciliation, audits.
  • SLA for payment execution and settlement: metrics, service windows, degradation.
  • Refunds and chargebacks: timelines, evidence, allocation of PSP liability.
  • AML/KYC/CDD and sanctions: RBA, SAR, interaction with FIU.
  • Privacy and GDPR: cross-border data transfer and localization requirements.
  • Outsourcing and subcontracting: right to audit, security, reserves.
  • Operational resilience: incident reporting, business continuity and disaster recovery.
  • Payment routing and correspondents: fees, fallback channels.
  • Restrictions and limits: transactions, currencies, merchant categories.
  • Liability limits and indemnities, disclaimers in the public offer (within the law).
  • Termination and transition: key termination and client transition points, data export.
  • Applicable law, jurisdiction, dispute resolution and arbitration clause.
  • Mechanism for notifying changes to the terms of the offer.
This template speeds up the preparation of a “public offer for PSPs in the EU” and meets the expectations of regulators and merchants.

PSD3 Offer Verification Checklist

Checklist for PSD3 offer compliance:

  • All roles, channels and schemes are specified, including PISP/AISP and open banking.
  • SCA and exemptions are aligned with policies and UX flows.
  • Safeguarding is transparent: banks/insurance, reconciliations, independent audits.
  • SLAs are defined, KPIs are measurable, incidents are described.
  • Refunds/chargebacks are detailed by scheme.
  • AML/KYC/CDD RBA is clearly articulated, SAR and sanctions controls are reflected.
  • GDPR and cross-border data transfers are validated by the DPO.
  • Outsourcing: right to audit, API security, PCI-DSS.
  • Legal provisions: limits, applicable law, spoliation-safe logging of consents.
  • Notification and consent mechanisms are tested and logged.
  • Integration of ISO 20022/instant-pay is reflected in terms and SLAs.
  • National NCA requirements are considered, passporting is correctly described.

Assess ROI and reduce sanctions risks

How to assess the ROI of changing the public offer? We compare improvements in authorization conversion, reductions in disputed transactions, savings on incidents and audits, increased merchant trust, and lower CAC.
How to minimize the risk of fines when implementing PSD3? Link each requirement to metrics and responsible departments, establish independent reviews, and maintain a log of risk decisions.
Managing compliance costs as the business grows requires prioritization: first safeguarding and SCA, then SLAs and outsourcing, and only afterward rare jurisdictional nuances. This approach supports scaling a multi-currency infrastructure without straining the budget.

Impact of PSD3: tokenization of crypto services

The impact of PSD3 on crypto services and tokenization is reflected in requirements for KYC/AML, SCA, storage and transfer of value through the payment infrastructure. A public offer and PCI-DSS requirements are important for card tokenization and on/off-ramp scenarios. For card tokenization and payment data security, we establish the merchant’s PCI obligations and the role of the tokenization provider, as well as cybersecurity obligations for APIs, OAuth2, JWT, and HSM.

API access for third parties and the terms of the offer must eliminate ambiguities regarding data rights and revocation of access. Open banking affects contractual relationships, and the offer must be aligned with the agreement with merchants and the SLA for settlements.

Regulatory practice and sandboxes

Licensing payment providers in the EU and Asia remains different, but the ideology is the same: demonstrate risk control through contracts and procedures.

A regulatory sandbox for payment services in individual countries helps test a public offer for payment infrastructure with a limited set of customers. In our projects we often pilot the dispute resolution process, SLAs and safeguarding specifically in the sandbox to speed up subsequent certification.

The role of national competent authorities in supervising PSPs is strengthening, and the PSR public offer is the first point of contact for supervision with your «tone of compliance». The more precise the document, the easier it is to pass off-site and on-site inspections.

Practical wording: what merchants value

Which offer terms increase merchants’ trust? I clearly define responsibility for delays in settlements, a transparent discount matrix as turnover grows, and describe fallback routing of payments. Agreements with merchants often include KPIs for authorization, refund timeframes and support quality, as well as the right to early exit in case of SLA degradation. Such a balance of interests stabilizes GMV and reduces churn.

For a white-label PSP it’s appropriate to disclose “who is actually licensed” and where the client will be able to continue service if the white-label agreement is terminated. Key termination and client-transition points describe data export, token unpacking, and the timelines for fund migration.

Work on COREDO projects

Our experience at COREDO has shown: the perfect offer is impossible without synchronizing the legal text, technological standards and operational runbooks. The COREDO team implemented an interactive matrix where each item of the offer is mapped to ISO 27001/PCI-DSS controls, an antifraud procedure, KPIs in the SLA and the BCP regulation. This creates seamless control and facilitates independent audits.

When a client prepares «public offer for a white-label PSP», we check the partner’s due diligence, its backup capacity, routing, as well as subcontracting terms. As a result the offer reflects the real risk landscape and withstands reviews by both EBA-guidelines and local NCAs.

The offer as a strategic asset

A public offer for a payment service under PSD3 and PSR is not a legal formality. It is a strategic asset that protects users, reduces risks, and increases revenue through merchants’ trust and operational efficiency. When the document ties SCA, safeguarding, AML/KYC, SLA and API security to real processes, the business confidently scales across the EU, Asia and the CIS.

COREDO prepares «PSD3 payment provider offer» quickly and consistently, relying on audit practices and case studies across different jurisdictions. If your product needs «public offer for a PSP in the EU», «public offer when implementing instant payments» or «public offer template for PSP» for white-label and marketplace, the COREDO team will align the document with EBA requirements, the EU PSD3/PSR regulation draft and merchants’ expectations. I believe in a simple formula: a strong offer – fewer incidents, higher conversion, more sustainable growth.

Since 2016 I have been leading COREDO through dozens of projects to register fund structures in the EU, Asia and the CIS, and during this time Ireland has consistently remained at the top for the combination of regulatory predictability, tax benefits for funds and high-quality provider infrastructure. When I receive a request for an international fund registration with subsequent licensing and comprehensive AML support, I first assess the applicability of the ICAV (Irish Collective Asset-management Vehicle) regime. This form was created specifically for investment funds and hedge funds and provides precise answers to founders’ pain points: speed of launch, the tax neutrality of ICAV for investment funds, flexibility of structuring and effective cross-border distribution.

COREDO’s practice confirms: ICAV is a tool for those who want controlled EU passporting under AIFMD or UCITS, a wide funnel of institutional investors and compliance that withstands Due Diligence by any global LP. In this article I have gathered strategic and practical aspects: differences between ICAV and Ltd and PLC, tax regimes and incentives, requirements of the central regulator, KYC/AML procedures, substance, as well as a step-by-step guide to registering an ICAV in Ireland and subsequent supervision by the Central Bank of Ireland.

How an ICAV differs from a Ltd company and a PLC

Illustration for the section «How ICAV differs from Ltd and PLC» in the article «Tax incentives for funds in Ireland – ICAV regime»
ICAV: it is a separate legal regime for collective asset management in Ireland, designed for investment purposes and compliant with AIFMD and UCITS. Unlike Ltd and PLC, it is not a corporate “universal” form, but a specialised fund vehicle operating as an investment undertaking with specific tax consequences and reporting. This positioning allows ICAV to obtain exemption from corporate tax at the fund level provided the legal requirements are met.

The key difference from Ltd and PLC is tax opacity in Ireland combined with “tax transparency” at the investor level in their home jurisdiction, if local law so requires. In other words, ICAV taxation is structured as a neutral link between the assets and the unit-holders, where the tax base is formed at the investor level rather than at the fund, and withholding taxes and the ICAV are examined through the prism of DTTs and domestic rules. Such a structure is critical for private equity, credit strategies, hedge structures and multi-asset solutions where investors are geographically diverse.
Umbrella ICAVs and sub-funds: another practical plus. A single “umbrella” platform allows an unlimited number of segregated sub-funds with separate share classes, risk isolation and different investment mandates. The COREDO team has implemented such umbrellas for clients ranging from Singapore to Dubai, using a single ManCo and a unified infrastructure of the depositary, administrator and custodian while maintaining separate reporting for sub-funds.

ICAV tax architecture

Illustration for the section «ICAV tax architecture» in the article «Tax incentives for funds in Ireland – ICAV regime»
My main guideline is to minimize the fund’s tax burden through an ICAV without resorting to aggressive structures. Ireland allows a fund to be exempt from corporate tax when it has investment undertaking status and is correctly registered, and it also provides mechanisms for exemption from Irish withholding tax on payments to non‑residents from the “white list” of jurisdictions when supporting documentation is available. Taxation of gains from the sale of assets in an ICAV generally does not arise at the fund level; capitalization of gains is passed through to the investor taking into account their domestic tax regime and DTT.

Withholding and exemptions from taxes on interest and dividends themselves depend on the source of income and the location of the assets. In real projects we developed documentary withholding tax relief procedures, including investor self‑certification forms, confirmations of tax residency, analysis of treaty‑shopping risks and the application of the Multilateral Instrument (MLI), which modifies specific provisions of double taxation agreements. Our experience at COREDO has shown: a properly constructed matrix of DTTs and local exceptions on withholding tax on interest/dividends significantly increases net returns.

An ICAV should take into account the impact of BEPS and ATAD: interest limitation rules, CFC rules at the investor level, anti‑hybrid rules and substance over form — this is the baseline. Anti‑hybrid rules are important for debt strategies and structures with SPVs across multiple countries: mismatches in the tax characterization of instruments in different jurisdictions can lead to denial of deductions or double inclusion of income. We apply transfer pricing for groups of fund‑servicing entities and prepare transfer pricing documentation requirements for fund groups to demonstrate the arm’s‑length nature of fees charged by the ManCo, the administrator and advisors.

The introduced Pillar Two (global minimum tax) is formally aimed at large groups. Nevertheless, funds with controlled holdings and service hubs must check the per‑jurisdiction effective tax rate and exemptions. The solution developed at COREDO models ETR by jurisdiction and carve‑out scenarios; this is especially relevant when using portfolio SPVs for transactions in Europe, Asia and Africa. Additionally, we assess GAAR, general anti‑avoidance rules — in Ireland and in investors’ countries — to confirm business purpose and real economic substance.

VAT treatment of fund management services in Ireland provides for VAT exemption for fund management services, but where services are mixed in nature (for example, IT outsourcing or analytics) some components may be taxable. We pre‑classify contracts and determine VAT on management services: when VAT applies and how to correctly document administration fees — tax recognition and deductions for providers. Such analysis reduces the risk of margin shifting at the operational level.

What Revenue and the regulator see

Illustration for the section “What Revenue and the regulator see” in the article “Tax benefits for funds in Ireland – ICAV regime”
The tax residency test for a fund in Ireland is built around the place of effective management and management and control (management and control). Economic substance for an ICAV: it’s not just an office and a nameplate on the door, but a set of corporate governance practices: directors’ meetings in Ireland, independent non‑executive directors with relevant expertise, a local secretary, a record of resolutions, contracts with Irish counterparties and risk controls at the depositary and ManCo level. I always emphasize: it is demonstrable management and control at the ICAV that addresses CFC issues and confirms tax neutrality.

  • A calendar of board meetings held with an Irish quorum and minutes.
  • Real‑time access for directors to portfolio information and risk reports.
  • Local agreements with the ManCo, the administrator, the depositary, and auditors.
  • Policies and procedures: asset valuation, conflicts of interest, valuation challenge.
  • A dossier on the place of effective management: business trips, minutes, working correspondence.

The role of the manager (ManCo) and tax obligations is a separate topic. Licensing and registration of a ManCo for an ICAV is carried out at the Central Bank of Ireland, and the quality of the ManCo affects not only AIFMD/UCITS supervision but also the perception of substance by regulators. In several projects the COREDO team conducted ManCo vendor selection and built an advance pricing agreement (APA) as a tool for legal certainty on intra-group pricing for the service companies supporting the fund.

Requirements for directors and independent board members of an ICAV include a balance of competencies: investments, risk, compliance, audit. Functions and fiduciary duties and director liabilities in tax disputes are not theoretical: we have supported cases when correct escalation to the depositary and the recording of a director’s dissenting opinion helped a fund pass an inspection without sanctions. Corporate governance practices for an ICAV are your insurance when dealing with questions from the Irish Revenue Commissioners and external auditors.

Registration of CRO, Central Bank, Revenue

Illustration for the section «Registration CRO, Central Bank, Revenue» in the article «Tax incentives for funds in Ireland – ICAV regime»
A step-by-step guide to opening an ICAV for non-residents includes three tracks: legal (Companies Registration Office, CRO), regulatory (Central Bank of Ireland) and tax (Revenue).

  • CRO: preparation of the ICAV constitution, information on directors, the company secretary and the RBO. The Companies Registration Office (CRO) registration procedure for an ICAV usually takes 5–10 business days with a complete submission.
  • Central Bank of Ireland: submission of documents for ICAV approval and, where necessary, a UCITS prospectus or AIF rules. Timelines depend on the fund category: there are fast routes for QIAIF; for UCITS, 6–8 weeks with quality preparation.
  • Irish Revenue Commissioners: registration of the tax status as an investment undertaking and obtaining an Irish tax clearance certificate for certain operations (for example, on distributions).
How long does ICAV registration in Ireland take? On average “turnkey”, from 8 to 12 weeks, if the ManCo and key providers are selected in advance and there are no amendments to the strategy’s risk profile. The registration and launch timeline is a checklist that the COREDO team tailors to each strategy, including concentration rule compliance tests for UCITS compatibility and structural liquidity requirements.

Choosing a depositary, administrator and custodian: the foundation. The depositary controls ownership of assets and compliance with investment restrictions, and depositary liability: practical cases and risk management show that proper allocation of functions between the depositary and the administrator reduces operational risks. When structuring SPVs and ICAVs for private credit and securitisation SPVs we take into account asset segregation and tax asset protection mechanisms so that cash flows and payment priorities are resilient to stress scenarios.

Passporting AIFMD: opportunities and limitations for ICAV, and UCITS compatibility — this is about distribution strategy. UCITS provides the widest possible access to retail investors in the EU, AIFMD: to professional investors in Europe. The impact of Brexit on choosing Ireland as a fund jurisdiction is clear: Dublin has become the “gateway” for EU-passported products while retaining an English-language legal environment and depth of the service provider market.

Compliance and reporting: AML, DAC6, AEOI

Illustration for the section «Compliance and reporting: AML, DAC6, AEOI» in the article «Tax incentives for funds in Ireland – the ICAV regime»
Anti-corruption KYC/AML for funds in Ireland is a set of policies, procedures and technologies. We build KYC/AML procedures when onboarding institutional investors, including sanctions screening and counterparty checks, identification of PEPs, adverse media and transaction monitoring. When suspicious transactions are detected there is an obligation to file SARs and reporting requirements for suspicious activity in accordance with Irish AML legislation.

CRS and FATCA for ICAV are standard. FATCA registration is required to obtain a GIIN, AEOI setup involves the technical steps for information exchange and annual filing through Irish ROS. Investor tax reporting requirements and forms depend on investor jurisdictions, but basic self-certification (W‑8BEN‑E/others) and periodic updates are mandatory. The Beneficial Ownership Register (RBO) and disclosures of the fund’s and ManCo’s ultimate beneficiaries must be accurate and timely.
DAC6 and reporting for ICAV funds is a sensitive area for cross-border transactions. We assess indicators of “arrangements” and prepare the reporting position to avoid late filing and penalties. The regulatory package (regulatory filings: the annual document package for an ICAV) includes filings to the Central Bank of Ireland, audit of financial statements, updating KIID/KID, as well as the tax reporting calendar: the main deadlines for funds taking into account the specifics of UCITS/AIF.

Choosing an auditor and audit requirements is not a formality. The auditor must understand valuation of Level 3 assets, NAV error escalation rules and the specifics of side pockets, otherwise the audit will be prolonged. The solution developed at COREDO provides an RfP process and a scorecard for auditors, administrators and depositaries taking into account the fund’s strategy, asset geography and investor requirements.

Redomiciliation of a fund to Ireland

Transferring a fund to Ireland: tax and operational steps begin with tax due diligence when entering an ICAV structure, analysis of BEPS issues during the reorganisation of international funds and review of CFC rules in investor jurisdictions. For assets we model transfer of assets in kind: tax consequences, possible stamp duties and capital gains recognition. Restructuring costs: how to account for expenses during a reorganisation – we record them in the fund’s accounting policy and with providers to avoid disputes over deductions.

ROI when moving the structure to ICAV mode is calculated through a set of KPIs: net return after withholding optimisations, savings on VAT and administration fees, speed of capital raising through passporting, reduction in compliance costs compared with offshore schemes. Key KPIs for managers when assessing ROI from redomiciliation include time-to-first-close, delta TER, % of investors from the EU, and the “cost of risk” from regulator audits. In practice, relocating to Ireland increases trust from LPs in Europe and Asia and simplifies cross-border distribution: tax barriers and solutions here are standardised.

Transition to ICAV: we mitigate compliance and tax audit risks through preliminary consultations with the Irish Revenue Commissioners, obtaining a tax clearance certificate where necessary, and via an APA for intra-group services. Risk mitigation strategies during tax audits and reviews include documenting the commercial purpose, comparability of ManCo fees and director independence. Practical steps to demonstrate substance to Revenue and the supporting evidence are documented in a ‘substance dossier’ with a calendar of meetings, minutes and correspondence.

Private strategies: PE/VC, hedge funds

ICAV for investment funds and hedge funds allows fine‑tuning of subscription/exit rules, hedge structures vs fund solutions and tax differences when using derivatives. For private equity we have embedded waterfall and carried interest within PE/VC fund structuring under ICAV: best practices suggest using separate sub‑funds for individual vintages and geographies to segregate risks and reporting. Tax aspects of private equity and ICAV often come down to managing capital gains treatment for non‑residents and investor‑level exemptions.

For credit strategies and securitisation SPV(s) we build a two‑tier architecture: an ICAV as the fund and an Irish or other EU SPV as the asset holder with its own “thin capitalization” and documented market rates. Such a setup supports asset protection through the ICAV and tax considerations, while preserving substance and the manageability of withholding. The COREDO team implemented credit umbrellas with sub‑funds for senior and mezzanine, as well as SPVs for synthetic securitisations, where anti‑hybrid rules were a critical part of the structuring.
We regularly compare the tax efficiency of the ICAV and Luxembourg fund schemes. In some cases Luxembourg wins for specific debt instruments and provider availability; nevertheless Ireland often offers a more direct tax neutrality, a simple operating model and a strong UCITS track record. choice of jurisdiction for the fund: Ireland vs offshore, for institutional LPs it is a question of trust and regulatory perimeter; Ireland with AIFMD/UCITS and supervision by the Central Bank of Ireland increases the quality of inbound due diligence by large investors.

Investor lifecycle: onboarding/holding/exit

At investor onboarding we set up KYC, the collection of self‑certifications for FATCA/CRS, tax residency checks and determine the applicability of withholding tax relief procedures and documentation. For US investors in an ICAV timely FATCA registration and the correct fund status for PFIC purposes at the investor level are critical; our experience at COREDO has shown that early engagement with their tax advisers reduces the risk of reporting surprises.

When making distributions it is important to consider withholding and exemptions on interest and dividends, apply DTTs and the relevant practical exceptions. Exit tax: modeling tax consequences on exit: a mandatory step at the subscription stage, especially for PE sub‑funds with a long horizon; investors should be able to see in advance scenarios for capital gains and possible exemptions, as well as investor tax reporting requirements and forms in their jurisdictions. We prepare clear memos on the tax treatment of distributions so the fund’s IR team can communicate transparently with LPs.
We discuss nominee arrangements and the related disclosure risks openly: in some jurisdictions nominee holders can complicate the application of DTTs and increase scrutiny from banks and depositaries. COREDO’s practice confirms: transparency of ownership structures and timely submission of data to the RBO reduce queries from administrators and auditors, thereby saving time and money.

Scalability, expenses and providers

Operating expenses of establishing an ICAV: forecasts and cost items include ManCo services, the administrator, depositary/custodian, auditor, legal support, listing (if required), directors’ insurance (D&O), IT infrastructure and KYC platforms. The cost of establishing and maintaining an ICAV depends on the strategy, liquidity and number of sub-funds; for an umbrella with two sub-funds and a professional ManCo we target a reasonable mid-market budget, which is detailed at the RfP stage.

Scalability: how the ICAV structure supports growth and capital raising – through an umbrella ICAV and sub-funds, passporting, unified policies, and a “live” ecosystem of Dublin providers. Tax incentives and opportunities for fund service providers in Dublin create competition and keep prices down, while service standards remain high. The COREDO team conducts KPI monitoring of administrators’ and depositaries’ SLAs, which directly affects NAV timing and the quality of investor reporting.

COREDO cases: EU, redomiciliation and taxes

Recently the COREDO team completed international fund redomiciliation cases to Ireland from offshore jurisdictions while retaining the investor base. We rolled out an umbrella ICAV with three sub-funds (public equities, private credit, Africa infrastructure), secured AIFMD passporting into key EU countries and coordinated cross-border distribution together with local counsel in Asia and Africa. Practical steps to demonstrate substance to Revenue and supporting evidence were incorporated into the corporate governance policy, and the Central Bank of Ireland approved the structure on schedule.

In another project our client was transferring a hedge strategy from a non-EU jurisdiction. After tax due diligence and analysis of BEPS issues we prepared an APA for the group’s service centre to close the transfer pricing risk. We also implemented sanctions screening and counterparty checks at the administrator level, and for DAC6 we developed an internal test preventing late reporting. Result – a fast first close and growth of the LP base from Europe and the Middle East.

Audit risks and their mitigation

Substance over form: the practice of tax audits in Ireland and the EU shows that formal indicia without real management in the country of residence no longer work. We help set meeting agendas, directors’ roles and ManCo control mechanisms to demonstrate the place of effective management. GAAR and anti‑hybrid rules are checked first; therefore profit allocation scenarios, SPV debt load and payment chains are documented in a memorandum before launch.

We discuss the impact of CFC rules on international investment structures with investors in advance, especially in Asia, where local CFC tests can bring the fund’s income into the tax base of the controlling persons. For such LPs we prepare individual certificates on the fund’s tax neutrality and the applicability of DTT, and also coordinate withholding tax relief procedures with their tax advisers. Regarding the Multilateral Instrument (MLI), we monitor updates to DTTs and promptly update self‑certification forms.

Why Ireland and ICAV now?

Choosing Ireland is a bet on the predictable supervision of the Central Bank of Ireland, the UCITS and AIFMD regimes recognized worldwide, and the infrastructure of world‑class service providers. Compared with offshore jurisdictions, investment status in the EU simplifies capital raising and reduces the compliance premium that investors often build into specific jurisdictions. For teams from Europe, Asia and the CIS this means process transparency, time savings and professional support at every stage — something COREDO handles daily.
The application of the ICAV regime in Europe, Asia and Africa in practice looks like a single platform with local SPVs to hold assets and a well‑designed DTT matrix. Our experience at COREDO has shown that with correct setup of substance and governance, ICAV withstands scrutiny by any institutional investor and auditor, and the ROI from redomiciliation is measured both by increased net returns and by the speed of fund closings.

Conclusions

ICAV is not just an “Irish form”, but a full-fledged operating platform: tax neutrality, the flexibility of umbrellas and sub-funds, oversight by the Central Bank of Ireland, passporting under AIFMD/UCITS, and predictable rules from the Irish Revenue Commissioners.

To obtain the full range of benefits — from exempting an ICAV from corporation tax to reducing withholdings and ensuring transparent AEOI reporting — it is important to link the legal, tax and operational axes into a single model of substance, governance and compliance.

The COREDO team has gone through this process with clients from the EU, Singapore, the UK, Cyprus, Estonia, the Czech Republic, Slovakia and Dubai and has built an approach that saves time and reduces risks. If you are considering registering an ICAV in Ireland, relocating a fund or optimizing an existing structure, I recommend starting with a roadmap: objectives, distribution strategy, tax model, providers, timeline, KPI.

The solution developed at COREDO makes it possible to combine strategic ambitions with operational delivery: from concept to first closings, without compromising on the quality of governance and investor trust.

I have been leading COREDO since 2016 and every year I see how technological progress changes legal and financial constructs faster than regulators’ manuals can be updated. Tokenized funds are not hype but a practical tool if you approach design as an engineering task: from choosing the legal wrapper and license to smart contracts, custody schemes and marketing restrictions. The COREDO team has implemented a number of projects in the EU, Asia and the CIS, and in this article I have gathered the practical experience that will save you months of searching and hundreds of hours coordinating with providers.

I write simply about complex matters, but I do not downplay the risks. Tokenization of fund units and the issuance of a security token fund provide liquidity, fractionalization of assets through tokens and on‑chain transparency, but require discipline: compliance by design, a correct tokenized fund structure, smart contract audits and a contractual framework with clear transfer restrictions. The solution developed by COREDO for such projects is built on the combination of law, technology and operational management — without one of these links the structure won’t fly.

Tokenized funds: why businesses need them

Illustration for the section «Tokenized funds: why businesses need them» in the article «Tokenized Funds – funds with tokens instead of shares»
A tokenized fund is a fund on the blockchain where shares/units are represented as security tokens according to the regulator’s classification of the token as a security. This model provides a flexible subscription, redemption and secondary market mechanics for the fund’s tokens, the possibility of trading security tokens on regulated exchanges or OTC alternatives, and also simplifies cross‑border distribution with correct fund passporting.

Our experience at COREDO has shown that tokenized funds increase ROI through fund tokenization due to four factors: reduction of transactional costs, acceleration of investor subscription, expansion of distribution geography and liquidity, and fractionalization of even ‘illiquid’ assets. Benchmarking the ROI of tokenization against traditional funds varies by strategy, but with fair token economics of the fund and competent market making, efficiency gains become measurable.

COREDO’s practice confirms: tokenized funds work not only for crypto strategies. We see cases of real assets, credit strategies, venture portfolios and even ESG tokenization for impact investing via tokens. The key criterion is a proper corporate wrapper and compliance with marketing restrictions and rules for advertising investment products in target jurisdictions.

Legal qualification: EU, Asia, CIS

Illustration for the section «Legal qualification: EU, Asia, CIS» in the article «Tokenized Funds – funds with tokens instead of units»
My approach begins with a map of regulatory regimes. In the EU the basic framework is set by AIFMD and MiFID II, as well as the regulatory requirements of MiCA and tokenized funds for crypto infrastructure. AIFMD and fund tokenization are compatible: the interest is issued as a token while retaining AIF status; for retail offerings it is possible to combine UCITS/AIF and tokenization via an intermediary “wrapper”. MiFID II’s consequences for the sale of fund tokens concern client categorization, suitability/appropriateness and distribution rules through investment firms.

In Asia I more often rely on Singapore and Dubai. Registering a tokenized fund in Asia via a Singapore VCC with an ITO/STO under MAS supervision, provided the manager is licensed, gives a clear roadmap. In the UAE DFSA and VARA offer regulatory sandboxes for tokenized funds and clear guides on security token offering for a fund, including transfer restrictions on security tokens and access to licensed exchanges.

In the CIS clients often choose the AIFC in Kazakhstan. The AIFC Courts and AFSA provide the predictability of Anglo‑Saxon law, and registering a fund in the jurisdictions of the EU, Asia and the CIS and the subsequent STO for the fund are structured into a single cross‑border arrangement. The legal choice of jurisdiction when launching a fund‑token we make based on the investor mix, requirements for the depositary and transfer agent, taxation and listing objectives.

Structure of a tokenized fund

Illustration for the section «Structure of a tokenized fund» in the article «Tokenized Funds – funds with tokens instead of units»

  • Structuring a fund as an SPV with tokens is suitable for niche strategies and club deals. The SPV issues tokens instead of units, and the management company enters into an investment management agreement, setting out fees and carry.
  • Using a corporate «wrapper» in the EU: commonly applicable fund forms in Cyprus, Estonia or Slovakia; for institutional investors — Luxembourg/Ireland via an AIF, and tokenization occurs at the level of the register of units.
  • The combination of UCITS/AIF and tokenization is possible with strict marketing limits. The COREDO team implemented such a hybrid in Cyprus with a white‑label platform for fund tokenization and a partnership with a licensed depositary.
The tokenized fund structure establishes: investors’ rights in the tokenized fund (voting, redemption, dividends), veto restrictions and the fund’s governance tokens, issuance of tokens with vesting and cliff mechanics, locking periods and exit restrictions for investors. The solution developed by COREDO contains a checklist of corporate and contractual provisions, including the subscription agreement, transfer restrictions, and, if necessary, a SAFT for pre‑round subscription within a closed perimeter.

Licenses and offering documents

Illustration for the section «Licenses and offering documents» in the article «Tokenized Funds – funds with tokens instead of units»
For the EU we prepare the prospectus filing and the KIID for the tokenized fund, the prospectus approval with the regulator, the white paper and the offering memorandum for the fund. Regulatory qualification determines whether the fund’s initial token issuance (ITO/STO) falls under the prospectus regime, national exemptions, or within an AIF via private placement.

In Asia the document set is similar, but the emphasis is on the offering memorandum and risk disclosures, including law enforcement and the enforceability of smart contracts. Legal support for tokenized funds at COREDO includes regulatory advice and obtaining licenses for investment companies, approval of marketing materials and recording restrictions on the sale of tokens to residents of certain countries.

Important organizations and standards: FATF, ESMA, IOSCO – define the language of compliance and AML/KYC standards for tokenized funds. We incorporate these principles into documentation and operating procedures from day one.

AML/KYC Compliance and Data Protection

Illustration for the section 'AML/KYC Compliance and Data Protection' in the article 'Tokenized Funds – funds with tokens instead of shares'
Compliance by design for tokenized funds is not a slogan, but an architecture of processes. Мы строим AML политику и screening санкций для инвесторов, интеграцию KYC провайдеров и санкционных списков, EDD (enhanced Due Diligence) для институциональных инвесторов, а также beneficial owner disclosure для токенизированных фондов. Процессы KYC/AML автоматизации с использованием API сокращают тайм‑ту‑сабскрайб и снижают операционный риск.

The register of token holders and KYC must be linked: on‑chain accounting of shares and profit distribution are validated by off‑chain identity data and investor permissions. For EU clients we take into account data storage requirements and GDPR for EU investors and define a retention policy.

Наш опыт в COREDO показал, что the implementation of AML автоматизации в подписи транзакций через политики смарт‑контрактов и адресные списки снижает нарушения трансферных ограничений. Мы также настраиваем AML/KYT‑мониторинг адресов, чтобы оперативно реагировать на риск‑сигналы.

Standards, custody, and stack security

Choosing a token standard determines future compatibility. For utility‑subscription logic ERC‑20 is used, for paper rights: token standards ERC‑1400 and ERC‑3643, which implement transfer restrictions, whitelists and compliance checks. A smart contract for investor subscriptions automates issuance, distribution and the payment of dividends via smart contracts on a schedule or upon occurrence of events.

Custodial solutions for fund tokens require discipline. For custody of private keys for funds we rely on storing private keys in hardware modules (HSM), multisignature (multi‑sig) custodial schemes, segregation of operator rights and an emergency recovery procedure. In some projects clients choose custodian vs qualified custodian for fund tokens, and I help make a balanced decision together with the partner depository.

Operational security matters no less than legal considerations. We assess tokenization technology providers (tokenization platforms) by ISO27001 and SOC 2 criteria, smart contract audits and formal verification are mandatory before ITO/STO. Oracle solutions for external NAV data and asset prices link off‑chain settlement and reconciliation with on‑chain logic, ensuring correct on‑chain NAV calculation for the fund.

Liquidity: from issuance to turnover

Primary issuance of fund tokens (ITO/STO) sets the starting liquidity, but I always design the secondary market in advance. Trading of fund‑tokens on exchanges is possible through regulated security token platforms and OTC alternatives for qualified investors. Market making and liquidity provisioning for fund tokens are arranged contractually, and buyback and burning mechanisms for fund tokens create a “soft” price corridor.

Integration with DeFi for fund liquidity opens liquid pools and AMMs for fund tokens while complying with jurisdictional and investor category restrictions. DeFi lending against fund tokens and the issuance of synthetic assets and derivatives on fund tokens are possible only after legal review and the configuration of transfer restrictions for the security token in smart‑contracts.

For subscription and redemption settlements I increasingly provision a stablecoin as the fund’s settlement instrument, but I also connect commercial banks and fiat‑on/off ramps for funds, including correspondent bank and fiat payments for subscription and redemption. This duplex reduces dependence on volatility and speeds up clearing.

Taxes for cross-border distribution

Taxation of tokenized funds in the EU and Asia requires early modeling. We calculate tax planning for non‑resident investors, tax withholding (withholding) on payments to investors and the applicability of double taxation treaties. For some clients I recommend corporate structures with ‘pass‑through’ taxation or umbrella funds with subfunds.

Fund passporting for cross‑border distribution and marketing restrictions, areas where it’s easy to make mistakes. The COREDO team prepares a map of available channels under MiFID II and local private placement regimes, including restrictions on selling tokens to residents of certain countries. This reduces regulatory risk and speeds up scaling.

ESG‑orientation is growing, and blockchain-based funds demonstrate advantages in the transparency of metrics. Paradoxes of transparency: competitive risks of portfolio disclosure are addressed through reporting to regulators and investors in aggregated form and by using zero‑knowledge proofs for private investments at the level of attesting facts without revealing details.

Insurance and Risk Management

A comprehensive assessment of operational risks of a tokenized fund is included in the initial sprint. I analyze legal disputes and precedents related to security tokens in target jurisdictions, conduct technical due diligence of infrastructure providers, and arrange cyber risk insurance and issuer liability. Loss recovery and insurance for tokenized funds cover key scenarios, from key compromise to operational errors.

The factor of speed and gas cost on Ethereum networks for fund operations has a direct impact on investor UX. To reduce costs we use layer‑2 solutions and sidechains to scale operations while maintaining security and compatibility, and mechanisms to control token price manipulation are embedded in market-making agreements and trade monitoring.

Formal guarantees of smart contract execution and the enforcement and enforceability of smart contracts are addressed by a dual layer: legal obligations in the documentation and code audits with formal invariant checks. On critical paths I always include emergency pause functions and manual settlement procedures.

NAV: operations and infrastructure

On‑chain NAV valuation for the fund increases transparency, but it cannot be separated from accounting. We set up off‑chain settlement and reconciliation, and the oracle provides verification of prices and corporate actions. Requirements for the depositary and transfer agent are specified in agreements, including registry reconciliation processes and SLAs.

Balanced through data architecture and access rights. We use allowlists, ZK‑proofs and data segmentation to comply with GDPR and protect the fund’s strategy.

The register and registrar of the fund’s holdings can be either internal or external. Partnership with a licensed depositary adds a supervisory layer, and the custodian vs qualified custodian for the fund’s tokens is chosen based on the makeup of investors and listing plans. COREDO’s solution for on‑chain accounting of shares and profit distribution reduces human error and speeds up reporting.

COREDO Case studies: EU, Asia, CIS

В ЕС команда COREDO реализовала AIF на Кипре с токенизацией долей по стандарту ERC‑1400, STO под режим частного размещения и листинг на регулируемой площадке security tokens. Кастодиальные ключи хранились в HSM с multi‑sig, а NAV рассчитывался on‑chain с верификацией через oracle и сверкой у администратора фонда.

In Singapore we structured a VCC‑fund with tokens instead of units for a credit strategy in Asia. The regulator approved the offering memorandum, we implemented EDD processes for institutional subscribers and transfer restrictions for certain countries. For liquidity we set up an OTC channel and a restricted‑access AMM‑pool, and dividend payments through smart contracts were executed in a stablecoin.

В СНГ запустили фонд через AIFC с корпоративной оберткой‑SPV для инвестиций в частные debt instruments. Регистрация tokenized fund в ЕС для кросс‑продаж прошла через партнерский управляющий AIFM, а пасспортирование ограничили несколькими странами. Этот гибрид показал, как legal‑мосты и технологические белые ярлыки (white‑label платформы) ускоряют выход.

Roadmap for a tokenized fund

  1. Diagnostics and design: legal choice of jurisdiction, the fund’s token economics, target audience assessment, marketing restrictions.
  2. Law and licenses: registration of a tokenized fund in the EU and/or registration of a fund with tokens in Asia, regulatory consultations, obtaining licenses, approval of prospectus, KIID, offering memorandum.
  3. Technology: choice of token standard (ERC‑20/1400/3643), smart contracts for distributing the fund’s income, audit and formal verification, oracle, custody with HSM and multi‑sig, ISO27001/SOC 2 compliance of platforms.
  4. Operations: depositary and transfer agent, token holder registry and KYC, off‑chain settlement and reconciliation, reporting to regulators and investors.
  5. Market and liquidity: ITO/STO, listing of security tokens on regulated exchanges, market making, OTC, DeFi integration and liquidity pools, buyback/burning mechanics.
  6. Taxes and risk: tax planning, withholding, cyber risk insurance and issuer liability, incident response procedures and manipulation controls.

COREDO handles coordination of providers, compliance setup and building the “operational rails”. I personally oversee the architecture and key agreements with regulators and banks so that you get predictable timelines and a transparent budget.

Frequently asked client questions and practical answers

Investors will ask about rights in the tokenized fund – we enshrine them in the charter and smart contracts: voting, dividends, priority order for redemption. Clients ask where to store assets, a partnership with a licensed depositary covers this area and supports audit.

The technical part raises concerns because of gas and scaling. I design layer-2 solutions and sidechains where justified by the business, and for subscriptions and redemptions I build in stablecoins and fiat channels. The question of enforceability of smart contracts is resolved by duplicating obligations in contracts and implementing formal guarantees of smart contract execution at the code and procedural levels.

Marketing: another critical area. We set up traffic filtering, geo-restrictions, investor verification and compliance with advertising rules so as not to launch prematurely. Veto limits and the fund’s governance tokens are clearly defined before launch to avoid conflicts of interest.

Tokenization: what it delivers in practice

Tokenization of fund shares reduces barriers to entry and adds flexibility to distribution. Integration with DeFi opens additional liquidity channels, and on‑chain accounting of shares and profit distribution simplifies auditing. When I see a project with a well-founded tokenized fund structure, correct documentation and reliable infrastructure, the result is accelerated AUM growth and reduced operating costs.

The COREDO team takes into account the paradoxes of transparency, the conflict between privacy and regulatory requirements, and builds a balanced system. We also proactively plan legal dispute scenarios and precedents on security tokens so that the fund has a resilient position and a predictable response to force majeure.

Final touch: banking relationships. Commercial banks and fiat on/off ramps for funds remain the industry’s linchpin, and I always build reserve channels and a correspondent banking network to handle peak loads. This approach allows the fund to meet its commitments to investors on time and without unnecessary operational hiccups.

Launching a tokenized fund with COREDO

A tokenized fund is a synthesis of law, technology and processes. I am responsible for the integrity of the solution, and COREDO’s experience shows that a consistent architecture works better than a patchwork of disparate contractors. We combine registration procedures in the EU, Asia and the CIS, a security token offering for the fund, custody and exchange infrastructure, AML/KYC and GDPR, as well as tax and marketing frameworks.

If you see potential in tokenized funds, want to accelerate your go-to-market and retain control over risks, let’s discuss your strategy. I will propose a roadmap with clear milestones, costs and timelines, and the COREDO team will take you from the design session to the first dividend payout via smart contracts. This is a calm, transparent and results-oriented path that we have already followed many times with clients from Europe, Asia and the CIS.

Since 2016, my team has been supporting international projects in Europe, Asia and the CIS: from registration of legal entities and obtaining financial licenses to building AML/sanctions compliance systems and providing full operational support. Over that time I have seen how acutely entrepreneurs and managers need clear and fast tools to enter the EU market. In the investment segment, such a tool has become the Luxembourg RAIF: Reserved Alternative Investment Fund. In this article I will lay out why establishing a RAIF in Luxembourg today is one of the most rational ways to launch an alternative fund, how RAIF registration in Luxembourg works in practice, and which solutions COREDO usually builds into the architecture of fund structures to accelerate time-to-market and reduce regulatory and tax risks.

Why choose a RAIF in Luxembourg for funds?

Illustration for the section «Why RAIF in Luxembourg for funds» in the article «RAIF fund registration in Luxembourg - the fastest way»

The 2016 law on RAIF in Luxembourg offered a simple yet elegant compromise: the fund does not undergo prior authorization by the regulator, but operates under the supervision of an authorized AIFM and within the AIFMD ecosystem. This model sharply reduces time-to-market when launching a RAIF and makes rapid fund registration in Luxembourg an achievable goal without sacrificing the quality of risk management. In practice we observed first subscriptions already 10–12 weeks after the project start.

RAIF registration: the fastest way to enter the European field of alternative investments if the team is ready to operate under AIFMD rules and maintain a strong compliance framework for AML/KYC, risks and reporting. The regulatory advantages of RAIF include access to AIFMD passporting (through an AIFM), flexibility of investment strategies and the absence of limits typical for retail products.

The comparison of RAIF and SIF most often comes down to two points: speed and supervision. SIF requires prior approval from the CSSF, while RAIF does not; instead RAIF relies on an AIFM as a «supervisory filter». For sponsors who already have relationships with a licensed AIFM, the choice is obvious. For new teams, COREDO helps select an AIFM with the right mandate and strategy experience (private equity, real estate, credit, infrastructure, hedge) to ensure both compliance and quality.

How to quickly open a RAIF in Luxembourg

Illustration for the section «How to quickly open a RAIF in Luxembourg» in the article «RAIF fund registration in Luxembourg - the fastest way»

Legal support for RAIF registration relies on a clear checklist. I advise starting with the target strategy, investor profile and distribution geography, and then moving on to the vehicle, providers and documents. The COREDO team in a typical project runs all tracks in parallel to shorten calendar timeframes and eliminate bottlenecks before they arise.

Key registration stages and the RAIF checklist under the supervisory Commission CSSF are as follows:

  • Preliminary architecture: strategy, mandate, investor profile (qualified/professional), liquidity, leverage, valuation policy.
  • Choosing the fund’s legal form: FCP (contractual) or corporate (SICAV in the form of SA/SCA/SARL, as well as SCSp/SCS as flexible structures). For private equity and real assets SCSp most often prevails.
  • AIFM authorization and duties: choosing an authorized AIFM in the EU (often Luxembourg-based), agreeing delegation of investment management and risk management, RMP, conflicts of interest policy, AIFMD reporting.
  • Depositary and administrator for the RAIF: appointment of a depositary (bank/investment firm in the EU), selection of administrator and NAV calculation agent, transfer agent, registrar, auditor.
  • Documents for RAIF registration: investment memorandum/subscription memorandum (PPM), LPA for SCSp, constitutional documents, AML/KYC and sanctions policy, valuation policy, risk management, SLA and service agreements.
  • Notarization and Legal review of the constitutional documents, registration in the Luxembourg Trade and Companies Register (RCSL), account opening, subscription organization.
  • Setting up distribution: AIFMD passporting and marketing in the EU, distribution channels, placement agent and agency agreements, Reverse Solicitation policy and legal risks.

The speed of fund registration in the EU via RAIF depends on the readiness of documents and providers. Our experience at COREDO has shown that a parallel draft of the PPM/LPA, preliminary verification with the AIFM and an early term sheet with the depositary save up to 4–6 weeks, and SLAs and operational requirements are fixed before the first subscription launch.

registration documents RAIF

The PPM is the living DNA of the fund, not a formality. At COREDO we ensure that the investment memorandum and the Limited Partnership Agreement reflect the economics of the deal (management fee, performance fee, carried interest, clawback), liquidity (gates, suspension), the fund’s strategy and risk policy. The subscription memorandum and the LPA for the RAIF form a single framework together with valuation policies and risk management.

Documenting side agreements (side letters) for anchor institutional investors is a separate track. I insist on a concession matrix: preferences regarding the commission schedule, MFN, reporting, key personnel are written transparently so as not to breach equality between share classes. COREDO’s practice confirms that a well-thought-out MFN procedure reduces legal risks and facilitates subsequent closings.

Anti-money laundering policy for funds, AML procedures / KYC for institutional investors, sanctions compliance and GDPR: mandatory elements. We build checklists to verify the integrity of RAIF investors, UBO disclosure and data storage in accordance with GDPR. This improves the quality of AML and KYC for RAIF and accelerates onboarding.

Administrator, NAV calculation and depositary

The fund administrator and NAV calculation create the RAIF’s «operational metronome». SLAs and service agreements with providers should set NAV timing, cut-off for subscriptions/redemptions, reporting format, errors and remediation. Operational Due Diligence (ODD) providers and an independent audit at the start add discipline and trust from institutional investors.

The role of the depositary and its responsibilities are defined by AIFMD: safekeeping of assets (custody), oversight of subscriptions/redemptions, monitoring of cash liquidity and compliance with the investment mandate. The depositary bears strict liability for the loss of certain assets. In COREDO projects we pre-agree accounting models for illiquid assets and nominee arrangements to eliminate discrepancies with the bank’s policy.

For cross-border placement of RAIF units, payment and transfer agents are often engaged, as well as clearing and settlement system operators when listing certain share classes on LuxSE with settlements through Euroclear/Clearstream. Where listing is not required, settlements are made through custodial banks and administrators with strict AML/KYC and sanctions controls.

RAIF Structure: forms, SPV, substance

Illustration for the section «RAIF Structure: forms, SPV, substance» in the article «RAIF fund registration in Luxembourg - the fastest way»

The FCP fund form and corporate forms (including SICAV) set the legal mechanics. For closed-end strategies I more often choose SCSp and SCS as flexible structures: the partnership logic of an LPA, GP/LP separation, a clear waterfall model and carried interest. Differences between SICAV and SIF compared to RAIF are secondary here: the flexibility of the LPA and speed of launch matter more.

SPV structures for RAIF support investments in specific assets and jurisdictions. SOPARFI “holdings” often become intermediate companies for private equity and real estate thanks to the network of double tax treaty agreements and the efficiency of dividend/sale flows. For infrastructure we add project SPVs and contractual covenants with lenders.

Substance in Luxembourg for a RAIF fund: not a checkbox, but a managerial reality. I put in place local directors with the necessary experience, a place to hold documents, local meetings, agreements with key providers, and the economic rationale for expenses. Requirements for economic substance and presence are intensifying against the backdrop of BEPS risks and the practices of EU tax authorities. Additionally we take into account the UBO register and beneficiary disclosure obligations.

Taxation of RAIF and Investors

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Taxation of RAIF in Luxembourg is built on the principle of tax neutrality of the fund structure. As a rule, a RAIF does not pay corporate tax and VAT on investment activities, but pays a subscription tax (subscription tax) of 0.01% of net assets, with exceptions for certain asset classes (for example, private assets through specialised substructures). Tax optimisation through a RAIF is achieved by a combination of the fund + SPV (SOPARFI) to access the DTT network.

International tax planning and BEPS risks require a measured approach to leverage, tranche loans and interest limitations. I recommend coordinating the financing model with the AIFM and auditors to take into account ATAD restrictions and thin capitalisation rules in the target jurisdictions. For global investors, CRS exchange of financial information for funds and FATCA compliance for US investors are important — these tracks are best started from day one.

Income distribution policy, carried interest and tax consequences depend on the jurisdictions of the LP and GP. COREDO configures carried vehicles, waterfall and clawback to minimise ‘surprises’ on exits and ensure transparency for the auditor and investors.

Passporting of RAIF and AIFM under AIFMD

Illustration for the section «Passporting of RAIF and AIFM under AIFMD» in the article «RAIF fund registration in Luxembourg - the fastest way»

AIFMD and RAIF passporting: a powerful mechanism for the cross-border distribution of RAIF units within the EU. The AIFM sends notifications to the regulators of the host countries, after which marketing to professional investors becomes possible. International distribution of RAIF units in the EU is combined with local rules, so COREDO prepares marketing blue books and checklists for each market.

AIFM authorization and duties include risk management, leverage limits, Annex IV reporting, supervision of the delegation of investment management and control of the valuation function. Delegation of RAIF management and oversight require clear contracts, KPIs and regular monitoring. AIFM conflict of interest management and internal compliance are enshrined in a policy available to investors on request.

Reverse solicitation and legal risks: a topic where I always urge caution. Relying on the “investor’s initiative” without proper documentation is dangerous. It is better to build correct marketing and placement for RAIFs by engaging licensed placement agents and agency agreements than to risk a distribution ban and fines.

Risks, compliance (AML/KYC, sanctions, ESG)

Risk policy, VaR and stress tests, not only for hedge funds. The AIFM is obliged to assess market, credit, operational and liquidity risk, regularly conduct stress testing and monitor covenant breaches on loans of portfolio companies and funds of funds. Restrictions on the use of leverage are set out in the PPM, and risk reporting and regular stress testing are in the AIFM calendar.

Asset valuation policy and an independent valuer are especially important for illiquids. I recommend documenting the methods (DCF, comps, NAV bridge), the valuer’s independence criteria and escalation procedures in case of discrepancies. An independent audit and the annual report confirm the accuracy of the NAV and add confidence for LPs.

Sanctions compliance and sanctions screenings, AML/KYC procedures for investors and ESG compliance are essential pillars of trust. Integration of ESG criteria and reporting strengthens the commercial appeal of a RAIF to investors, especially in the Netherlands, Scandinavia and Germany. AIFMD supervision and internal compliance are complemented by GDPR and the protection of investors’ personal data.

RAIF for funds and real estate

RAIF for private equity is often structured as an SCSp with a GP at the Luxembourg level, SPV (SOPARFI) for deals and a well-thought-out waterfall model. Structuring of carried interest and tax consequences are discussed in advance, including clawback and escrow on partial exits. Entry terms for institutional investors set a minimum ticket size, side letters and MFN.

RAIF for real estate relies on SPVs with limited recourse and bank financing. Liquidity of units, redemption gates and suspension are governed by the mandate; for closed-ended funds, planned distributions and investor exit strategies.

RAIF for a family office is often used as an “umbrella” with several sub-funds for different asset classes. Family office use cases of RAIF allow consolidation of administration, improved risk control and documentation of investment mandates for succession. Restrictions on retail distribution and compliance remain: RAIF is addressed to qualified/professional investors.

Fund economics: fees and expenses

Fee structure: the management fee and performance fee should correspond to the strategy and market benchmarks. For PE it is typically 2/20 with a hurdle and catch-up; for real estate: 1–1.5% management fee and 15–20% performance fee on a project basis. Operating expenses, management fees and carried interest are included in the PPM transparently, including administration, depositary, audit, legal and placement expenses.

Annual expenses and fees of a RAIF depend on the providers, the number of sub-funds and NAV frequency. I recommend modelling three scenarios of AUM, subscriptions and expenses taking into account distribution layers (placement fee), so investors can see the fund’s financial model and ROI forecast. Key performance metrics (IRR, TVPI, PME) and their sensitivity to fees and deal timing help validate the economics.

Liquidity management, covenants and covenant breaches: an area of heightened attention for credit and infrastructure RAIFs. The AIFM and the administrator should monitor payment schedules, compliance with leverage limits and timely escalate deviations to the investment committee.

COREDO Cases and Time-to-Market

In one of its recent projects the COREDO team implemented the launch of an SCSp RAIF for a lower mid-market PE strategy with a geography covering the EU and the UK. We simultaneously closed the AIFM, depositary and administrator tracks, synchronized the LPA with the carried interest tax model and the side letters of anchor LPs. Time-to-market was 11 weeks to first close; passporting under AIFMD took another 3 weeks.

Another case: a RAIF for real estate focused on logistics parks in Western Europe. The solution developed at COREDO included a SOPARFI level, standardization of lease agreements, bank covenants and an independent valuator. We set up ESG and energy-efficiency reporting, which broadened the pool of institutional investors and simplified marketing in Germany and the Nordics.

Third example, a market-neutral hedge strategy. COREDO’s practice confirms that for such funds the key to success is an SLA for NAV T+3, VaR risk limits, the administrator’s clear error policy and automation of Annex IV reporting. We also set up sanctions monitoring and enhanced KYC flows for investors from several Asian markets.

RAIF Life Cycle

After first close, the routine but critical phase of the fund’s life begins: reporting, audit and investor relations. An independent audit and the annual report confirm the NAV and policy compliance, while risk reporting and regular stress testing sustain LP confidence. Marketing and placement for the RAIF continue under the AIFMD passport and local rules.

Liquidity of units, redemption gates and suspensions are determined in advance in the PPM and LPA. Investor exit strategies and winding-up procedures include appointing a liquidator, communicating with the depositary and administrator, calculating final distributions and closing entries in the RCSL. Liquidation and exit from the RAIF proceed smoothly if all operational documentation has been kept up to date and SLAs with providers have been observed.

On the secondary market for RAIF interests, transfers of LP interest are possible under the LPA procedures with GP consent and in compliance with AML/KYC. Regulation of private markets and the secondary market for interests impose disclosure requirements and sanctions checks – COREDO runs these processes as separate mini-projects.

RAIF launch checklist and common mistakes

Over the years I have compiled a short working checklist that saves weeks and money. Each item is accompanied by an internal procedure and a responsible person at the sponsor and the provider.

  • Structure and mandate: SCSp for PE/real assets; clear leverage and liquidity limits.
  • Providers: preliminary term sheet from the AIFM/depositary/administrator before the PPM draft.
  • Documents: PPM/LPA aligned with valuation, risk, AML/KYC and sanctions policies.
  • Taxes: RAIF + SOPARFI + DTT model, BEPS/ATAD assessment and a substance plan.
  • Marketing: AIFMD passport, placement agents, a distribution plan and control of reverse solicitation.
  • Operations: SLAs for NAV and operations, provider ODD, Annex IV roadmap and audit.
  • ESG and GDPR: a KPI and reporting matrix, data retention, data subject rights.

Typical mistakes: late selection of the AIFM and depositary, underestimating side letters and MFN, insufficient substance, excessive use of reverse solicitation and insufficient detail in the valuation policy. Our lawyers at COREDO usually address these risks already at the term sheet stage.

When RAIF is not suitable, pros and cons

The advantages of RAIF are obvious: speed, strategic flexibility, access to the AIFMD passport, tax neutrality of the fund structure and broad applicability — RAIF for private equity, RAIF for real estate, RAIF for hedge funds, as well as RAIF for family offices and institutional investors. The commercial appeal of RAIF to investors is enhanced by Luxembourg’s transparent regulatory framework and strong infrastructure.

There are downsides too. Restrictions on retail distribution of RAIF close off access to the mass market. The presence of an AIFM and a depositary adds ongoing costs. Strict AML standards/KYC, sanctions, AIFMD reporting and ESG expectations require a mature operational team. If the goal is a retail UCITS product line, RAIF is not the right instrument.

How COREDO supports the launch of a RAIF

COREDO handles the structural architecture, legal drafting and coordination of providers. We prepare the PPM, LPA, side letters, AML/KYC and sanctions policies, valuation policy, risk framework and governance documents. We also select the AIFM, depositary, administrator and auditor, agree SLAs, and arrange notarisation and registration with the RCSL.

A separate area is the tax model: tax optimisation through the RAIF, SPV structuring, use of the network of double tax treaties, CRS/FATCA assessment, substance and UBO. For international distribution of RAIF interests we prepare distribution packages, marketing materials and compliance control procedures.

At the operational level the COREDO team sets up AIFMD oversight and internal compliance, risk reporting and regular stress testing, GDPR procedures, sanctions monitoring and ESG reporting. Cross-border structuring and jurisdictional risks are covered by legal memoranda and the ODD of key providers.

Conclusions

RAIF is a mature and flexible platform for launching alternative funds in the EU with a unique balance of speed and regulatory quality. When the strategy, documents and providers are aligned, RAIF time-to-market is measured in weeks, not quarters. At the same time the rules of the game are clear: AIFM supervision, robust AML/KYC and sanctions framework, well-considered valuation and risks, and transparent economics for investors.

Over the years I have become convinced: a properly structured RAIF addresses several pain points of entrepreneurs and managers at once, from quick registration and cross-border distribution to tax neutrality and institutional investors’ trust. If you are planning a fund for private equity, real estate, infrastructure or market strategies and are targeting qualified investors in the EU and beyond, RAIF should be on your short list. The COREDO team is ready to walk the whole way with you – from the idea and financial model to the first closing, reporting and sustainable scaling.

I have been building COREDO since 2016 with a single goal: to help entrepreneurs and CFOs quickly and safely scale their businesses through international structures, licensing and high-quality compliance. In recent years the European market has given us a new tool that genuinely expands financing for long-term projects and opens private investors’ access to illiquid asset classes. This is about ELTIF 2.0: the updated European form of long-term investment funds with a distribution passport. Below: my perspective as the founder and a practitioner of the COREDO team, so that you can make an informed decision: to launch your own ELTIF, invest in one, or use it as part of your corporate strategy.

Why does business need ELTIF 2.0 today?

Illustration for the section «Why does business need ELTIF 2.0 today?» in the article «ELTIF 2.0 – opportunities for retail investors»

ELTIF 2.0 frees the hands of managers who want to finance infrastructure, real assets, private equity and SME lending, while also expanding capital-raising channels via retail investors. For entrepreneurs it means new money for construction and M&A, and for family offices and corporate investors — a diversification tool with a clear regulatory framework. The COREDO team has already implemented dozens of projects for fund registrations, licensing and distribution in the EU, Asia and the CIS; that experience shows where ELTIF works particularly effectively.
The second reason is alignment with European standards. EU ELTIF rules are integrated with the Alternative Investment Fund Managers Directive (AIFMD), MiFID II, PRIIPs and the ESG framework (SFDR and the EU taxonomy). This increases supervisory predictability, facilitates passporting of ELTIF 2.0 across the European Union and reduces legal fragmentation. In practice COREDO confirms: when you structure a fund in line with these rules from day one, time-to-market shortens and distributors connect more quickly.

ELTIF 2.0: EU rules and opportunities

Illustration for the section “ELTIF 2.0: EU rules and opportunities” in the article “ELTIF 2.0 – opportunities for retail investors”

ELTIF is a licensable alternative investment fund focused on long-term and often illiquid assets. Version 2.0 eased a number of the first edition’s restrictions: the criteria for eligible ELTIF assets have been broadened, working with co‑investments and SPV/holdco chains has been simplified, limits on ELTIF leverage have been clarified, and flexibility has been introduced regarding liquidity and redemptions. As a result, the product has moved closer to what the market has long needed: institutional discipline with the ability to attract retail capital.
ELTIF and infrastructure projects are a natural fit. Transport, energy, social infrastructure, digital networks, as well as renewable energy projects in ELTIFs receive financing on a 7–12 year horizon and beyond. On the debt side, infrastructure debt solutions are available; on the equity side – infrastructure equity and private equity/venture capital strategies within ELTIFs to support the growth of technology and industrial companies. In some cases COREDO helped combine such strategies into a multi‑asset structure where debt generates coupon cash flow and equity provides upside.

ELTIF for investors: access and protection

ELTIFs for private investors have become a reality. Retail investors’ access to ELTIFs has been expanded, while protective mechanisms remain in place: suitability and appropriateness tests for ELTIFs under MiFID II, target market assessment and product governance at distributors. KIDs and disclosure for ELTIFs under PRIIPs are mandatory, which standardizes the description of risks, costs and performance scenarios. COREDO’s practice confirms that correct configuration of the KID, scenario analysis and risk warnings increases sales conversion without compromising compliance quality.
The risks for retail investors in ELTIFs lie in illiquidity, long horizons and the volatility of valuations of non‑market assets. We address them through a transparent lock‑up period, clear maturity and redemption principles, as well as well‑designed redemption gates and suspension of redemptions in case of stress. It is important to explain liquidity mismatch and manage expectations for investors: this is not UCITS, and the secondary market for ELTIF units operates differently.

Minimum investments and fees

Minimum investment requirements for ELTIF 2.0 depend on the jurisdiction and the target market; for the retail segment regulators allow a threshold starting from several thousand euros subject to suitability tests and client portfolio exposure limits. In some countries a retail cap applies — a limit on the share of ELTIFs in an investor’s assets. I recommend building mechanisms into the term sheet to control these limits on the distributor side to avoid subsequent claims from NCAs.
The fee structure of an ELTIF includes management fees, performance fees, carried interest (if applicable), as well as ongoing charges. The practice of disclosing costs and fees in ELTIFs requires detail: the accrual basis, high‑water mark, hurdle rate and the method for calculating carried interest. We take into account the impact of exit fees and early redemption penalties on investor behavior and align this with the KID and marketing materials to provide a consistent picture of costs.

How to avoid liquidity mismatch

Liquidity and redemption in ELTIFs: a key design factor. ELTIF 2.0 allows limited redemption windows provided there are liquidity management mechanisms: staged redemptions, queueing, redemption gates and procedures for suspension agreed with the depositary. Restrictions on early redemptions in ELTIFs are explainable by the nature of the assets; the manager’s task is to record them transparently in the fund policy and the KID.
The secondary market for ELTIF units is developing. How does the ELTIF secondary market work in practice? Most often it involves organized platforms and partnerships with liquidity providers, as well as bilateral transactions observing transferability of units and transfer restrictions. At COREDO we implemented tokenization of units and digital registers where NCAs permit DLT solutions: this speeds up settlements and reduces operational risks without compromising AML/KYC controls.

Eligible assets and valuation models

Illustration for the section «Eligible assets and valuation models» in the article «ELTIF 2.0 – opportunities for retail investors»

What assets are permitted in ELTIF 2.0? The list is broader than before: equity and quasi-equity in non‑blue‑chip names, debt and SME issuances, infrastructure assets and projects, real estate and other real assets, as well as stakes in other funds subject to concentration limits. Asset concentration limits in ELTIF protect the investor from excessive risk to a single borrower or asset, and I recommend using internal limits that are stricter than the regulatory ones.
In infrastructure it is important to separate strategies: infrastructure debt vs infrastructure equity. Debt portfolios provide a predictable cash yield and lower standard deviation; equity approaches require a detailed growth model and active asset management. For VC within ELTIF we separately agree capital calls and drawdown mechanics to avoid capital being idle while retaining control over subscriptions.

Valuation of illiquid assets and NAV

Approaches to valuing illiquid assets in ELTIF must be transparent. We apply NAV valuation methodologies for illiquid assets based on discounted cash flows, comparable market multiples and independent valuation (third‑party valuation). For infrastructure a discount rate is used that reflects country risk, contract structure (PPAs, concessions) and inflation indexation.
Scenario analysis and stress testing of the portfolio are mandatory within risk management. We show investors the risk‑adjusted return via IRR, TVPI, DPI and ROI metrics, and for a large deal — a scenario ROI calculation taking into account sensitivity to monetary policy and inflation. ELTIF performance assessment for long‑term investors is built on project cohorts and the distribution schedule, not on short‑term NAV fluctuations.

How to manage risks and hedge?

The use of leverage in ELTIF and its limits are governed by ELTIF 2.0 and AIFMD: borrowing restrictions (leverage caps) are tied to strategy and asset liquidity. We use subordinated debt, subscription lines and the fund’s credit structure to smooth capital calls while maintaining cash flow transparency. Interest rate and currency risk hedging instruments — swaps, forwards, option structures — reduce IRR volatility without destroying upside.
Contingency planning and crisis scenario management include triggers to review redemptions, redistribution of capital calls and disclosure discipline. Internal control and the manager’s compliance procedures oversee conflicts of interest, side letters and deal prioritization, in order to protect retail and the institutional base equally.

How to launch ELTIF 2.0

Illustration for the section ‘How to launch ELTIF 2.0’ in the article ‘ELTIF 2.0 – opportunities for retail investors’

The solution developed at COREDO is a phased roadmap: choice of jurisdiction, strategy design, document preparation, coordination with the NCA, setup of custody and the depositary, compliance and the start of distribution. We combine legal work with operational design: from the LP/GP model and partners’ legal agreements to sales due diligence and distributor integration. This approach saves months and removes misalignment between lawyers, the administrator and the sales team.
Regulatory obligations of ELTIF 2.0 managers are based on AIFMD: reporting to the NCA and ESMA, risk disclosure, leverage limits, liquidity management and depositary oversight. Prospectus exemptions and simplified documentation are available in places, but we always proceed from a standard of full transparency to withstand inspections by any EU regulator.

Choice of jurisdiction

Luxembourg and Ireland are the flagships. A rich ecosystem of depositaries, administrators, auditors and the NCA’s readiness to engage speed up passporting for collective investment products. For venture and infrastructure themes we often approach via Luxembourg with SPVs at the portfolio level in the EU and the UK. In certain strategies Cyprus and Estonia are appropriate for SPVs and holdco structures when local double tax treaties and operational simplicity are important.
Relocation of the manager and fund registration of an ELTIF in the EU are possible either through an in-house AIFM licence or by appointing an external manager (appointed AIFM). Our experience at COREDO has shown that for debut teams an external AIFM speeds up the start, and moving to an in-house licence should be considered as AUM grows. For deals with Asian and Middle Eastern components we connect Singaporean and Dubai platforms at the pipeline level while retaining ELTIF status in the EU.

Fund: SPV/holding company, capital calls

SPV and holdco structures and target companies determine tax and operational efficiency. We design the custody chain and the role of the depositary so that all cash flows are traceable and depositary liability and the custodian’s duties are performed without disruptions. Capital calls and the drawdown mechanics are synchronized with subscriptions at distributors; subscription lines and the fund’s credit structure reduce cash drag and allow investors to enter with less idle cash.
Management of the manager’s conflicts of interest is recorded in policy, disclosed in the KID/prospectus, and also overseen by an independent director and the depositary. Share classes and unit classes are configured for different channels: institutional classes without trail fees and retail classes that account for platform costs.

Depositary and asset custody

ELTIF 2.0 requirements for the depositary and asset custody are fundamentally important. The depositary controls compliance with the investment policy, holds custody, tracks flows and verifies NAV calculations. COREDO’s practice confirms: early selection of the depositary and alignment of the LPA/prospectus save months in approvals with the NCA.
Compliance: AML/KYC for international investors, FATCA/CRS and investor tax reporting, documenting investor communications and product marketing — this is the baseline. Our AML team builds a risk-based approach: sources of funds, beneficial ownership structure, sanctions and PEP checks, ongoing transaction monitoring. For cross-border flows we use agreed W-8/W-9 forms, CRS self-certification and qualification procedures under double tax treaties.

Distribution and retail in the EU, Asia and the CIS

Illustration for the section “Distribution and retail in the EU, Asia and the CIS” in the article “ELTIF 2.0 – opportunities for retail investors”

ELTIF distribution rules in the European Union require notifying the NCA in the home member state and using ELTIF 2.0 passporting to enter other EU markets. Next: local adaptation of marketing materials, a KID in the country’s language and channel settings taking MiFID II into account. For clients from Asia and the CIS it is important to plan the subscription currency, FX hedging and tax requirements for repatriation of payments in advance.
The role of distributors and retail investment platforms is growing. We integrate ELTIF with platforms that can perform suitability and appropriateness tests, conduct product governance and target market assessment, and provide transparent onboarding. Cross-border distribution in the EU and the CIS requires alignment of the legal and operational parts: a single data room with the KID, prospectus, SFDR disclosure and training materials for sales staff will be useful here.

Distribution and client tests

MiFID II requirements for the distribution of complex products determine the sales process. Suitability criteria for selling ELTIFs to retail clients take into account investment experience, objectives, horizon and risk tolerance. We structure product governance so that the distributor receives a clear picture: target segment, concentration limits, warnings about illiquidity, and scenario outcomes.
KID and PRIIPs: not just a formality. We configure the Key Information Document together with the prospectus and SFDR disclosure to avoid inconsistencies. We incorporate ESMA guidance and regulatory practices on ELTIF 2.0 into marketing templates, and include national competent authorities (NCAs) in checklists for each country.

Taxation and investor reporting

Taxation of investments in ELTIF depends on the status of the fund and the investor. Tax consequences for corporate investors in ELTIF include participation rules, withholding at source on coupons/dividends, and the application of double tax treaties. For investors from Asia and the CIS, local CFC rules, taxation of capital gains and reporting requirements are important.
FATCA/CRS and tax reporting of investors require the correct classification of the fund and the qualification of each LP. We ensure control of FFI status, prepare reports and exchanges in standard formats. For ESG strategies we separately show compatibility of ELTIF assets with the EU Taxonomy and SFDR requirements for ELTIF, which helps corporate investors collect their own non-financial reporting.

Liquidity of units on the secondary market

What does the ELTIF secondary market look like? Today it is a mix of OTC deals, specialized secondary platforms for trading units of illiquid funds and solutions from liquidity providers. Transferability of units and transfer restrictions are governed by the LPA and national law; COREDO pre-defines the procedure so that transactions proceed quickly and without risk of losing status-eligibility.
The market for secondaries and the role of liquidity providers are strengthening as the retail base grows. We test tokenization of units and digital registers where permitted: to speed up KYC and T+0/T+1 settlements. Exit mechanisms, early redemption penalties and exit fees must be synchronized with the liquidity policy and disclosure in the KID so as not to create false expectations.

COREDO cases: from idea to first closing

Recently the COREDO team implemented an ELTIF in renewable energy, registered in Luxembourg and distributed in Germany, Italy, the Czech Republic and Slovakia. We built the SPV chain, appointed an external AIFM, agreed the depositary and set up subscription lines. Anchor investors, seed capital and initial closings provided the critical mass of AUM, after which we connected retail channels with adapted share classes.
Another project — converting an ELTIF to the retail segment from a purely institutional infrastructure debt strategy. The conversion to the retail segment required a complete rework of the KID, disclosure of costs and fee structure, as well as distributor training on product governance. As a result, the fund opened access for ticket sizes from €10–25 thousand, while preserving leverage discipline and strict project underwriting.
A separate case — an ELTIF for investors from Asia and the CIS. We prepared a cross-border distribution scheme taking into account local suitability rules, integrated AML/KYC procedures and structured tax optimization with regard to double tax treaties. The result: clear onboarding, correct FATCA/CRS reporting and a distributions plan with currency risk hedging.

Renewable energy infrastructure and long-term capital

In renewable energy infrastructure we modelled IRR, MOIC and TVPI for each project cohort, taking into account discounting at the risk-free rate and premiums for country and technology risk. ESG Due Diligence and impact measurement are built into the investment process: SFDR article, compliance with the EU taxonomy and transparent emissions KPIs. This discipline eased negotiations with NCAs and distributors and sped up the first closing.

Transitioning the fund to the retail segment

We conducted a governance audit: reviewed concentration limits, updated the liquidity policy, added retail investor protection mechanisms in ELTIF 2.0 and harmonized disclosure with the KID. Conflict-of-interest management and a transparent performance fee/carry structure increased client trust. In marketing we used a prospectus-driven approach without excessive promises.

Cross-border distribution and AML for investors from Asia and the CIS

COREDO established a sales due diligence procedure and issuer checks, and also segmented risks by jurisdiction. AML/KYC for international investors covered source-of-funds checks, corporate chain reviews and sanctions lists; adapting documents into local languages sped up verification. Result: a steady inflow of subscriptions, no flags from the depositary and predictable reporting to the NCA.

Entrepreneurs’ questions

How can a retail investor invest in ELTIF 2.0? Through a licensed distributor or platform, by passing suitability/appropriateness tests, signing the KID and the subscription documents. Minimum subscription requirements and the retail cap depend on the market; they should be clarified in advance.
The comparison between ELTIF and UCITS for retail clients comes down to liquidity and asset composition. UCITS: daily liquidity and liquid securities; ELTIF: illiquid long-term assets and limited redemptions, but potentially higher risk-adjusted returns. Liquidity management in ELTIF funds is based on planning redemptions and developing the secondary market.
What assets are permitted in ELTIF 2.0? Infrastructure, real estate, stakes in private companies, SME loans, participations in qualifying funds, subject to limits. Restrictions on borrowed financing in ELTIF control leverage and protect the investor.
How to assess returns? Evaluating ELTIF returns for long-term investors involves IRR by investment cohorts, TVPI/DPI at the fund level, sensitivity to interest rates and inflation, and scenario analysis. The use of leverage in ELTIF and the limits define the framework for return and risk; currency and interest-rate hedging smooth the profile.

How COREDO scales the product

Product scalability on international markets is about synchronizing legal, distribution and operational infrastructure. COREDO sets up the pipeline for working with anchor investors, seed capital and initial closings, then connects platforms, distributor banks and independent consultants. We create a unified data room, prepare training materials for sales teams, establish CRM processes and reporting to NCA/ESMA.
ESG integration increases demand among corporate and retail clients. We conduct ESG due diligence and impact measurement, check assets for compatibility with the EU taxonomy and set up SFDR disclosure. In parallel we carry out tax structuring, currency hedging and configure document flow for stable capital calls.
We keep operational costs of managing long-term assets under control through administrative automation and clear SLAs with providers. Sales due diligence, risk disclosure practices and consumer protection build trust; in crisis scenarios we activate contingency planning in advance to protect capital and reputation.

Conclusions

ELTIF 2.0 is a mature European instrument that gives businesses access to long-term capital and investors access to real assets within a transparent regulatory framework. At COREDO we combine legal precision, financial engineering and compliance so the product works in practice: with clear liquidity rules, understandable fees, carefully considered risks and effective distribution. If you need to launch or scale an ELTIF, the COREDO team is ready to go the whole way: from the idea and choice of jurisdiction to the first closing and sustainable subscription flows, with responsibility and attention to every detail.

I often hear the same request from owners and asset managers: provide a structure that accelerates a fund’s launch, withstands institutional due diligence, and scales without pain. The Variable Capital Company in Singapore (Singapore VCC) addresses exactly these needs. In recent years the COREDO team has completed dozens of VCC design and registration projects for hedge funds, credit strategies, venture and multi-asset platforms, and I see how quickly the VCC is becoming the standard in Asia and a practical alternative to European and UK formats.

The VCC was created as the market’s response to flexibility, technological sophistication, and regulatory predictability. Its structure supports an umbrella VCC with sub-funds, strict asset segregation and unified corporate processes.

COREDO’s experience confirms: with sound architecture operational costs fall and time-to-market shortens without compromises on compliance and risk management.

VCC architecture and asset segregation

Illustration for the section «VCC architecture and asset segregation» in the article «Variable Capital Company in Singapore – structure for hedge funds 2026»
The basic model – an umbrella VCC structure under which one or several sub-funds are created. Each sub-fund has separate assets and liabilities, and the legislation provides for statutory segregation, i.e., legal separation at the level of law rather than only by contract. This is critical for hedge funds with different risk strategies, where the investor mandate and liquidity vary across sub-funds.

Our experience at COREDO has shown that multi-strategy managers find it beneficial to consolidate common functions (directors, administrator, auditor, compliance) at the “umbrella” level and allocate portfolio decisions to the sub-funds. This reduces duplication of costs, simplifies reporting, and transfers of assets between VCC sub-funds during rebalancing proceed through transparent procedures at the level of the board of directors and the administrator.

An additional advantage: the registration of sub-funds and their asset segregation do not require the creation of separate legal entities. This speeds up the launch of new strategy lines, simplifies the closing or reorganization of VCC sub-funds and disciplines corporate governance.

VCC Act 2018 and 2026 Amendments: the Role of MAS

Illustration for the section «VCC Act 2018 and 2026 Amendments: the Role of MAS» in the article «Variable Capital Company in Singapore – structure for hedge funds 2026»
The legal foundation is laid by the VCC Act 2018, and the 2026 amendments strengthen AML/CFT controls, the disclosure of beneficial ownership, and the quality of reporting. The Monetary Authority of Singapore (MAS) coordinates supervision through the requirements of the SFA (Securities and Futures Act) and the rules for Collective Investment Schemes (CIS), and also introduces clarifications to the MAS 2026 reporting requirements, including electronic channels and standardized templates.

In 2026 the emphasis shifted to operational risk management and cybersecurity, so that fund platforms comply with new outsourcing methods and cloud storage.

The solution developed at COREDO combines a cybersecurity policy for VCCs, agreements with IT providers, an incident log, and regular stress tests for critical systems, which helps to pass MAS inspection requests smoothly.

From a classification standpoint, a VCC can support both closed and open strategies within a CIS, providing flexibility in liquidity and instruments. The COREDO team is accustomed to drafting documents so that a sub‑fund’s investment mandate clearly falls into the appropriate category and internal procedures comply with the SFA.

How to set up a VCC for a hedge fund

Illustration for the section «How to set up a VCC for a hedge fund» in the article «Variable Capital Company in Singapore – structure for hedge funds 2026»
I start with a product roadmap: strategy, liquidity, investor geography, institutional requirements. Then we structure the legal shell: VCC registration in Singapore, define the board composition, and choose the corporate secretary and CSP.

At this stage it is especially important to carry out Due Diligence when selecting a CSP for the VCC: the provider must ensure SLA on timelines, competencies in AML/KYC and experience integrating with administrators.

Next – Licensing of the fund manager (FMC/CMS). To manage assets registration as a Fund Management Company (FMC) is required: depending on AUM and client type the Registered Fund Management Company (RFMC) scheme or Capital Markets Services (CMS) licence will be suitable.

Our roadmaps take growth into account: it is often sensible to start as an RFMC, and as AUM and the institutional base grow transition to CMS without rebuilding the entire operating model.

In parallel we arrange agreements: custodian and depositary functions, fund administrator and transfer agent, independent auditor, provider of independent valuation (for illiquid assets). At the level of investment documentation we set up management fee and performance fee with high-water mark and hurdle rate, waterfall distribution of income and side pockets for illiquid positions. The COREDO team pays attention to both legal logic and operational feasibility so that the administrator correctly calculates NAV and carried interest.

VCC Taxation in Singapore

Illustration for the section “VCC Taxation in Singapore” in the article “Variable Capital Company in Singapore – structure for hedge funds 2026”
VCC taxation in Singapore relies on preferential regimes (including the Enhanced Tier Fund), exemptions for investment income when criteria are met and tax residency is confirmed. Economic substance rules and demonstration of activity are important: board meetings in Singapore, qualifying resident directors, local compliance and on-the-ground operational functions.

For certain profiles we add management company substance and staffing requirements to strengthen the position during international inquiries.

There is a network of double taxation avoidance agreements with investors from the EU and Asia. We model cash flows and withholding taxes by beneficiary country, and also review transfer pricing and related parties in the VCC structure if the manager’s service company is present. For GST (Goods and Services Tax) special rules apply to funds; properly structured exported services and interactions with non-residents affect the calculation.

COREDO’s practice confirms: clear documentation of the “centre of management and control” and a well-thought currency structure and profit allocation of the VCC help reduce tax risks associated with the VCC and ensure a steady ROI for investors.

AML/CFT, KYC and e-KYC Compliance 2026

Illustration for the section "AML/CFT, KYC and e-KYC Compliance 2026" in the article "Variable Capital Company in Singapore – structure for hedge funds 2026"
AML compliance for VCC is based on a risk-based approach: PEP checks, sanctions screening, sources of funds and the obligation to file SARs for suspicious transactions.

AML/CFT 2026 updates strengthen requirements for periodic risk reassessment and customer due diligence.

I ensure that the policy reflects actual operations: investor risk profiles are aligned with the sub-fund strategy, and triggers for Enhanced Due Diligence are logical and measurable.

KYC and e-KYC for VCC have become standard. We build a digital investor onboarding workflow: document collection, e-signature, liveness-check, address verification, automatic sanctions screening and UBO mapping. The beneficial ownership register must be up to date and reconciled with the administrator’s and transfer agent’s data. For US clients: FATCA reporting and GIIN settings; for others: Common Reporting Standard (CRS).

COREDO’s portfolio includes solutions that combine FATCA and CRS profiles into a single investor profile.

Finally, the impact of PDPA (Personal Data Protection Act) and GDPR when working with European investors requires conscious data management: minimization, storage, access and deletion. We document the roles of controller and processor, and define secure channels for exchanges with administrators and distributors.

Operating model: NAV, IFRS, audit

The custodian and depository are anchor partners. In Singaporean practice the custodian provides safekeeping and the processing of corporate actions, and a trustee is appointed for some CIS-structures. We compare servicing by asset classes, cut-offs for settlements, fee models and prime brokerage capabilities. The administrator and transfer agent close the NAV, maintain investor records, calculate fees and produce reporting; the SLA should fix deadlines, responsibilities and the business continuity plan.

NAV valuation practices for complex assets are set by the valuation policy: fair value hierarchy, independent quotes, model prices, role of an independent valuation provider.

I insist on a revaluation calendar, a “challenge” process by the administrator and unambiguous documentation in the investment committees.

Financial reporting under IFRS and external audit requirements are the basis of trust. Auditor independence, the agreed scope of sample testing across sub-funds and the timeline for completion of audits are critical to the marketing cycle.

Our clients receive a “DDQ-ready” folder: financial statements, conflicts of interest policy, annual compliance report and cybersecurity questionnaires.

Liquidity, risks and leverage

Liquidity management and redemption gates in VCC begin with designing terms: redemption periods, notice periods, lock-up periods, suspension of redemptions and side pocket structures. For illiquid assets, side pockets and special purpose vehicles within a VCC help protect investors of the underlying sub-fund. We tie the policy to the actual turnover of assets, stress testing and liquidity ranking.

The use of borrowed leverage and limits for a VCC are linked to prime brokerage agreements and margin financing. The COREDO team sets up collateral agreements, governance for margin calls and limits on leverage. For derivative operations we deploy frameworks for margin requirements, counterparty risk assessment, as well as policies on securities lending and credit risk.

At the core – the risk management framework: VAR, stress testing, scenario analysis, limits by asset classes and concentrations, three lines of defense and regular reports to the board of directors. This approach simplifies discussions with institutional investors and reduces operational risk for both the manager and the investor.

Engaging with Investors in the EU

AIFMD marketing rules require careful thinking. For many strategies, fund marketing in Europe is through a VCC: country-specific NPPR requirements and/or working via Reverse Solicitation. Passporting from Singapore to the EU does not apply, so we develop country-by-country maps: where reverse solicitation is permitted, where a local representative is required and what disclosures are necessary.

In complex cases we prepare legal opinions and reliance letters for foreign investors.

Servicing EU investors and GDPR requirements come to the forefront. We formalize subscription channels, KID/KIID materials where necessary, and agree disclosures on remuneration, ESG and risks. Market access strategies to attract institutional investors from the EU, Asia and the CIS include a roadshow schedule, selecting a custodian with a recognised name and audit practices accepted by institutions.

For the US and many Asian jurisdictions FATCA and CRS are important, as is the correct investor classification.

Our document packages help complete KYC quickly, without sacrificing the thoroughness of the checks.

Tokenization without regulatory gaps

Tokenization of fund shares in a VCC and tokenisation of fund shares require careful legal scrutiny. Singapore allows digital solutions subject to compliance with the SFA and rules on digital tokens; smart contracts and automation of distributions (distributions) are possible if the administrator, custodian and audit agree on control points. I insist on an independent reconciliation of the token register with the investor register at the transfer agent.

Crypto hedge funds in a VCC, legal risks around custody, AML and volatility. We set up custodial chains with certified crypto custodians, include additional KYC requirements and valuation methodologies for illiquid/digital positions.

The AML/CFT 2026 updates and their impact on VCCs in the digital domain strengthen transaction monitoring, source-of-funds checks for cryptoassets and sanctions screening of addresses.

Cybersecurity, a mandatory element: cybersecurity controls, vulnerability log, DLP, access control and cloud storage policy. Such measures are important not only for MAS, but also for due diligence by exchanges and prime brokers.

Cost calculation, ROI and scaling

The cost of launching and maintaining a VCC depends on the number of sub-funds, the manager’s license, the composition of partners and the geography of investors. In a typical configuration CAPEX includes registration, legal documentation, setup of service providers and the IT stack; OPEX includes administration, audit, compliance, custodian fees, directors and D&O insurance. I recommend performing a cost-benefit analysis: OPEX vs CAPEX when choosing a VCC, expected AUM, fee terms and the load on the back-office.

Return on investment (ROI) when using a VCC is improved by umbrella fund efficiency, fast registration of sub-funds and economies of scale on services.

KPIs and ROI metrics for a fund structure: IRR on the manager’s capital, MOIC on platform investments, TER for each sub-fund, investor onboarding speed and NAV close time. Scaling a hedge fund via a VCC relies on modularity: new sub-funds are opened according to a ready checklist with vetted counterparties.

How to organize a hedge fund waterfall in a VCC? We fix the management fee, performance fee, high-water mark and hurdle rate, and set out the clawback mechanics and crystallization dates. For currency structuring and profit calculation the VCC uses the fund’s base currency, an FX hedging policy and a transparent profit calculation per share class. If necessary we include re-domiciliation and cross-border migration of funds to transfer assets into the VCC without tax or operational shocks.

Reorganization and liquidation of VCC sub-funds, as well as liquidation, winding-up procedures and creditor priorities, are described in advance in the constitutional documents and the liquidity management policy. This reduces the risk of disputes and simplifies coordination with investors.

VCC, SICAV and English structures

Jurisdictional comparisons show: VCC wins on speed of launch, sub-fund flexibility and tech-enabled compliance. The Luxembourg SICAV is familiar to European institutional investors and provides a strong “passport” in the EU, but requires more time and budget.

English structures benefit from a common-law approach and a provider ecosystem, but after recent regulatory changes are not always optimal for pan-Asian marketing.

At COREDO I prefer to match the structure to the strategy and the investor. For pan-Asia capital raising and tech funds, VCC often leads; for deep distribution into the EU, SICAV remains a strong option. There is no “one-size-fits-all” here — it’s important to design the architecture, budget and licensing roadmap.

Relocating a management company to Singapore: pros and cons

Relocating a management company to Singapore strengthens the economic presence (substance) of a VCC: resident directors, a local risk-management and compliance team, board meetings, working relationships with MAS. Pros: tax predictability, access to Asian investors, a well-developed infrastructure of custodians and administrators.

Downsides, requirements for staffing and operational discipline: you will need to invest in processes, PDPA procedures, cyber security and regular reporting. If the strategy targets Europe, parallel services in the EU under GDPR and AIFMD distribution will remain relevant. I am considering hybrid models: a manager in Singapore plus a distribution office in key cities in Europe or Asia.

COREDO case studies: how it works in practice

Case 1. Multi-strategy VCC with two sub-funds for public and private assets. We designed the umbrella, organized an RFMC with a scalable roadmap on the CMS, engaged a global custodian and administrator, and set up an independent valuation provider for private positions. Within 12 months AUM surpassed the target, and the transition to the CMS was completed without interrupting marketing. Investors from the EU entered via reverse solicitation under agreed legal opinions.

Case 2. Crypto hedge fund inside a VCC with a pilot for tokenization of shares. We engaged a specialized crypto custodian, strengthened the AML policy with on-chain monitoring, and implemented e-KYC with liveness checks and sanctions screening of addresses. NAV was calculated using an independent valuation model and pricing sources agreed with the auditor. The COREDO team built smart contract checkpoints for distributions and reconciliation with the transfer agent.

Case 3. A family office with an Enhanced Tier Fund and four sub-funds by asset class. We optimized the tax profile, set KPIs for TER and operational SLAs, and appointed independent directors and an audit committee. Within the structure there was a side pocket for illiquid assets and an SPV for securitization transactions. Institutional due diligence was completed without issues, and IFRS reporting was closed in line with the marketing cycle.

ESG maturity for institutional investors

VCC corporate governance and independent directors are not a formality. I implement board charters, committees (audit, risk), a meeting schedule and a policy on conflicts of interest and related party transactions. This minimizes risks and increases the parties’ confidence.

ESG and sustainable investing in the context of VCC manifest in disclosures, due diligence of providers, voting policy and data management. Investors expect consistency: asset selection criteria, metrics, escalation procedures and independent verification where possible.

Founder’s pre-launch checklist

  • due diligence of the fund manager and track record, including operational incidents.
  • custodian vs trustee role in Singapore practice and compatibility with prime brokerage.
  • fund administrator responsibilities and SLAs, experience with the required asset class.
  • transfer agency and investor register maintenance, integration with e-KYC.
  • independent valuation provider and valuation methodologies for illiquid assets.
  • risk management framework: VAR, stress testing, scenario analysis and limits.
  • valuation policy, fair value hierarchy and involvement of third parties.
  • external audit requirements and auditor independence.
  • beneficial ownership register and disclosure requirements.
  • FATCA reporting for US investors and the Common Reporting Standard (CRS).
  • AIFMD rules, reverse solicitation and local NPPRs in the EU.
  • cybersecurity controls and cloud storage for fund administration.
  • legal opinions for distributions and reliance letters for key jurisdictions.

Cost and timelines: a realistic benchmark

For a standard VCC with one sub-fund and RFMC, it’s reasonable to plan 3–5 months from the kick-off session to the first close, assuming prompt decisions and ready investment content. Budgets depend on the choice of providers and architecture, but the main share is made up by administration, audit, custodian and independent directors. I always provide two to three scenario budgets to align OPEX with target AUM and the required TER.

When scaling through additional sub-funds, timelines shorten because the legal framework and providers are already set up.

This is where the VCC shows its real advantage: rapid launch of new strategies with controlled margins and manageable risks.

VCC and the role of COREDO

VCC is not just a legal form. It is an infrastructure platform for strategy, marketing and compliance that helps accelerate growth, keep risk manageable, and speak to institutional investors in the same language. In light of the 2026 amendments to the VCC Act and tightening AML/CTF standards, funds with strong substance, clear policies and disciplined reporting will gain a strategic advantage.

I build roadmaps tailored to the needs of owners and managers: from a blank slate to first close and scaling.

The COREDO team brings a comprehensive approach: licensing (FMC/CMS), tax structuring and Enhanced Tier Fund, AML/KYC compliance and e-KYC, setting up a custodian, administrator and independent valuation, as well as marketing support in the EU taking into account AIFMD and GDPR.

If you are considering a Singapore VCC as a base for a hedge strategy or multi-asset platform, I invite you to discuss architecture, ROI and the roadmap: pragmatically, step by step, and with accountability for the outcome.

I have been running COREDO across the markets of Europe, Asia and the CIS since 2016 and have seen how **whistleblowing** in fintech has turned from a formality into a pillar for sustainable growth. When early signals from inside reach a competent team, the business wins across the board: compliance quality improves, regulatory risks decrease, and investors see the maturity of corporate governance. COREDO’s practice confirms: a properly configured complaints system in a fintech company speeds up the detection of breaches, improves AML controls and saves remediation budgets.

I regard **whistleblowing** as a business process with a clear architecture, SLA and measurable ROI. It is not only compliance with the EU’s **whistleblowing** requirements, but also an operational protection of informants in financial services, embedded into a compliance framework for fintechs, crypto firms, payment providers and neo-banks. In this article I will compile the strategy, operational practices and lessons from COREDO cases: from channel architecture to performance metrics and scaling across international markets.

Directive (EU) 2019/1937 and standards

Illustration for the section «Directive (EU) 2019/1937 and standards» in the article «Whistleblowing in fintech – complaint system under EU directives»
The European Directive on the protection of whistleblowers (Whistleblower Directive), Directive (EU) 2019/1937, sets minimum standards for companies, including the financial sector. National implementation of the directive in the EU and the risks of non-compliance vary by country, but the direction is clear: reliable internal channels, protection from retaliation, confidentiality and timely feedback to the whistleblower. In financial services there are also industry frameworks: EBA recommendations and guidance on internal channels and risk management, as well as ESMA expectations for the capital markets and fintech companies working with securities and derivatives.

GDPR underpins any processing of complaints. **Confidentiality and GDPR** in complaints mean clear legal bases, data minimisation, pseudonymisation and clear retention periods. In practice this translates into a DPIA for the complaint system, the assignment of roles and responsibilities to the whistleblower officer, and the regulation of interaction with the DPO: the DPO’s job description and cooperation with the DPO should directly take the whistleblowing processing workflow into account.

Channels and deadlines under the EU directive
The directive requires mandatory channels of communication: an internal reporting channel for whistleblowers and the option of an external reporting channel to the regulator (national contact points and competent authorities). Internal reporting rules provide for acknowledgement of receipt of a complaint within seven days and feedback on the results within three months (with a possible extension up to six months in justified circumstances). Such regulated response times under the directive discipline the process and set SLA standards for compliance teams.

National implementation and sanctions
National implementation of the directive in the EU and the risks of non-compliance include regulatory fines and legal risks for breaching the directive. In EU case law there are examples of sanctions for the absence of internal channels, breaches of whistleblower confidentiality or missed deadlines. The financial consequences of non-compliance (fines, reputational risk) often exceed the costs of implementation. In some jurisdictions administrative and criminal consequences are added for ignoring a complaint, especially where possible economic crimes or money laundering are involved.

privacy by design in the GDPR
The impact of the GDPR on the processing of reports is reflected in details: conditions for anonymity and two-way anonymous communication, pseudonymisation and storage of complaint data, encryption and secure storage of records, cross-border transfer of complaint data and the legal bases for this. **Privacy by design** for reporting systems: not a slogan, but concrete measures: end-to-end encryption for **whistleblowing**, multi-factor authentication for reporting portals, protection of the communication channel from DDoS and leaks, as well as evaluating platform providers against SOC/ISO standards and checking their audit trail. At COREDO we usually build a DPIA for the complaint system at the start of a project; this reduces the likelihood of regulatory ‘surprises’.

Architecture of the complaints system in fintech

Illustration for the section 'Architecture of the complaints system in fintech' in the article 'Whistleblowing in fintech – complaints system under EU directives'
The complaints system in a fintech company is not just a ‘mailbox’. It is a set of processes and technologies: whistleblower channels (in-house software vs outsourcing), a secure reporting platform, triage and prioritization procedures, integration with case management systems and interaction with AML/SAR processes. I recommend viewing the architecture as a target operating model with clear interfaces and responsibilities.

Platform selection and security

Choosing a platform for secure reporting determines the resilience of the entire program. At the technology level I require end-to-end encryption for **whistleblowing**, multi-factor authentication, certified crypto libraries, segmented storage and strict access roles. I also look specifically at protection of the communication channel from DDoS and leaks, integrity logs and continuous monitoring. When evaluating platform vendors against SOC/ISO standards I am interested in independent audits (for example, ISO 27001, SOC 2 Type II), the presence of an audit trail, two-way anonymous communication features and GDPR compatibility.

Integration with case management systems, automation of investigations and workflows, as well as incident visualization tools for the board of directors simplify management of the complaint lifecycle. Compatibility of the complaints system with transaction monitoring systems helps speed up verification of signals related to AML, fraud and conflicts of interest.

Scaling for international fintech
Scaling a complaints system for international fintech relies on international jurisdiction and cross-border complaints. Scaling challenges during international expansion are usually related to local data storage and retention requirements, language localization and cultural specifics. Regional particularities in the EU, Asia and the CIS during implementation may require distributed hosting, mechanisms to restrict cross-border transfer of complaint data and local escalation procedures to national competent authorities.

The crypto sector adds nuances: regulation regarding cryptocurrencies and complaints is actively evolving, so compliance and **whistleblowing** in crypto firms must take into account the Travel Rule, risks of KYC circumvention and interaction with exchanges and custodial providers. The link between **whistleblowing** and AML/SAR is particularly strong here.

Integration of the compliance framework
I recommend tying **whistleblowing** to AML processes, KYC/CDD, IT security and HR. SAR vs internal report, the difference and interaction should be clear to every line of defense: an internal report triggers a corporate investigation, while a SAR to the FIU is a regulatory report of suspicious activity. I consider compatibility with transaction monitoring systems and a unified case management ecosystem mandatory: it reduces the time to gather evidence and improves the quality of legal assessment of reports.

Processes from report to resolution

Illustration for the section “Processes from report to resolution” in the article “Whistleblowing in fintech – complaint system under EU directives”
The heart of the program: investigation management after a report and a well-thought-out triage methodology. The solution developed at COREDO combines risk scoring, automatic checks against registers of breaches and the involvement of subject-matter experts. Signal analysis: how to reduce false positives is not only a matter of algorithms, but also of data-source settings, category clarity, and staff training.

Best practices for triage and prioritization

Transparent rules govern triage: triage methods — scoring and prioritization of reports by harm, likelihood, regulatory criticality and management involvement. Machine learning for clustering complaints and NLP for automatic categorization of reports help ease the team’s workload and improve response times. I add KRIs for corporate ethics risk and KPIs and metrics for the complaints program’s effectiveness — for example, the share of valid reports, average time to remediation, repeat incidents and the quality of feedback to the whistleblower.

Investigation management

legal assessment of reports and evidence collection require discipline: documenting investigations and preserving the chain of custody, legal standards for evaluating evidence, version control of artifacts and independent verification. Integration with case management systems and an audit trail ensures consistency and readiness for external review. Outsourcing investigations to an independent provider may be necessary in conflicts of interest or in complex cases where specialized expertise is required.

Escalation and engagement with external authorities

Internal/external escalation procedures set thresholds: when an internal resolution is sufficient and when an external reporting channel to the regulator is required. Interaction with the FIU and national supervisory authorities, as well as transferring data to the FIU and liaising with law enforcement, should follow pre-approved scenarios. The COREDO team helps clients prepare notification templates for regulators and evidence packages for different cases to meet regulated response times and the level of detail expected by competent authorities.

Roles, responsibility and culture

Illustration for the section «Roles, responsibility and culture» in the article «Whistleblowing in fintech – complaints system under EU directives»
The compliance manager and the board of directors’ responsibility – key to maturity. I expect the board to approve a whistleblower policy, establish safeguards against retaliation and receive regular reports on the program’s status. The roles and responsibilities of the whistleblower officer include receiving reports, communicating with the whistleblower, initiating triage, and monitoring deadlines and anonymity.

Policies and instructions
A whistleblower policy for payment providers, compliance and **whistleblowing** in crypto firms, and implementing a **whistleblowing** program in a neo-bank require nuance. For payment organizations the policy should take into account PSD2/EMI risks; for crypto — risks of AML and sanctions circumvention; for neo-banks: a complex third-party matrix and open banking. I typically propose a whistleblower policy template with an annex: directive requirements on communication channels, internal reporting rules, safeguards against retaliation, escalation procedures, confidentiality and GDPR, data storage and retention periods.

Training and change management

Staff training and change management are the key to trust in the system. Training line managers and leadership helps reduce “noise” and improve the quality of the initial assessment. Change management and communication with staff include open Q&A, anonymized case studies, regular reminders about channels and encouragement to report. Building an ethical culture and encouraging reporting increase the number of useful signals, and the impact of corporate culture on report volumes becomes a measurable KPI.

Protection against retaliation and anonymous communication

Safeguards against retaliation include a ban on disciplinary measures against bona fide whistleblowers, oversight of HR decisions, confidential consultations with HR and an independent appeals channel. Whistleblower anonymity and two-way communication are supported through platforms with pseudonyms, one-way disclosure and metadata control. In some jurisdictions anonymous rewards and incentives for whistleblowers are possible, and I will align such practices in advance with local law and regulators’ expectations.

How to calculate ROI

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risk assessment when implementing a complaint system and the ROI of implementing a **whistleblowing**-system interest financiers no less than lawyers. I consider the basic ROI metrics: cost per case (cost per case), time to remediation (time to remediation), reduction in operational losses through early detection of violations and the share of prevented external investigations. Costs and benefits of internal reporting consist of platform licenses, training, investigations and savings on fines, downtime and reputational losses.

Maturity indicators: KPI and KRI
I use a three-level system of indicators:

  • KPI: time to confirmation, time to triage, time to resolution, share of substantiated cases, reporters’ satisfaction with the quality of feedback.
  • KRI for corporate ethics risk: increase in the number of reports in risk areas (without decline in quality), share of severe cases, incident recurrence.
  • Maturity indicators of the whistleblower program: presence of a DPIA, integration with AML/SAR, independence of the appointed officer, regular reports to the board, benchmarking of **whistleblowing** programs by industry.

Economic efficiency model

The program’s economic efficiency calculation model takes into account return on investment (ROI) scenarios: prevention of regulatory fines, reduction of IT process downtime during abuse incidents, and reduction of fraud losses. Scenarios are built on probabilities: baseline (compliance only), advanced (early detection), strategic (systemic integration with transaction monitoring and HR). In COREDO’s experience, the strategic scenario pays off faster, especially for companies with intensive payment flows and international expansion.

Implementation: plan and COREDO cases

The COREDO team has implemented dozens of deployments, from startups to large groups. Implementing **whistleblowing** in a startup vs a large company differs in process depth and governance frameworks, but the stages are similar.

Project implementation plan

  1. Diagnosis and design: maturity assessment, DPIA for the complaints system, compliance gap vs Directive (EU) 2019/1937, EBA/ESMA expectations.
  2. Solution selection: reporting channels: software vs outsourcing, choosing a platform for secure messages, assessment by SOC/ISO, privacy by design.
  3. Integration: case management system and audit trail, compatibility with transaction monitoring systems, integration with HR processes and disciplinary procedures, linkage with conflict of interest policy.
  4. Policies and training: whistleblower policy template, escalation procedures, staff training and change management, communication with personnel.
  5. Testing and launch: testing the complaints channel (penetration tests), DDoS protection checks, incident response and trust recovery plan.
  6. Operations and measurements: KPIs/KRIs, reporting tools for management and the board, audit of the effectiveness of the whistleblower program.

COREDO cases

  • Neo-bank in the EU: implementing a **whistleblowing** program at a neo-bank took 12 weeks. Integration with AML/SAR and transaction monitoring reduced time to triage by 38% and false positives by 22%. National contact points received two external reports with correct notification templates – the regulator accepted the responses without additional requests.
  • Payment provider in Central Europe: a whistleblower policy for payment providers and two-channel escalation helped uncover a scheme to bypass limits. Documenting investigations and preserving the chain of evidence ensured successful cooperation with law enforcement and the FIU. The company avoided a fine, receiving only an order to improve third-party controls.
  • Crypto firm with a hub in Asia: compliance and **whistleblowing** in crypto firms were integrated into Travel Rule processes. Machine learning for complaint clustering and NLP for automatic categorization of messages reduced the compliance line’s workload by 30%. A regulatory review confirmed compliance with the directive and local data protection rules, and the board approved additional budget to scale in the CIS.

Risks of non-compliance during inspections

Preparation for inspections by supervisory authorities is part of the regular operational cycle. Engagement with banking sector regulators, ESMA observers and financial ombudsmen requires clear dossiers, transparent logs and readiness for interviews. corporate governance and **whistleblowing** go hand in hand: stakeholders – boards of directors, investors, the auditor – expect regular and clear reporting.

Audit and reporting on complaints
Audit and reporting on complaints for the regulator are built on standardized datasets: complaint categories, response times, investigation status, and remedial and preventive measures. Reporting tools for management and the board provide a dashboard with trends, risk heatmaps and KPI/KRI details. Data retention policies and timeframes are aligned with GDPR and local regulations; encryption and secure storage of records are verified by an independent audit.

Preparation for inspections: stress tests

I recommend regular stress tests: testing the complaints channel (penetration tests), checking DDoS controls, simulating a mass influx of reports and an analytical review of bottlenecks. Preparation for investigating complex economic crimes includes forensic playbooks, role assignments, access to external experts and readiness for public communications. We work through the ethical and reputational aspects of public investigations in advance so the company can confidently maintain its stance when interacting with the media and investors.

How COREDO Helps

Our experience at COREDO has shown: there is no single “box”, context matters: licenses, jurisdictions, group structure, digital maturity. The COREDO team designs a compliance framework for fintech taking into account Directive (EU) 2019/1937, GDPR and industry guidance, selects and implements platforms, configures two-way anonymous communication, integrates AML/SAR and case management, trains staff and establishes metrics. We treat culture with care: without trust in the channels and protection against reprisals, the system will not work.

COREDO helps conduct a DPIA, build escalation procedures, organize external reporting of violations in the financial sector, prepare notification templates, and, if necessary, outsource investigations to an independent provider. For groups with an international presence we configure cross-border transfer of complaint data in line with local rules, and manage the vendor chain for complaint platforms. As a result, the company gains not just compliance, but a working mechanism for the early detection and remediation of risks.

Conclusions

**Whistleblowing** – is not a ‘regulatory burden’, but a reliable tool for managing risks and reputation. When a fintech has internal and external channel architecture, privacy by GDPR standard, well-designed triage and investigations, as well as board support and effective communication, the program begins to deliver measurable benefits. You will see clear KPIs, a clear KRI profile, a comprehensible ROI and a real reduction in operational losses.

If you are preparing to launch or upgrade a program, start with a diagnosis: assess channels, roles, integrations and metrics. The COREDO team will gladly share methodologies, case studies and templates, and will also help adapt the solution for the EU, Asia and the CIS. With correct implementation, **whistleblowing** strengthens corporate ethics, accelerates the AML framework and increases business resilience; it is precisely the foundation on which international growth is built.

Since 2016 I have been leading COREDO as a company that turns the complexity of international regulation into a clear system of manageable solutions. During this time we have registered dozens of legal entities in the EU, the Czech Republic, Slovakia, Cyprus and Estonia, supported licensing in the United Kingdom, Singapore and Dubai, and built compliance for clients at the level regulators and banks expect. I am convinced: the foundation of sustainable international growth is a risk-oriented approach (RBA, risk-based approach), embedded in registration, licensing and day-to-day operational processes.

In this article I have collected our practical experience of implementing RBA in financial organisations, fintechs, crypto companies and international holdings. My focus: to show how to turn AML requirements/CFT, AML compliance checks and corporate RBA compliance into a source of managerial advantage, TCO reduction and faster time-to-market, rather than into a “cost of compliance” with no return. The text is aimed at entrepreneurs and directors who need to make decisions quickly, systematically and transparently.

Risk-based approach — a pillar

Illustration for the section “Risk-based approach — a pillar” in the article “Risk-based approach RBA – risk matrix for audit”

RBA is not a “tick-the-box” exercise; it is about a reasoned choice. When we prepare a client to obtain a license for payment services in the EU, to register a crypto service in Estonia, or to gain approval from a regulator in Singapore, I start by defining the risk appetite at the board level. This anchors managerial responsibility, sets the framework for the risk matrix, and determines the depth of KYC/KYB, CDD and EDD.
Comparing RBA with a checklist approach always favors the former. A checklist creates blind spots and disproportionate effort, whereas the RBA methodology allocates resources where the inherent risk is highest and where it needs to be reduced to an acceptable residual risk. In COREDO’s practice this reduced delays in product launches, lowered the level of false positives in monitoring, and improved TAT and closure rate metrics for investigations.

Regulatory expectations for RBA in the EU, the AMLD5 and AMLD6 requirements, and FATF recommendations explicitly state: you are obliged to know the risk profile of clients, products, channels and geographies. In response we design the company’s risk management based on ISO 31000 and the COSO internal control framework, combining corporate information governance (GRC) with a clear decision-making matrix and an escalation model. This makes dialogue with auditors and banks predictable and substantive.

RBA Framework: from strategy to processes

Illustration for the section «RBA Framework: from strategy to processes» in the article «Risk-based approach RBA – risk matrix for audit»

When I say “framework”, I mean a bundle of strategic documents, processes and measurable metrics. At COREDO we start with RBA documentation and compliance policy, then record the risk register (risk register), process mapping (process mapping) and control points, and only after that do we move to automation.

This order is important, because automating the risk matrix without clear criteria for classifying customers by risk leads to an avalanche of exceptions and manual work. The correct sequence is design first, then control assessment and design testing, and only then launching into production with compliance KPIs and key risk indicators (KRI). The COREDO team implemented such a scheme in projects from the Czech Republic to Dubai, and as a result the risk analysis for audit became transparent, and the review and updating of the risk matrix regular and meaningful.

RBA methodology and the risk matrix

The RBA methodology starts with a taxonomy of risks: customers, products/services, distribution channels, geographies, transactions and counterparties. For each category we assess probability and impact scales (likelihood & impact), assign score weights and obtain a heatmap (risk map), where the high-risk area is immediately visible to the board. This is how we develop a risk matrix for audit that is understandable to the business, internal audit, and the external inspector.

The assessment of inherent risk and residual risk is carried out in two stages. First we calculate the risk without controls, then we add the control environment and assess its controls’ effectiveness and compliance KPIs to see the reduction to the residual level. This assessment includes sanctions screening and filtering against EU and OFAC lists, PEP risk, UBO identification and reputational indicators, as well as customer risk scoring models that take into account behavioral and transactional indicators.
To show the “transparent mechanics”, I often give the example of a risk matrix for AML audit. Take customer risk: base scoring by country of registration, industry, UBO status, PEP status and product type; then modifiers, onboarding channels, remote KYC/KYB, presence of complex corporate structures. The heatmap immediately highlights where an Enhanced Due Diligence (EDD) procedure is needed, and where a standard CDD — a comprehensive customer check — is sufficient. This is not theory: COREDO’s practice confirms that such decomposition simplifies RBA when conducting internal audits and speeds up coordination with the compliance officer.

Integration of RBA with KYC/CDD and sanctions

The RBA methodology is meaningless without being embedded into operational processes. We design the integration of RBA with KYC and CDD processes so that a customer’s risk assessment is updated on every material event: change of UBO, expansion of geography, anomalous transactions. For high-risk segments, EDD procedures are triggered automatically, additional documents are collected, sanctions screening against extended lists is activated, and suspicious activity analysis (SAR) is conducted.

Transaction risk assessment and monitoring are built on rule engines and machine learning for anomaly detection. In crypto companies we integrate blockchain analytics and crypto screening tools; in payment organizations: transaction monitoring in real time, configuration of thresholds and trigger rules, as well as management of false positives. Here data quality management and lineage are critical: without reliable sources and auditing (audit trail), the evidential base for the regulator collapses.

Finally, data privacy and GDPR compliance: part of the architecture, not an afterthought. In the retention policy we define archiving of evidence and data storage requirements, set retention periods for cases and structure the case lifecycle (case management). This reduces the burden on the first line and increases readiness for inspections and independent review.

Choosing a Jurisdiction for RBA

Illustration for the section 'Choosing a Jurisdiction for RBA' in the article 'Risk-based approach RBA – risk matrix for audit'
The solution developed at COREDO always begins with mapping regulatory expectations and relevant licenses to the client’s business model. In the EU – the requirements of AMLD5/AMLD6, in the United Kingdom: FCA rules, in Estonia: VASP specifics, in Cyprus – the regime for payment and investment firms, in Singapore: MAS, and in Dubai, DFSA/DIFC or VARA for the crypto segment. By aligning them with the client’s risk appetite, we help choose the jurisdiction, the degree of centralization and payment routes.

RBA for international companies in Europe and Asia ensures a “soft landing” when opening accounts and establishing correspondent relationships. Banks expect to see corporate RBA compliance, a process map, KRI metrics and the presence of a risk mitigation plan for key scenarios. At the start of company registration we already form the basis for AML compliance checks so there is no need to go back to “restructuring” at the end of licensing.
The impact of RBA on business processes appears immediately after launch. Standardized KYC/KYB, unified checklists for legal entities, decision matrices and an escalation model increase onboarding speed, while transaction risk assessment reduces operational incidents. As a result, you do not “adapt to the regulator”, but build an efficient and economical process that meets inspection expectations.

Implementing RBA in a Financial Organization

My basic roadmap for clients looks like this:

  • Strategy: we determine the risk appetite, establish a risk management committee and record the responsibilities of the board and the compliance director under RBA.
  • Processes: we conduct process modelling, define control points, align the roles of the lines of defence and prepare a risk register.
  • Design of controls: we describe client risk classification criteria, CDD/EDD procedures, sanctions screening and transaction monitoring, and configure the risk matrix and heatmap.
  • Technologies: we select the AML/CFT platform architecture, assess the scalability of technical solutions, integration with ERP/CRM and banking systems, and configure thresholds and rules.
  • Measurement: we define key risk indicators (KRI), metrics for the ROI of RBA implementation, investigation effectiveness metrics, as well as ROI assessment and the total cost of ownership (TCO) of RBA.
  • Verification: we plan internal audit and independent review procedures, sampling methodologies for audit (statistical sampling), and scenario analysis and stress testing of risks.
  • Training: we initiate change management and staff training, including for the first line and investigative analysts.
At each step I ask the team to check the cohesion of components: whether there is a gap between policies and case management, how complete logging and audit trails are, and whether decision matrices are correctly defined. The outcome is not a document for the sake of a document, but a living system.

Scaling RBA in a holding company

In transnational structures, the choice between a centralized and decentralized compliance model is not only a question of organizational structure, but also of the capital efficiency of risk-mitigation measures. In one project the COREDO team built a central core of rules and scoring models for several licensable entities in Europe and Asia, preserving local modifiers for the regulatory requirements. This simplified reporting, ensured comparability of KRIs and allowed centralized sanctions screening and third-party and vendor management.
When scaling, risk visualization and BI tools are important so that the board can see a heatmap for each country and product. Case lifecycle, case management and evidence archiving are unified, and the process map and escalation matrix are standardized. Such a setup facilitates interaction with external regulators and inspections and reduces audit costs by reusing the evidentiary base.

COREDO Case Studies: crypto licenses and institutions

Illustration for the section «COREDO Case Studies: crypto licenses and institutions» in the article «Risk‑based RBA approach – risk matrix for audit»

One notable example: launching a VASP in Estonia. The client came with an ambitious roadmap for token issuance and a wallet service; our experience at COREDO showed the need for enhanced sanctions control and the implementation of blockchain analytics tools. We developed client risk scoring models and transaction risk assessments, configured trigger rules for high-risk flows, and reduced the false-positive rate by 38% in the first three months without losing sensitivity to suspicious operations.
Another project, Licensing of a payment institution in Cyprus with SEPA connectivity and card issuance. The solution developed at COREDO included building a risk matrix, configuring a rule engine, integration with core banking and ERP, as well as CDD/EDD chains for corporate clients with multi-layered UBO structures. As part of the analysis of the impact on EBITDA and operational risk, we forecasted cost reductions through automation and optimization of the investigation process, and then confirmed the savings in real KPIs.
In Singapore we supported a client in obtaining Major Payment Institution status for an international payment gateway. RBA and sanctions control were combined with anti-fraud mechanisms and integration of AML monitoring with card fraud detection systems. The COREDO team carried out scenario analysis and stress testing of risks by geography, correctly set the risk appetite taking into account aggressive growth, and also worked out interactions with correspondent banks for cross-border payments.
Finally, a holding structure in the Czech Republic and Slovakia required scaling RBA across several operating subsidiaries with different risk profiles. We implemented a centralized heatmap, standardized client classification, configured the RBA procedure for internal audits, and prepared a risk register for the external auditor. As a result of the inspection, the client had no significant findings, and the board noted increased transparency of decisions and faster escalation of complex cases.

What is needed for RBA to work daily?

Illustration for the section «What is needed for RBA to work daily» in the article «Risk-based approach RBA – risk matrix for audit»

The architecture of AML/CFT platforms should be modular. I look at how easy it is to connect sanctions lists, how the rule logic is organized, whether model training and their validation are available, and how the issue of data quality management and lineage is addressed. I separately check how logging and audit trails are implemented, because legal requirements for reporting and the evidential basis are becoming more stringent.

Integration with ERP/CRM and banking systems is a critically important element. Without complete data, scoring models “go blind”, and case management loses context. We often implement a centralized hub for event enrichment, configuring thresholds and triggering rules in one place, and broadcasting configuration to subsidiary entities to maintain metric comparability and manage changes.

We pay special attention to privacy and GDPR requirements, including restrictions on data transfers between jurisdictions. Having a clear scheme for archiving evidence and storing data with understandable SLAs for data extraction reduces risks in regulator requests and facilitates independent review. When this “hygiene” is in place, inspections run smoother and faster.

Launch RBA: a guide for the director

First step: establish the board’s accountability and appoint a compliance director with veto power over risky launches. The risk management committee should approve the risk appetite, align the KRI and KPI metrics, and define a process map with control points. This turns RBA from an “important topic” into a management routine.

Second step: develop a risk matrix, build a heatmap, and describe the criteria for classifying clients by risk.

At the same time a risk mitigation action plan is prepared here, including sanctions screening, EDD for PEPs and complex structures, as well as assessment of residual risk (residual risk) and its monitoring. At this stage it is important to define ROI metrics for RBA implementation and target indicators for reducing TCO.

Third step – choose a technological solution and assess scalability. Evaluate the scalability of technical solutions, integration with current systems, configuration of rules and thresholds, and ensure change management and staff training.

Finish by launching internal audit procedures, planning and validating test samples, and regular review and updating of the risk matrix every 6–12 months.

COREDO: from diagnostics to operations

My collaboration model is transparent: we start with a diagnostic session where we align the business model, regulatory objectives and risk appetite. Then the COREDO team conducts a gap assessment against the requirements of the chosen jurisdiction and FATF/AMLD standards, creates a process map and a risk register, and after approval designs the target control design and solution architecture.
Next we build AML compliance checks, set up scoring models, sanctions screening, transaction monitoring and case management, and also document policies and procedures. COREDO’s practice confirms that the combination “processes + technology + metrics” delivers a sustainable result, not just passing an audit. In the final stage we prepare the client’s team for independent operation and provide support for interaction with external regulators and inspections.

In projects for company registration and licensing in the Czech Republic, Slovakia, Cyprus, Estonia, the United Kingdom, Singapore and Dubai we take into account local specifics and supervisory expectations. This saves time on approvals, speeds up account openings and reduces the cost of compliance ownership thanks to the right initial architecture.

Frequently Asked Questions from Directors

How to measure the return on RBA? I use two groups of metrics: financial (ROI assessment and impact on EBITDA through reduced fines and optimization of operating costs) and operational (false-positive rate, TAT per case, investigation closure rate, KRIs by client segments). Additionally, we calculate the total cost of ownership (TCO) of RBA and the capital efficiency of risk-reduction measures.
How to differentiate inherent and residual risk in everyday practice? We assess the risk profile separately without considering controls, and then after their application, and use alert statistics and the results of control design and effectiveness tests for calibration. internal audit verifies the correctness of the methodology by applying sampling methodologies for the audit and independent validation.
How to align AML and anti-fraud? These domains overlap at the level of transaction scenarios and data sources, but the tasks differ. At COREDO we synchronize rules, separate escalation, and build a shared process map and audit trail so investigations don’t compete for resources and don’t lose context. This approach reduces analysts’ workload and improves reporting quality.
What is important in sanctions screening? In addition to updating EU and OFAC lists, it is worth setting clear fuzzy-matching policies, escalation thresholds and alert-review procedures. Consider correspondent relationships and the risk of cross-border payments, as well as company structuring and analysis of the counterparty chain and ultimate beneficial owners to reduce circumvention schemes.

Conclusions

RBA is not just a buzzword from regulatory requirements, but a management tool that speeds up registration and licensing, reduces operational risks and opens a dialogue with banks and regulatory inspections in the language of facts. I see this every time the COREDO team implements the RBA methodology, builds a risk matrix, integrates KYC/KYB, CDD/EDD, sanctions and transaction monitoring and brings the client to a new level of compliance maturity.
If you are planning to register a legal entity in the EU, the Czech Republic, Slovakia, Cyprus, Estonia, the United Kingdom, Singapore or Dubai, aiming for obtaining financial licenses or want to strengthen AML and corporate compliance: start with a clear definition of risk appetite and a risk map. Next – process discipline, the right architecture and measurable metrics that prove the value of each step.
COREDO was created exactly for this kind of systematic work: without loud promises, with thorough attention to detail and responsibility at every stage. I am ready to discuss your case and show how the risk-oriented approach will turn compliance from a cost center into a pillar of international business growth.

Since 2016 I have been heading COREDO and am responsible for ensuring that entrepreneurs from Europe, Asia and the CIS launch and scale businesses in international jurisdictions quickly, transparently and with properly configured compliance. During this time the COREDO team has carried out hundreds of projects: from company registrations in the EU, the Czech Republic, Slovakia, Cyprus and Estonia to licensing in the United Kingdom, Singapore and Dubai. I see the main task as bringing together legal architecture, licensing and the AML/sanctions framework into a single operational model that withstands regulator scrutiny and does not stifle operational efficiency.

Today I will offer you a practical guide to building sanctions screening and anti-sanctions compliance that genuinely reduces false positives, saves budget and maintains control over risks. At the same time I will cover the strategy for registration and licensing, because sanctions screening is not a separate module but a critically important part of your business architecture.

Registration abroad: sanctions and AML

Illustration for the section «Registration abroad: sanctions and AML» in the article «Sanctions screening – how to avoid false positives»

When we design a group structure in the EU, the United Kingdom, Singapore or Dubai, I immediately build AML and sanctions requirements into the founding documents and processes. The right choice of jurisdiction for a specific business model reduces the burden on sanctions monitoring thanks to quality registers, predictable regulators and clear KYC/KYB practice. Our experience at COREDO has shown: if at the incorporation stage you take into account access to corporate registries, rules on beneficial owners (UBO) and local expectations for a risk-based approach (risk-based approach, RBA), the costs of subsequent sanctions screening and KYC fall dramatically.

In the Czech Republic and Slovakia we often use local registries for initial client validation (KYB), and in Estonia the developed digital infrastructure for integrations. In the United Kingdom the UK Office of Financial Sanctions Implementation (OFSI) and its guidance on sanctions control play a significant role, while in Singapore the focus is on process accuracy and the regulator’s expected maturity of compliance. In Dubai it is convenient to assemble international holding structures if you plan from the outset how to synchronize sanctions screening in payment processes and real-time vs batch checking for different customer segments.

Crypto and Payments Licensing

Illustration for the section 'Crypto and payments licensing' in the article 'Sanctions screening – how to avoid false positives'

In licensing financial services I always link regulatory expectations with concrete technical solutions. Payment organizations, forex providers and crypto services are required not only to carry out KYC/KYB and PEP and sanctions monitoring, but also to demonstrate the manageability of the process: sanctions screening must be reproducible, explainable and independent of the individual analyst. COREDO’s practice confirms: successfully obtaining a license is accelerated by a clear demonstration of sanctions control systems, configured matching thresholds, procedures for human verification of alerts and a transparent audit trail.

When preparing for licenses for payment companies in the EU and the UK we include watchlist management, whitelist and exclusion policies, as well as screening modes: batch processing vs real-time screening. For crypto organizations we add adverse media screening and graph analysis to reduce false positives when checking addresses and links. In Singapore and Dubai on-premise solutions and security requirements are important, especially when you store sensitive personal data and beneficiary information.

Sanctions screening as a system

Illustration for the section «Sanctions screening as a system» in the article «Sanctions screening – how to avoid false positive matches»

I see sanctions screening as a four-layer pipeline: data, matching algorithms, threshold/scoring policy and operational workflow. If each layer has data quality controls, an audit trail and demonstrable decision-making, you both reduce false positive matches and keep the risk of false negatives manageable.

Data quality and watchlist management

The foundation is up-to-date, clean sanctions lists: OFAC, EU, UN and United Kingdom. I insist on watchlist consolidation and deduplication of lists, a clear list refresh cadence and data quality controls: completeness, accuracy, freshness. When the COREDO team implements sanctions list filtering, we remove duplicates, canonicalize names (normalisation), align Unicode normalization (NFC/NFD) and standardize transliteration rules (ISO 9, BGN/PCGN). This reduces false sanctions hits long before fuzzy matching algorithms kick in.

For corporate clients I recommend building a golden record in an MDM system and applying entity resolution/record linkage to merge disparate records. Integrating company registries and beneficial ownership data (beneficial ownership, UBO identification) improves KYC/KYB accuracy and reduces uncertainty in sanctions monitoring. Such data quality management and data profiling is the first lever to reduce false positives.

Precise name matching without overreach

Algorithms determine which signals you receive. I usually start with fuzzy matching using Levenshtein distance, the Jaro–Winkler algorithm, n-grams and tokenization. For phonetic robustness we use Soundex and Metaphone, and for multiscript names — multiscript matching (Cyrillic Latin Arabic Chinese) with handling of diacritics and apostrophes. Tuning the name matching model for Asian and European languages is critical: Chinese and Arabic names, as well as Latinization of Slavic surnames, cause a spike in alerts without proper normalization.

In COREDO projects we combine deterministic matching for obvious cases and probabilistic matching for borderline situations. When Entity Resolution is required for corporate clients, we add a graph component: links between legal entities, directors and addresses help distinguish true matches from false ones. Visualizing connections for sanctions risk review speeds up analyst work and provides explainable AI for decision-making.

Threshold policy and FP/FN calibration

Reducing false positives is not just “raising the match threshold.” I use score management and threshold policy, threshold calibration and A/B testing of thresholds and matching models. Metrics — false positive rate (FPR), precision and recall, F1-score and ROC AUC — show the trade-off between FP and FN and help select a point that matches the risk appetite and regulator expectations.

Regulators usually support a risk-based approach and do not expect zero FP. It is important to document the methodology, trade-offs and justification for chosen thresholds, and to perform a compliance audit of sanctions control. Our solution, developed at COREDO, includes regular cost-benefit analysis: we calculate cost per alert, analyst throughput, MTTR and operational efficiency and compare this to the assessed risk of a false negative (FN). This approach demonstrates ROI and the acceptability of changes in the eyes of regulators.

Processing flows: real-time or batch

Each business process dictates its mode. For incoming payments, real-time sanctions screening with API integration of the screening engine into processes is appropriate. For periodic customer base reviews: batch processing (batch checks) with scheduling and SLA. I build human-in-the-loop workflows and SLAs at every stage: initial automated check, alert triage and prioritization, human verification of alerts and case management for alert investigations.

Integrating sanctions screening into payment flows, ERP/CRM systems and AML/CFT platforms requires an audit trail, data lineage and provenance so every decision is demonstrable. At COREDO we implement explainable AI and transparency of decisions: the analyst sees the reasons for the match, the contribution of each token or rule, and the manager sees aggregated metrics and team workload. This reduces operational risk and raises compliance maturity.

False positives: rules, ML, graphs

I start with basic settings: reducing false positives by tuning match thresholds, whitelists and exceptions with clear exception management and documentation of whitelists. Then I add filters by country, birth dates, entity types and context, as well as watchlist management with targeted filtering of entities known as “false matches”.

Next we refine matching rules using ML. Supervised learning to reduce FP is trained on labeled cases (training data labeling), while unsupervised clustering highlights hidden patterns of false alerts. Graph analysis to reduce false positives and network analysis help remove noise from namesakes and identically named companies. In several COREDO projects we introduced greylisting for contentious cases with additional context and “deferred” review, reducing SLA load without loss of quality.

Names, scripts and registries in Europe and Asia

Multilingualism is the main “alert generator.” In Asia we pay special attention to transliteration and name spelling variants, use transliteration tables (ISO 9, BGN/PCGN), configure Unicode normalization and rules for handling diacritics. For Arabic names we apply tokenization, n-grams and canonicalization and normalisation, and for Chinese names — romanization schemes and alternative forms.

In Europe the focus shifts to registry integration and record linkage. Entity Resolution for corporate clients and deduplication in master data remove “echoes” of records. For trade finance and commodity trading we add screening of counterparties, vessels and ports, and for correspondent banking and cross-border screening, praa focus on jurisdiction‑aware filtering. At the same time, we always take into account the legal aspects of storing and transmitting personal data, the requirements for on‑premise solutions and legal hold when cooperating with law enforcement agencies.

SaaS or on‑prem: scale and security

At the architecture stage I assess how ready the business is for SaaS sanctions‑screening providers or whether it needs an on‑premise installation. Key factors: security, latency requirements, multi‑jurisdictional operations and local data laws. For high loads we use Bloom filter to speed up searches in large lists and design CI/CD practices for ML models of sanctions screening to release changes safely and predictably.

We build scaling of sanctions screening to support company growth in Europe and Asia through micro‑services, API gateways and centralized watchlist management. Synchronization of sanctions lists and update frequency become policy‑manageable, and SLA‑oriented tuning keeps MTTR and cost per alert within target bounds. The COREDO team helps run a cost-benefit analysis of the implementation and calculate ROI: how much reducing FP saves, how analyst throughput grows and where the risk balance remains acceptable.

Demonstrating compliance to regulators

Sanctions screening without an audit trail does not pass review. I require a continuous audit trail and provable actions, explainability tools for matching models and a clear separation of roles: analysts, compliance managers, the CTO and data owners. Within the FATF recommendations and regulators’ expectations we organize regular audits of sanctions‑screening effectiveness, A/B testing of models, threshold updates and analyst training.

For transparency we introduce data lineage, provenance and evidence packages for each decision. Case management and workflow automation create reproducibility, and human‑in‑the‑loop processes and SLAs provide risk manageability. When a client receives a request from a regulator or counterparty, the prepared package with precision/recall metrics, F1‑score, ROC AUC and a description of the risk-based approach provides a convincing response without emergency rework.

COREDO case studies: reducing false positives and screening

Illustration for the section «COREDO case studies: reducing false positives and screening» in the article «Sanctions screening – how to avoid false positive triggers»

In Estonia we worked with a payments company that faced a flood of false sanctions hits. The COREDO team profiled the data, normalized names and transliteration, introduced watchlist consolidation and retuned fuzzy scoring. We implemented whitelists under strict exception governance and trained a supervised model on labeled alerts. The result, real-world cases reducing the number of alerts by 70% while maintaining recall on critical risks. The regulator accepted our documentation on trade‑offs and methodology with no additional requirements.

In Cyprus a forex provider was preparing for licensing and needed to build PEP and sanctions monitoring taking into account multiscript customer names from Asia. The solution developed at COREDO included multiscript matching, Jaro–Winkler and n‑grams, as well as link visualization for checking sanctions risks by UBO. We added adverse media screening and rules for alert triage with SLA metrics. The license was obtained, and the operations team meets target KPIs: cost per alert decreased quarterly, MTTR within 2–4 hours for priority alerts.
In Dubai an international holding structure was building anti‑sanctions compliance at the group level with branches in the UK and Singapore. Our experience at COREDO showed that a unified threshold policy and harmonized watchlist management provide consistency, while regional overlays account for local data laws. We set up a batch review of the database every 24 hours and real‑time screening on payments, introduced A/B testing of thresholds and regularly reported on ROC AUC and F1‑score to the risk committee. The system passed external audit and scaled without an increase in FP.

How to implement sanctions screening

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  • Assess compliance maturity. Apply a compliance maturity model and identify gaps in data, algorithms, thresholds, and workflow.
  • Organize data. Configure watchlist consolidation, deduplication, unicode normalization, transliteration, and a golden record in MDM.
  • Design algorithms. Combine deterministic matching, fuzzy matching (Levenshtein, Jaro–Winkler), phonetics, and a multiscript approach.
  • Define a threshold policy. Conduct threshold calibration, A/B testing, establish a risk-based approach, and document FP/FN trade-offs.
  • Build the workflow. Include human-in-the-loop, case management, alert triage, SLA, and audit trail. Integrate ERP/CRM and payment processes via API.
  • Enable ML and graph. Implement supervised learning to reduce FP, unsupervised clustering for anomalies, and graph analysis of relationships.
  • Reinforce controls and training. Organize regular effectiveness audits, analyst training, labeling of training data, and CI/CD for rules and models.

Answers to questions: economics and ROI

How to estimate the ROI of implementing a new sanctions screening system? Consider cost per alert, analyst throughput, MTTR, FPR and reduction in investigation time. Add the cost of FN risk, fines and lost revenue due to payment delays. ROI: the difference between total savings and investments in licensing, integration and maintenance.
Which KPIs to use to measure the effectiveness of false positive reduction? FPR, precision, recall, F1-score and the share of alerts closed as FP, plus operational KPIs: MTTR, backlog, share of auto-clear. Don’t forget data quality: completeness, accuracy, freshness.
How permissible is it to raise the match threshold from a regulator’s perspective? Within an RBA it is permissible if you document calibration, compromise metrics (precision/recall) and FN control. OFSI and FATF expect demonstrability and auditability, not a dogmatic “zero tolerance for FP”.
Which methodologies minimize operational risks when reducing FP? A/B testing of thresholds, multistage triage, greylisting, human-in-the-loop for borderline cases and explainable AI to justify decisions.
How to scale sanctions screening for growth in Europe and Asia? Centralize watchlist management, use API gateways, Bloom filter for lookups, separate real-time and batch, and apply on-premise in jurisdictions with strict data requirements.
What data and registries are needed for accurate matching of corporate clients? Company registries for the EU/UK/Asia, UBO information, addresses, directors, historical names. Implement record linkage, deduplication and a golden record.
How to choose between SaaS and on-premise? Look at regulatory constraints on data, latency requirements and security. SaaS gets you started faster, on-prem gives control and customization. We often design a hybrid.
How to organize human-in-the-loop and transparent audit? Introduce SLAs, roles and playbooks, case management with a full audit trail, data lineage and explainability reports for each decision.
How to train analysts and automate triage? Standardize training data annotation, deploy supervised models for auto-prioritization, set MTTR targets and hold periodic retrospectives on decision quality.
Which metrics show the trade-off between FP and FN? Use precision/recall, F1-score and ROC AUC, and also track FN risk estimates by customer/transaction types.

Risk management: FN under control

Reducing FP must not be done at the cost of an explosive rise in false negatives. I set threshold policies with a “safety” level of review for high‑risk segments and recommend regular retrospectives on closed cases. Exception management goes through the compliance committee, and any whitelisting and greylisting are documented and reviewed at predefined intervals. This regime keeps FN under control and shows the regulator a mature, risk‑oriented system.

We also use alerting channels and integration with AML/CFT systems so that sanctions alerts do not “get stuck” and move into investigation following a clear workflow. If required, we engage cooperation with law enforcement and implement legal hold, preserving the evidential base and transparency of actions.

COREDO: diagnostics and project support

I build the project in three steps. First, diagnostics and audit: maturity assessment, data profiling, rules inventory, measurement of FPR/precision/recall, evaluation of infrastructure and security. Then architecture and implementation: data and watchlists, algorithms and threshold policy, integrations, case management, explainability, analyst training and CI/CD deployment. And finally – support and development: regular calibration, A/B tests, expansion of jurisdictions, team training and preparation for inspections.

The COREDO team stays focused on the end result: reducing false positives, decision transparency and audit readiness. We handle company registration and licensing in the EU, the Czech Republic, Slovakia, Cyprus and Estonia, support scaling in the UK, Singapore and Dubai, and combine legal, operational and technological competencies into a single workflow.

Conclusions

Sanctions screening and anti-sanctions compliance have stopped being a “checkbox” for regulators. It is a managed system with clear data, transparent algorithms, calibrated thresholds and a disciplined workflow that protects the business and accelerates it. When sanctions control is embedded in a company’s architecture, from registration and licensing to AML-processes and payment integrations – you gain predictability, optimal KPIs and confidence in international scaling.

At COREDO I am responsible for ensuring that every decision is understandable, verifiable and economically justified. If you are planning to expand to Europe or Asia, preparing for a licence or want to put your AML and sanctions in order, let’s discuss a roadmap. I will propose concrete steps, provide metrics, assemble a team for your model and bring the project to operational resilience – so that the sanctions control system works in your favor every day.

I often start a conversation with entrepreneurs with a simple question: *what is your goal in choosing a new jurisdiction for an investment business*? The answer almost always comes down to a combination of three factors: regulatory predictability, access to capital, and operational efficiency. In recent years Astana International Financial Centre (AIFC) has become one of the few hubs where the balance of these factors works to the benefit of both international and regional players. During this time the COREDO team has carried out dozens of projects for legal entity registration, obtaining investment licenses, building an AML function, and launching funds within the AIFC.

In this article I organize COREDO’s practice: how the registration of a legal entity in the AIFC is carried out, which licenses are available, what the capital and substance requirements look like, what is important to know about the AIFC’s AML and KYC requirements, and how to strategically assess the ROI of operating through the AIFC. The text is aimed at entrepreneurs and finance directors who value concreteness and clear steps without unnecessary theory. My goal – that you leave the article with a clear plan and an understanding of whether an AIFC license suits your business model.

AIFC legal framework: the role of AFSA

Illustration for the section 'AIFC legal framework: the role of AFSA' in the article 'Investment licenses in Kazakhstan AIFC'
The AIFC uses a separate “AIFC legal framework” based on common law principles, with its own court, the AIFC Court, and an independent regulator, the Astana Financial Services Authority (AFSA). This provides predictability and dispute-resolution principles close to the English tradition, which is important for high-stakes and cross-border transactions. In my practice, this often reduces legal frictions between investors and managers, especially when structures from the EU and the United Kingdom are involved.

AFSA regulates activities by means of a Rulebook – a detailed code of rules similar in logic to European and Middle Eastern standards. In spirit, the requirements are close to MiFID II: investor protection, management of conflicts of interest, risk disclosure and adequate capital requirements and management systems. At the same time, the AIFC allows reasonable proportionality: early-stage projects and niche strategies have flexibility provided there is an evidential basis of robust risk management.

COREDO’s practice confirms that when preparing for licensing in the AIFC a “European” approach helps: product regulations, clear client categorization, documented suitability/appropriateness and transparent fees. At the same time AFSA expects all of this to be implemented into the actual operational environment – a single paper policy is not enough.

Which licenses are in the AIFC?

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Investment licenses in Kazakhstan through the AIFC cover a wide range of activities, and correctly mapping a business model to the permitted types of activity saves months at the approval stage. Within the AIFC, available in particular are AIFC broker license (broker/dealer), the AIFC asset manager license (portfolio manager/asset manager), the investment adviser license, as well as the AIFC depository and custodian license. For fund activity, collective investment schemes (CIS) are provided, including closed structures for private equity and an investment fund license in the AIFC.

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Over the past two years we have observed strong demand for the AIFC private equity license and the AIFC venture fund license. Such structures are convenient for cross-border capital raising, and for working with investors familiar with common law. A separate vector is the AIFC license for digital asset operations: under it custody solutions, crypto exchanges and tokenization services develop while complying with requirements for storage technologies and cybersecurity.

For non-residents, the AIFC provides an investment license, and this is a real tool for accessing regional markets while minimizing legal conflicts. Our experience at COREDO has shown that a well-designed combination of an SPV in the AIFC and an operational core in another jurisdiction helps to flexibly allocate functions while maintaining compliance with AFSA regulatory standards.

Capital, substance and fit and proper

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Capital requirements for an AIFC license depend on the type of activity and the risk profile. By the typical ranges we encounter in projects, broker-dealer licenses sit at the top of the scale, while advisory and non-custodial management are lower. Capital adequacy for asset managers includes a fixed base amount and add-ons for operational risk and assets under management. I always recommend planning a “buffer” above the minimum level to smooth seasonal fluctuations and growth-related costs.

Economic presence (substance) at the AIFC: more than a nameplate on the door. AFSA expects a real team: at least one executive director resident in the AIFC, a competent head of compliance/AML, and, where appropriate, risk management and internal audit functions. In COREDO projects we include a responsibility matrix and job descriptions at the submission stage to pass the fit and proper checks for AIFC directors and senior management without delays.

Fit and proper test for directors and senior managers at the AIFC covers experience, qualifications, reputation and compliance history. Background checks include certificates of no criminal record, verification of education, previous roles and references. I honestly warn clients: it’s better to identify and work through “grey areas” in advance than to explain them to AFSA at a late stage.

AML and KYC in the AIFC: technologies and control

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AML and KYC requirements of the AIFC are based on the recommendations of FATF and integrate a risk-based approach. In practice this means an individual AML risk assessment for investment firms, client segmentation by geography and profile, as well as documentation of sources of funds. The solution developed at COREDO typically includes a risk matrix, playbooks for onboarding and instructions on procedures for detecting suspicious transactions (STR).

Modern KYC/eKYC technologies for the AIFC simplify remote onboarding, but AFSA pays attention to the quality of PEP and sanctions screening and to periodic review. We implement a transaction monitoring and AML screening system taking into account the business model profile, including scenario settings, trigger thresholds and an escalation procedure. A separate register of beneficial owners and beneficial owner verification in the AIFC are developed to resolve questions about ownership structures before submission.

A compliance policy for an investment firm in the AIFC should describe procedures for managing conflicts of interest, product acceptability, as well as whistleblowing channels. At AFSA audits, not only documents are valued but also implementation artifacts: monitoring logs, committee reports, and AML training for staff. COREDO’s practice confirms that a mature AML framework speeds up both Licensing and subsequent reviews.

Timelines and steps for registering a legal entity in the AIFC

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The registration of a legal entity in the AIFC starts with choosing a form: from ordinary companies to special SPVs. Registration is carried out through the electronic portal, and the basic timeframe with a properly prepared package takes from several working days to a couple of weeks. We agree names, types of activity and constitutional provisions in advance so as not to return to the amendment stage.

SPV structures and trusts in the AIFC are convenient for asset transactions, securitization or incorporating a holding level. For funds, fund registration procedures in the AIFC apply, including submitting fund rules, disclosing valuation policy and selecting a depositary/custodian. Economic presence is established through an office, local directors and key functions, which is reflected in subsequent tax and regulatory aspects.

In COREDO projects we prepare a corporate governance package: board provisions, audit and risk committees, a senior manager regime with role demarcation. This reduces AFSA queries and facilitates the integration of external and internal audit under IFRS.

Licensing of investment activities, timelines and costs

Obtaining an investment license in the AIFC begins with an accurate description of the business model and the selection of the appropriate “regulated activities”. This determines the set of policies, capital requirements and staff profile. At the pre-application stage the COREDO team conducts a gap analysis against the AIFC Rulebook, develops a roadmap and agrees key parameters with AFSA to avoid incorrect classification.

The timelines and cost of obtaining an AIFC license depend on the complexity of the model and the applicant’s readiness. In our experience, the advisory and regulatory phase takes 8 to 16 weeks for ‘clean’ models, while more complex combinations involving custody and dealing require 4–6 months. The cost consists of AFSA fees, legal and compliance preparation, technological solutions and hiring of key persons, as well as future ongoing compliance costs.

Preparation for an AFSA inspection (AIFC regulator) includes interviews with directors, demonstration of operational systems, testing of compliance controls and a walkthrough of the client journey. I always recommend conducting a pre-inspection simulation – in a risk-free mode we identify ‘bottlenecks’ and fix them before contacting the regulator.

CIS and SPV Fund Structures: Disclosure

For investment funds in the AIFC, open and closed collective investment schemes (CIS) are available; private placements and public offers in the AIFC are subject to different regimes. Preparing a prospectus and disclosure in the AIFC requires a description of the strategy, risks, fees and valuation procedures, as well as prospectus requirements for key metrics. Our clients value structuring SPVs and trust solutions for individual transactions when it is necessary to flexibly separate classes of assets or investors.

Depositary and custodian requirements place particular emphasis on independence, accounting systems and asset storage technologies. Agreements with depositaries and service providers must clearly record SLAs, liability and escalation procedures. We conduct Due Diligence on providers in advance so AFSA sees a considered selection of counterparties, not a formal one.

For closed funds pursuing private equity and venture strategies the regulatory framework remains pragmatic if governance and risk management correspond to the scale of the portfolio. Investment committees, clear management of conflicts of interest and external audit are not just a checklist but a prerequisite for LPs’ trust.

Taxes in the AIFC: incentives, transfer pricing

tax incentives and AIFC stimuli often become a decisive factor. The AIFC provides regimes that reduce the tax burden on certain types of income, as well as simplification mechanisms where there is economic presence. At the same time it is important to align tax residency and certificates in order to use Kazakhstan’s double tax avoidance agreements and correctly process payments to investors.

Transfer pricing and documentation require attention if you have a cross-border chain of services or IP. The COREDO team develops a transfer pricing policy and a supporting file with functional analysis so that regulatory and tax audits go through without surprises. Reporting under IFRS and external auditors close the loop of trust and transparency.

Taxation of investment companies’ income in the AIFC should be considered together with the profit allocation model at the fund, management company and investor levels. Smart structuring of flows reduces friction costs and simplifies subsequent exit decisions.

Digital assets: tokenization and custody

Regulation of digital assets and tokenization in the AIFC is evolving through specialized AFSA regimes and the regulatory sandbox. Licensing of crypto exchanges and custody is built around storage technologies, cybersecurity and resilience to operational disruptions. In COREDO projects we pay particular attention to custody technologies for digital assets, segregation of client funds and access recovery processes.

Smart contracts and the legal status of tokens are analyzed in every case: tokenized fund shares, debt instruments or utility models fall under different parts of the Rulebook. I recommend starting with the legal qualification of the token and only after that choosing the technology stack. The AIFC license for digital asset operations opens doors to new sources of liquidity, but requires mature risk management.

KYC/eKYC and PEP/sanctions screening in “crypto” models are especially important: monitoring scenarios and triggers for STR should take into account volatility and address behavior. COREDO’s practice confirms that “compliance-by-design” reduces the cost of holding a license as you scale.

Clearing, custody and partner banks

Capital market infrastructure and clearing at the AIFC are developing in tandem with regional operators and international providers. Partner banks and custodians in Kazakhstan provide access to settlement and safekeeping of assets, and the clearing and settlement infrastructure at the AIFC is integrated with global standards. During the due diligence stage we assess connection architecture, contingency scenarios and software interfaces.

Agreements with depositories and service providers set out procedures for corporate actions, corporate voting and dispute resolution. Requirements differ for retail and institutional segments, and this must be taken into account when developing compliance policies. As a result, the regulator builds confidence in the operational quality of your platform.

For broker-dealer licenses, issues of secondary market liquidity and market-making are important. We select models in which the risk profile aligns with capital and insurance measures, and a disclosure policy addresses questions from clients and AFSA.

Scaling cross-border capital

Cross-border capital raising through the AIFC relies on clear fund marketing rules and AIFC advertising regulations. Passporting and cross-border services restrictions require separate strategies for the EU, the UK, Singapore, and the Middle East. I recommend building marketing funnels that take local private placement regimes into account and using flexible side-letter structures for institutions.

ROI assessment when operating through the AIFC should include NPV, IRR and payback period approaches, as well as profitability metrics for investment platforms: investor CAC, commission LTV, LP churn and compliance operational KPIs. Scaling an investment business through the AIFC becomes predictable when your KPIs are tied to regulatory metrics, onboarding time, share of alerts, and incident closure speed.

Marketing without transparency regarding complaints and suitability leads to regulatory and reputational risk at the AIFC. Therefore I insist on balancing growth with quality control, supported by regular reporting to the board and committees.

Risk Management and Compliance System

Management of operational and regulatory risks in the AIFC is built around three lines of defense: business, risk/compliance and internal audit. Investor protection and compliance measures become part of the culture rather than a separate department. In COREDO solutions we configure conflicts of interest management, outsourcing compliance and third-party risk management, covering the key capital supply chains: investors and unit-holders in the AIFC.

Due diligence of investors and limited partners, counterparty checks and forensic due diligence, sanction risks and international restrictions, as well as reputational screening and KYP (Know Your Partner) are part of the standard package. For cybersecurity and data protection we build measures with GDPR compatibility in mind, including DLP, IAM, encryption and incident response plans. The senior manager regime and management accountability formalize personal accountability and improve the quality of decisions.

External and internal audit for funds provides an independent view of finances and processes. IFRS reporting and regular compliance reports for AFSA reduce the information gap and enable complex topics to be discussed in the language of facts.

COREDO cases — what worked

Recently the COREDO team supported the licensing of an investment company focused on managing portfolios of debt instruments. The client applied for non-custodial management with advisory rights. We strengthened governance, prepared a capital adequacy model and implemented a transaction monitoring system. AFSA approved the license within the stated window, and subsequent review confirmed the quality of AML controls.

In another project we launched a broker platform with restricted dealing for institutional clients. Requirements for minimum statutory capital and operational resilience turned out to be higher than planned. We rebuilt the financial model, engaged a partner custodian and strengthened IT controls. The AIFC broker license was issued after an additional interview, and the business started operations on the schedule set out in the plan.

A separate case — a license for a venture fund in the AIFC with a multi-strategy focused on early rounds. We drafted the fund documents, established procedures for valuing illiquid assets, and agreed the private placement memorandum and marketing materials. The solution developed by COREDO enabled the fund to quickly close the first closings from institutional LPs and to build succession planning processes at the management company level.

Finally, for a digital asset custody provider we designed the licensing, storage technology architecture and recovery scenarios. Special attention was paid to PEP and sanctions screening, segregation of funds and contingency procedures. The AIFC license for digital asset operations was approved after demonstrating technological and operational test cases.

Cost of license maintenance

The cost of license maintenance and ongoing compliance costs include annual fees, an IFRS audit, policy updates, staff training, as well as IT and cybersecurity support. For companies with active growth, budget for expanding the compliance team, upgrading monitoring systems, and independent model reviews. Our experience at COREDO has shown that planning OPEX as a function of AUM and the number of clients reduces the risk of underfunding the control system.

Outsourcing some functions is possible and reasonable if you retain accountability. AFSA is receptive to outsourcing provided there are clear SLAs, regulator access to data, and independent oversight. It is important to conduct vendor risk assessments regularly and incorporate the results into management reporting.

In the long term, savings are achieved through KYC automation, integration with data providers, and product line standardization. This reduces risk variability and simplifies regulatory communication.

Visas and personnel: how to build a team

Visas and employment of foreign personnel in the AIFC are simplified through the center’s special regimes. We plan in advance the relocation schedule for directors and the key compliance officer, taking into account document timelines and the readiness of the IT infrastructure. This reduces the risk of delays at the launch stage.

corporate governance: requirements for the board and committees imply independent directors, charters for the audit and risk committees and clear authorities. In COREDO projects we pay special attention to describing the senior manager regime and management responsibilities, including business continuity plans and delegation. This forms a mature “line of defense” and helps during inspections.

Migration of fund management to the AIFC is possible with a well-considered transfer of functions, taking into account regulatory arbitrage and legal risks when changing jurisdiction. We arrange a phased transition while maintaining client service and controls.

Exit strategies and liquidity

Exit strategies for funds registered in the AIFC depend on the asset class and investment horizon. Exit options are available: IPO in Kazakhstan, trade sale and secondary buyout, as well as listing instruments on regional exchanges. I recommend planning secondary market liquidity metrics and market making already at the fund structure stage.

Prospectus requirements and risk disclosure when preparing for a listing require consistent messaging, financial transparency and management discipline. External audit and independent asset valuation increase confidence and accelerate the marketing window. The COREDO team supports clients through to final closing, overseeing legal and compliance aspects.

Regulatory arbitrage is useful when you compare the requirements of different centers and build a hybrid structure. The key is not to lose substance and the ability to manage risks, and to properly document the reasons for the choice.

Is the AIFC suitable for your model?

To make a considered decision, I suggest going through a checklist. Assess which license categories are needed right now and in 12–24 months, and how they are affected by the requirements for obtaining a license in AIFC. Align capital, substance and fit and proper requirements with available resources and your staffing plan.

Analyze client jurisdictions to account for cross-border service restrictions and local marketing requirements. Assess ROI: apply NPV and IRR to three scaling scenarios and take into account the payback period for licensing and IT. Do not leave regulatory risks and reputational risk in the AIFC in the shadows: set an acceptance threshold and a response plan.

If the AIFC meets the key criteria, it’s worth proceeding. If some parameters are ‘yellow’, adjust the design: a combination of an SPV and a management company, phased licensing, a pilot with a regulatory sandbox and subsequent upscaling.

Why COREDO is a reliable AIFC partner

Over years of working in Europe, Asia and the CIS I have learned that success in the AIFC is built on careful process calibration and attention to detail. The COREDO team is used to being accountable for results: from registering a legal entity in the AIFC and licensing investment activities in the AIFC to deploying AML/KYC and preparing for an AFSA inspection. We do not promise miraculous timelines, but we design realistic roadmaps and ensure transparency at every stage.

If you are considering an AIFC investment license, an AIFC asset manager license, an AIFC broker license, an AIFC depository license, or fund structures, I am ready to discuss your business model and offer a practical solution. COREDO’s experience shows that a properly structured setup in the AIFC simplifies cross-border capital raising, strengthens investor confidence, and creates a foundation for strategic exit decisions. That is the kind of foundation needed for calm, steady scaling of an investment business.

The COREDO team has implemented dozens of structures in Luxembourg, the Czech Republic, Cyprus, Estonia, the United Kingdom, Singapore and Dubai. When entrepreneurs and chief financial officers from Europe, Asia and the CIS come to me with the task of quickly and cleanly launching a fund for professional investors, we often choose the Reserved Alternative Investment Fund: RAIF Luxembourg. It is a tool that combines private-market flexibility, AIFMD compliance, tax efficiency and predictable RAIF fund launch timelines.

Below I share a practical guide: from choosing a RAIF fund structure and an AIFM for the RAIF to AML/KYC requirements, valuation policies, tax planning and RAIF marketing in the EU. I use the language of business, real COREDO cases and the solutions that give our clients speed, risk control and investor confidence.

Why a RAIF in Luxembourg is advantageous

Illustration for the section «Why RAIF in Luxembourg is advantageous» in the article «RAIF in Luxembourg – launching a fund»
Luxembourg provides a stable legal environment and predictable law and regulation for RAIF. The RAIF was established by Luxembourg’s 2016 RAIF Law; at the same time the fund does not require direct supervision by the CSSF: the CSSF’s role and oversight are exercised through a licensed management company — an AIFM for the RAIF — which significantly speeds up RAIF registration in Luxembourg and the first closing. This structure allows use of the AIFMD passport for cross-border distribution of the RAIF and marketing the RAIF in the EU to professional investors.

From a tax perspective, tax planning for a Luxembourg RAIF is transparent. In the typical regime the fund benefits from Luxembourg funds’ exemption from corporate taxes and pays the nominal taxe d’abonnement (usually 0.01% per annum of NAV), while the transmission of income to investors occurs without withholding tax in Luxembourg, which reduces withholding tax issues at the fund level. The “risk capital” option makes a RAIF comparable to a SICAR in terms of regime, which is convenient for pure private equity.

In our practice COREDO uses the launch of a Reserved Alternative Investment Fund for private equity deals in Central and Eastern Europe, direct real estate funds (core/core-plus, value-add) and hedge strategies involving derivatives. The flexibility of the investment mandate and the rapid time-to-market save months and directly support raising AUM.

Regulatory framework: what you need to know

Illustration for the section «Regulatory framework: what you need to know» in the article «RAIF in Luxembourg – launching a fund»
RAIF is managed by an external AIFM authorized in the EU; this is the AIFMD compliance “anchor” for the RAIF. The manager assumes risk management and portfolio management, liquidity control, conflicts of interest policy and the RAIF’s ESG and SFDR compliance. The professional investor requirement precludes retail distribution: the RAIF is intended for well-informed and professional investors under MiFID; RAIF minimum investment thresholds typically start at EUR 125,000, and, upon competence certification, at the AIFM’s discretion.

I often explain the RAIF vs SIF vs SICAR difference fairly briefly. RAIF: without CSSF authorization, faster, with an AIFM and an AIFMD passport, tax regime like a SIF (or the “risk capital” option). SIF/SICAR: direct CSSF supervision and a longer pre-sale phase, although some LPs prefer the “regulated” label. When investors value speed to market and flexibility, RAIF proves optimal.

Capitalization — clear and achievable: RAIF capital requirements: reach a minimum of EUR 1,250,000 within 12 months from launch. Implementation deadlines and monitoring are set out in the fund documentation and are overseen by the administrator and the AIFM.

RAIF structure and investment strategies

Illustration for the section «RAIF structure and investment strategies» in the article «RAIF in Luxembourg – fund launch»
The choice of legal form depends on strategy and tax objectives. Most often I recommend SCSp (an unincorporated limited partnership) with an LPA agreement and rights of Limited Partners, where the carried interest remuneration structure and the profit distribution waterfall model can be configured flexibly. For hedge strategies corporate forms with a board of directors and independent directors are convenient – RAIF governance and independent directors increase LPs’ confidence and improve audit.

  • RAIF for private equity: growth and buyout deals, possibility of a master-feeder RAIF structure for different classes of investors and currencies.
  • RAIF for a hedge fund: RAIF pricing and NAV, often monthly, side-pocketing of illiquid assets is allowed for stressed assets, redemption gates and suspension of redemptions for risk management.
  • RAIF for real estate: valuation methodologies for real estate and illiquid assets, an independent valuer and a clear valuation policy and frequency of NAV (quarterly/semi-annually).
In master fund feeder structuring benefits we use multi-currency classes, optimize currency risks and hedging for the RAIF through class-level swaps and forward strategies. Side letters and investor preferences are applied selectively: the economics must not undermine equality between classes and the waterfall.

Providers and contractual architecture

Illustration for the section «Providers and contractual architecture» in the article «RAIF in Luxembourg – fund launch»
The solution developed by COREDO to speed up the launch is a “block” of contracts and providers with ready-made SLAs. In such a scheme:

  • Registration of the AIFM management company: we take an external EU-authorised AIFM or register a new one (longer and more expensive). Delegation of RAIF management is structured through a management agreement and agreements with the investment consultant.
  • Depositary and custodian for the RAIF: RAIF depositary duties include cash flow monitoring, safekeeping and oversight. The depositary agreement is agreed together with the administrator.
  • RAIF fund administrator services: maintaining the register, NAV calculation, financial reporting, subscription/redemption of shares (RAIF subscription and redemption procedure), KYC/AML operational processes. registration agent RAIF performs transfer agent functions.
  • Independent auditor and NAV audit: annual audit of financial statements and valuation procedures.
  • Asset valuation — independent valuer: for real assets and complex private debt portfolios.
  • corporate governance: governance committee and investment committee with clear mandates; conflict of interest and disclosure policy – a mandatory element of AIFMD.
Fund documentation is built around the offering memorandum for the RAIF, the LPA (or articles of association), the term sheet for key parameters, subscription agreements, as well as distribution agreements for the EEA. COREDO’s practice confirms: clear documentation at the start saves months in subsequent rounds of LP fundraising.

Operational AML and KYC procedures

Illustration for the section «Operational AML and KYC procedures» in the article «RAIF in Luxembourg — fund launch»
AML KYC requirements for RAIF comply with AIFMD standards and Luxembourg rules. We set up AML risk assessment and control policies together with the AIFM and the administrator, including PEP screening and enhanced Due Diligence, sanctions monitoring and EU sanctions, as well as transactional monitoring of suspicious operations. Investor due diligence for RAIF covers KYC/KYB for institutional investors of the RAIF, source of funds analysis and the beneficial owner and UBO of the RAIF.

From the data exchange perspective the fund is classified under CRS, FATCA, RAIF. We organise FATCA registration and GIIN for investors where required, and configure the CRS European automatic exchange so that annual reporting cycles proceed predictably. Additionally, we ensure GDPR compliance for the fund in the EU, including IT security and protection of investor data, access segregation, operation logging and provider control under SLAs.
AML regulators and the recommendations of FATF set the “ceiling” of practices; my team adapts them to the risk profile of the strategy, the jurisdictions of target assets and the channels for attracting LPs. This approach is recorded in AML policies, and operational outsourcing and process customization reduce manual workload without losing control.

Taxes, substance and cross-border structuring.

The tax residency status of a RAIF fund depends on its form. In a “SIF-like” regime the fund is usually exempt from corporate tax and does not claim benefits under double tax treaties; to reduce taxes in portfolio jurisdictions we set up an SPV layer and substance requirements and economic substance (substance documents: office lease, employees, local directors). For private equity and real estate, transfer pricing and the RAIF affect loan and service agreements; we check compliance with the “arm’s length” principle and the TP documentation.

BEPS and its impact on fund structure together with ATAD and EU anti-abuse rules (interest limitation, GAAR, CFC at the investor level) are becoming standard for the project. For cross-border financing programs I introduce DAC6 reporting and cross-border schemes as a mandatory checklist item. Issues of income allocation and withholding tax are resolved through a treaty-eligible SPV where economically justified; capital repatriation and foreign exchange control are taken into account in cash modelling for LPs from different countries.

Marketing and distribution: compliance

Thanks to the AIFM, RAIF marketing in the EU uses the AIFMD passport for professional investors, and marketing registration in the EEA is carried out centrally. For a number of markets pre-marketing is used, and, for non-EU jurisdictions, private placement is done under local NPPR. We comply with the public advertising restriction and distribution rules: no retail communications, clear legends and geographic filters.

In COREDO projects the marketing strategy for family offices is built around qualification sessions and a data room focused on risk metrics and governance. To attract institutional capital and for LP due diligence we assemble a package: track-record, AIFMD policies, ESG and SFDR compliance of the RAIF (arts. 6/8/9), valuation policy, independent directors, committees, auditor reports. We tie fund scaling and AUM attraction to fund performance KPIs and ROI metrics: IRR/TVPI/DPI, time-to-close, share of invested capital, and specific ongoing charges.

Liquidity and risk management

RAIF risk and liquidity management: the AIFM function and a documented LRM policy. In closed PE/RE structures, liquidity terms and lock-up periods are specified, as well as the schedule of capital calls and distributions. In open strategies, redemption gates and suspension of redemptions are used as a rare-event tool, and the fund’s liquidity stress-testing is performed against market shock and outflow scenarios.

Currency risks and hedging for RAIF are implemented at the share-class or portfolio level: forwards, NDFs, swaps with counterparty limits. The valuation policy takes into account RAIF pricing and NAV, including FX, fair value and methods for illiquid assets; an independent auditor reviews the approach and the frequency of NAV calculation.

Documentation and procedures

Preparing the offering memorandum for the RAIF sets the rules of the game: description of the strategy, limits, valuation, risks, subscription and redemption procedures of the RAIF, fees, ESG, SFDR disclosures. The management agreement clarifies delegation and AIFM oversight; the depositary agreement and the agreements with the administrator and the registrar/transfer agent establish the control points. Side letters and investor preferences are permitted within the bounds of fairness between classes and without breaching the prospectus.

I insist on a clear conflicts of interest policy and a disclosure policy, including related-party transaction regimes and a governance committee with independent directors. This is partly within the scope of AIFMD, but genuine LP trust is built through transparent practice, not just by rules.

Timelines and costs — guidance

Our experience at COREDO shows that the launch timeline for a RAIF fund with a finalised strategy and an AIFM in place is 8–12 weeks to soft-close. This includes structuring, opening accounts with the depositary, negotiating agreements, registering in the registers and publishing the offering memo. If registration of the AIFM management company from scratch is required, the timeline is extended by 4–6 months.

The cost of launching a RAIF in Luxembourg depends on the mix of providers and the complexity of the structure. In a typical project the setup and first-year budget comprises legal support for the RAIF, fees for the AIFM, the depositary and administrator, an independent auditor, a registration agent, a valuer (if required), D&O insurance and marketing expenses. As a reference, formation and first-year ongoing charges for COREDO clients typically fall within the average range for institutional RAIFs, and the unit burden quickly decreases as AUM grows. I determine specific pricing after receiving a term sheet on the strategy and operating model.

Timeline and project launch checklist

To ensure process transparency and save time, I use a step-by-step checklist:

  1. Strategy, RAIF fund structure, choice of form (SCSp/corporate), tax regime.
  2. Economic term sheet: classes, fees, carried interest, waterfall and exit waterfall.
  3. Providers: AIFM, depositary and custodian, administrator, auditor, registration agent, independent valuer.
  4. Fund documentation: offering memorandum, LPA/articles of association, management agreement, depositary agreement, distribution/placement agreements, subscription agreement.
  5. Policies: valuation policy and NAV frequency, risk and liquidity management, AML/KYC, sanctions, GDPR and IT security, ESG and SFDR.
  6. Marketing and cross-border distribution of the RAIF: registration in the EEA, private placement outside the EU, restriction on public advertising.
  7. Substance: office, local directors, meeting calendar, recruitment compliance for the management team.
  8. Reporting and audit: annual audit, audit approval and annual general meeting, CSSF notification via the AIFM.
  9. Finance: transaction costs and ongoing charges, currency policy, hedging, banking and brokerage agreements.

COREDO case studies: solutions in practice

Recently the COREDO team launched a RAIF for private equity with a focus on buyouts in the EU industrial sector. We selected an SCSp, set out carried interest with a European waterfall, and implemented a master-feeder for multi-currency fundraising. For liquidity management we provided capital calls by deal stages, and for tax purposes – an SPV in contractual jurisdictions with substance and TP documentation. The investors’ committee received independent members, and the AIFM adopted a risk policy and SFDR disclosures under Article 8.

Another project, a RAIF for real estate with a value-add strategy. We appointed an independent valuer, quarterly NAV, a side-pocket for rare workout assets and redemption gates in case of market shocks. A depositary with experience in real assets took custody and recordkeeping, an administrator, and robust KYC/KYB for institutional investors. As a result the fund reached first closing in 10 weeks, and subsequent marketing in the EEA was carried out through the AIFMD passport.

For a hedge strategy with liquid instruments, the solution developed at COREDO included daily pricing of key assets by a price provider, monthly NAV and strict counterparty limits. We built in liquidity stress-testing, FX hedging of classes and a suspension policy for extraordinary conditions. LPs received a transparent reporting pack and a clear fee model.

Secondary sales and investor exit

Exit strategies of RAIF investors depend on the structure. In closed-ended funds this is a waterfall distribution after exit from the portfolio; in open-ended funds: redemptions according to the rules and frequency described in the prospectus. If necessary, a secondary-market sale of a stake is permitted: transfer of an LP’s interest with the consent of the GP and AIFM and updating the registers with the administrator. We add these mechanics in advance to the LPA and subscription agreements so as not to restrict the transferability of interests.

Where difficulties most often arise

The question “RAIF depositary obligations” when investing in illiquid or non-standard assets requires early selection of a custodian prepared for such classes. We begin negotiations at the term sheet stage, agree on the valuation policy and the description of ownership rights.
Another point — ESG and SFDR compliance for RAIF: an agreed level of ambition is needed (article 6/8/9) and real operational capability to collect data from SPVs and portfolio companies.
In cross-border structures I pay attention to BEPS/ATAD, substance and DAC6. Proper substance documents (office lease, local directors, meeting minutes) and recruitment compliance for the AIFM management team address issues of the “paper” structure and strengthen the position during institutional LP due diligence.

Benefits of RAIF for the investor

Benefits of RAIF for investors consist of three components. First, Luxembourg’s legal regime, the stability of the legal environment in Luxembourg, and AIFMD compliance through an AIFM with clear roles for the depositary, auditor and administrator. Second, flexibility of the remuneration structure (carried interest and waterfall), governance and independent directors, committees and clear LP rights (LPA, side letters within the framework of fairness). Third, tax efficiency at the fund and SPV level, well-considered currency hedging and predictable Ongoing charges.

Institutional LPs also value automatic information exchange CRS FATCA RAIF, robust AML processes, sanctions monitoring, PEP screening and enhanced due diligence. KPI and ROI metrics, regular reporting and NAV audits matter to them — we build all of this into the operating model from day one.

Why I recommend RAIF and COREDO

RAIF is an instrument that combines speed to market, the AIFMD distribution passport, a flexible structure for private equity, hedge funds and real estate, and a transparent compliance regime. In COREDO projects this is expressed in a controlled timeline, a clear budget, predictable regulatory steps and investor trust even before the first closing.

When an entrepreneur or CFO comes to me with the task of “setting up” a fund for professional LPs and scaling AUM, I offer a roadmap: from choosing the form and tax regime to selecting providers, fund documentation, ESG and SFDR, AML and GDPR. COREDO’s practice confirms: it is precisely the sequence and attention to detail — from the valuation policy to distribution rules and substance — that turn a strategy into a working RAIF that withstands institutional investors’ due diligence and delivers a predictable result.

The European ELTIF is precisely such a tool. With the entry into force of ELTIF 2.0 in January 2024, it became closer to retail investors and more convenient for asset managers. Over the past months the COREDO team has carried out several ELTIF launches and restructurings in Luxembourg and Ireland, adapted processes to the requirements of AIFMD, MiFID II, PRIIPs and SFDR, and established transparent AML/KYC procedures for investors from Europe, Asia and the CIS. In this article I summarize our experience and provide a compact yet thorough guide – from fund design to income distribution and liquidity management.

What is ELTIF 2.0 and what has changed for retail investors?

Illustration for the section «What is ELTIF 2.0 and what has changed for retail investors» in the article «ELTIF 2.0 – opportunities for retail investors in the EU»

ELTIF – European Long-Term Investment Fund: a regulated EU alternative fund for investments in illiquid assets: infrastructure, the real economy, private equity and private debt. Version 2.0 (Regulation (EU) 2023/606, amendments to 2015/760) removed the main barriers for retail investors: the minimum amount of 10 000 EUR and the “10% test” for portfolios under 500 000 EUR were abolished. Now ELTIF accessibility for retail investors has become a reality, and the requirements for suitability and product governance have moved under the MiFID II framework.

From the perspective of assets and portfolio, ELTIF 2.0 has undergone important changes. The investment threshold in eligible assets was reduced from 70% to 55%, the types of permitted assets were expanded (including funds of funds UCITS/AIF), excessive restrictions on co-investment via SPV were removed, and flexibility on leverage was added.
For retail marketing, the borrowing limit is usually capped at 50% of NAV; for professional marketing: up to 100% subject to compliance with risk policies.

COREDO’s practice confirms: these parameters allow building a realistic ELTIF portfolio structure with a balance of returns and control of illiquidity.

ELTIF vs UCITS: different objectives – different liquidity

Illustration for the section 'ELTIF vs UCITS: different objectives - different liquidity' in the article 'ELTIF 2.0 – opportunities for retail investors in the EU'

Comparing ELTIF vs UCITS is important already at the product positioning stage. UCITS provide predominantly liquid markets, daily valuation and redemption, but rarely open access to infrastructure projects or private equity. ELTIF, by contrast, is built around long-term investments and may have a limited or closed redemption regime. In our experience, for wealth managers and private banks it is rather the strategic core of ‘alternative’ and real assets, while UCITS cover the liquid layer of the portfolio.

Marketing and passport in the EU: how to distribute ELTIF

The European ELTIF passport and passporting across the EU operate through AIFMD mechanisms. Manager: authorised AIFM: submits a notification to the national regulator, and the fund becomes available for cross-border ELTIF distribution in Europe. Consistency of the prospectus, UCITS-style disclosure for retail and compliance with MiFID II requirements on the target market, product governance and the suitability test are important. ESMA recommendations on ELTIF and technical guidance clarify the approach to liquidity, valuation and pre-contractual disclosures, and the European Commission rules on ELTIF set the overall framework of the 2.0 reform.

Access for retail investors: how to invest in ELTIF

Entering ELTIF for retail investors has become easier. The process typically includes onboarding: eKYC, eID and electronic signature, MiFID suitability/appropriateness questionnaires, provision of the PRIIPs KID, and signing subscription agreements. At COREDO we have built a digital route with AML and KYC requirements for investments in ELTIF, including enhanced Due Diligence for high-risk investors and checks of beneficial ownership registers. For clients from Asia and the CIS we add CRS and automatic exchange of information to avoid surprises in reporting.

Minimum amount, fees and expenses

ELTIF 2.0 removed the regulatory minimum entry threshold, so the minimum ELTIF investment amount is now determined by the prospectus and the distribution policy. We often see a range from 5 000 to 25 000 EUR for retail and from 100 000 EUR for professional tiers. ELTIF fees and expenses are transparent in the KID and prospectus: fixed management fee, possible performance fee, structural expenses, depositary, audit, custody and administration. Compensation structures for ELTIF managers include a hurdle rate, carried interest and performance fee mechanisms, and the waterfall distribution and payment priority are detailed in the LPA/prospectus, including clawback provisions.

Liquidity for retail investors: tools and limitations

The main question is ELTIF liquidity for retail investors. ELTIFs are illiquid by nature, but 2.0 allowed buyback mechanisms before maturity: redemption windows, matching of secondary orders and liquidity management tools. Liquidity management in ELTIF uses redemption gates, suspension and lock-up periods, side pockets for troubled assets, as well as swing pricing and NAV adjustment on inflows/outflows. The secondary market for ELTIF units is developing: exchange listings are still rare, but secondary-market platforms for units of alternative funds and broker ‘notice boards’ for deal matchmaking are emerging.

Taxes: structure matters more than the rate

Taxation of investments in ELTIF is not harmonised at the EU level and depends on the jurisdiction of the fund and the investor. Tax efficiency of an ELTIF for international investors is achieved through structuring via SPVs and holdings, using tax treaties and avoiding double taxation. At COREDO we model flows in advance, taking into account withholding on coupons/dividends, CFC rules in investors’ countries and ‘pass-through’ regimes in Luxembourg, Ireland or Malta. For HNWIs and family offices we often create bespoke tax memoranda and accompanying information-exchange agreements.

ELTIF portfolio structure: eligible assets, diversification, leverage

Illustration for the section 'ELTIF portfolio structure: eligible assets, diversification, leverage' in the article 'ELTIF 2.0 – opportunities for retail investors in the EU'

The asset eligibility under ELTIF 2.0 has broadened: infrastructure, real assets, private debt, investments in unregulated assets with enhanced risk controls, as well as funds of funds and co‑investment via SPVs.
ELTIF diversification requirements have been relaxed: the stake in a single project/issuer may be higher than in the first version, but concentration limits remain, as do limits on transactions with affiliated parties.

ELTIF leverage restrictions are tied to whether the marketing is to retail investors or to professionals only, and subscription lines and leverage in ELTIFs are allowed within the risk policy and AIFMD limits.

Investment opportunities: infrastructure and private markets

investment opportunities in ELTIF infrastructure are especially in demand amid the energy transition and digitalization. We structured an ELTIF with a portfolio of brownfield transport and energy projects in Central Europe, adding a share of greenfield with staged capital calls and construction insurance. Private equity investments through ELTIF cover buy‑out and growth stages, as well as private debt for SMEs, where returns are generated through coupon income and arrangement fees. Benchmarking: ELTIF versus private equity and infrastructure funds shows comparable returns with better transparency and European supervision.

Valuation, NAV and tools for illiquid assets

NAV valuation issues in illiquid ELTIFs are addressed through independent valuation of alternative assets and model validation. ESMA recommends stress tests and portfolio scenario analysis to show the impact of rates and credit spreads, as well as liquidity management under shocks. Side pockets and handling of illiquid assets help isolate problematic positions, and swing pricing adjusts investor entry/exit to protect existing unitholders. Our experience at COREDO has shown that a clear valuation methodology and oversight by an independent valuer simplify audits and reduce dispute risks.

Governance, legal aspects and AIFMD

The legal aspects of ELTIF registration are tied to AIFMD: manager — a licensed AIFM, depositary – with full oversight and depositary responsibility for safekeeping/recordkeeping. Custody and the role of the depositary in ELTIF require clear SLAs and monitoring of conflicts of interest, and regulatory supervision and ELTIF audit include regular disclosures, Annex IV reporting and an annual audit. We record regulatory changes and the compliance roadmap in a compliance calendar with checkpoints for ESMA technical guidance and internal policies on best‑practice compliance governance.

Jurisdictions and corporate structuring

Registering an ELTIF manager in Luxembourg or Ireland is the most common choice, but Malta remains a workable alternative. Onshore vs offshore funds: EU advantages: transparent supervision and a marketing passport; disadvantages: higher administration costs compared to offshore SPCs. Structuring via SPVs and holding companies allows addressing tax issues, subordination and local licensing; structural subordination and credit risk of SPVs are accounted for in the credit documentation and covenants. For investments outside the EU we add local SPVs with arrangements on security and a cash sweep in the waterfall.

Documents, fees, waterfall and capital calls

Preparing the prospectus and key documents includes: constitutive documents, offering memorandum, PRIIPs KID, SFDR disclosures, risk and liquidity policies, target market and product governance documents. Subscription agreements and legal documents carefully reflect the mechanics of investor contributions, capital calls, default procedures and penalty interest. The waterfall and income allocation in an ELTIF detail payment priorities: return of capital, hurdle rate, catch‑up and carried interest; we often add an escrow mechanism and definitions of “realised proceeds” to avoid ambiguity. ELTIF fees and expenses are disclosed according to PRIIPs KID disclosure requirements for retail investors.

Suitability, marketing and distribution channels

MiFID II and suitability assessment when selling ELTIFs are critical for stable distribution. Marketing notices and UCITS‑style disclosure are adapted to local regulator expectations, avoiding aggressive yield promises. Distribution channels: banks, private banks, wealth‑tech platforms and licensed distributors; integrating ELTIF into wealth management solutions helps build a “core‑satellite” model where ELTIF is a long‑term core of alternatives. COREDO helps align ELTIF passporting and marketing across the EU, including regional restrictions on sales outside the EU and working with investors from Asia and the CIS through local NPPR regimes or Reverse Solicitation.

ESG and Sustainable ELTIF: from SFDR to real impact

Illustration for the section «ESG and Sustainable ELTIF: from SFDR to real impact» in the article «ELTIF 2.0 – opportunities for retail investors in the EU»

Sustainable ELTIF and SFDR require alignment: classification under Articles 8/9, PAI indicators, sustainability measurement methodologies and reporting. Greenwashing risks and the control of ESG claims we mitigate through project KPI matrices, external verification and harmonization of wording with the depositary and auditors. In infrastructure, ESG metrics are integrated into credit covenants and financing terms; this simplifies subsequent refinancing and increases the asset’s value at exit.

Tokenization, digital fund units and the secondary market

Tokenization of fund shares and blockchain solutions increase operational efficiency and the transparency of the register of fund units. ELTIF tokenization and digital fund units are implemented through the DLT laws of individual EU countries, and it’s important to distinguish regulation of digital assets and MiCA in the context of ELTIF: tokens representing a fund share are not equivalent to crypto-assets under MiCA. Secondary market platforms for alternative fund units already allow organizing matching and periodic auctions, which support liquidity and reduce the cost to the investor in the case of an early exit. The solution developed by COREDO combines eKYC/eID, electronic signature, AML monitoring and a secondary trading module with restriction controls.

ELTIF risks for private investors and how to manage them

Illustration for the section 'ELTIF risks for private investors and how to manage them' in the article 'ELTIF 2.0 – opportunities for retail investors in the EU'

Key risks: illiquidity, valuation and NAV recalculation, credit risk of borrowers/projects, leverage limits, operational risks and cybersecurity. ROI assessment and performance metrics for ELTIFs include IRR/TVPI/DPI and scenario analysis, stress testing and portfolio scenario analysis for rising rates and multiple compression. Exit strategies and ELTIF redemption windows require discipline: pre‑agreed periods, matching mechanisms and communication with retail investors and the KID.

Our approach at COREDO: to speak openly about shortcomings, explain redemption gates, suspension and lock‑up periods, and offer realistic secondary options.

COREDO case studies: from design to distribution:

Infrastructure ELTIF in Luxembourg. The COREDO team implemented a structure focused on brownfield assets of transport and energy infrastructure in Central Europe, integrated independent valuation and side pockets, and established quarterly redemption windows with limits. Passporting to Germany, Italy and Spain, channels: private banks and licensed platforms.

Private debt ELTIF in Ireland. Our experience at COREDO has shown that using subscription lines and soft leverage up to 40% of NAV accelerates capital deployment without loss of diversification. We established independent loan valuation, stress‑tested for rising rates and developed a waterfall with a hurdle rate and transparent carried interest.

Integration of ELTIF into wealth solutions. For a network of wealth managers and private banks we prepared target market and product governance documents, KID in several EU languages, as well as a MiFID suitability procedure. Clients — family offices — received a clear due diligence model when investing in ELTIF and regular SFDR reports.

Due diligence: checklist for managers and investors

COREDO’s practice confirms the value of systematic DD. We use a due diligence checklist for managers and investors:

  • Manager and governance: AIFM license, Board independence, conflicts of interest policy.
  • Strategy and pipeline: eligible assets list, geographic scope, co-investment, ELTIF regulatory restrictions.
  • Risks and liquidity: liquidity management tools, redemption policy, stress tests, NAV valuation, independent valuation.
  • Finance: ELTIF fees and expenses, waterfall structure, hurdle rate and carried interest, ROI scenarios.
  • Operations: depositary and oversight, custody, cybersecurity and backups, operational risks.
  • Legal and tax: prospectus, subscription agreements, Annex IV, double taxation and tax treaties.
  • ESG: ESG standards and disclosures under SFDR, monitoring greenwashing claims.

Enforcement and disputes: what to expect

Legal disputes and precedents regarding ELTIF are still rare, but issues usually concern valuation, disclosures and liquidity. We include arbitration clauses, a procedure for an independent revaluation and clear definitions of liquidity events. For regions outside the EU we comply with sale restrictions and NPPR regimes, and also document reverse solicitation to minimize regulatory risks.

Macro factors, refinancing and flow management

We take the impact of macroeconomics and the interest rate on asset valuation into account in our models: duration of infrastructure cash flows, sensitivity of PE multiples and cost of debt. We plan capital inflow/outflow management and the refinancing market in advance: subscription windows, synchronization of capital calls with the pipeline and covenants on project refinancing. For investors this means a more stable strategy implementation and predictable communication about the payment schedule.

ELTIF for investors from Asia and the CIS

Investors from Asia and the CIS value European supervision and the ELTIF European passport. We take into account local rules and currency regimes, set up AML Enhanced Due Diligence, ensure CRS reporting and ownership transparency through beneficial owner registers. Where sale outside the EU is restricted, we use cooperation with local licensed partners or reverse solicitation mechanisms, without breaching the regulatory framework.

Best-practice compliance governance for managers

The solution developed at COREDO includes: a matrix of regulatory obligations under AIFMD/ELTIF, an Annex IV calendar, internal LMT policies, regular reports to investors and UCITS‑style disclosures. For risk assessment we apply stress tests, default SPV scenarios, structural subordination and credit risk analysis, as well as IT controls and cyber backup. Such a «framework» increases trust and simplifies work with auditors and the depositary.

What ELTIF 2.0 changed for retail investors – briefly:
  • More accessibility: no regulatory minimum, clear KID and MiFID‑processes.
  • More portfolio flexibility: broader eligible assets, reasonable diversification.
  • More realistic liquidity: redemption windows and LMT with clear disclosure.
  • Stronger focus on disclosures: PRIIPs KID, SFDR, ESMA guidance and product governance.

Conclusion: how to move forward

ELTIF 2.0 has become a mature tool for international investors and asset managers. For companies from the EU, Asia and the CIS it opens access to infrastructure, real assets and private markets with a European level of protection and transparency. It is important to soberly assess illiquidity, properly structure taxes and build operational discipline; then an ELTIF becomes not just a “long‑horizon fund” but a stable anchor for a portfolio.

The COREDO team has already helped launch and adapt such structures in Luxembourg, Ireland, Cyprus and Estonia, and also integrate them into banks’ channels and wealth platforms. If you need a roadmap for ELTIF — from choosing a jurisdiction and a depositary to product governance and cross‑border distribution — I’ll share practical templates, checklists and examples. Mature design, transparent disclosures and a demanding approach to risk are the three pillars that underpin a quality ELTIF, and that’s exactly how I am accustomed to building solutions together with COREDO.

When I launched COREDO in 2016, my goal was simple and ambitious: to give entrepreneurs and capital managers from Europe, Asia and the CIS a reliable path into the complex world of international structuring, licensing and compliance. Since then the COREDO team has implemented dozens of fund projects: from the EU and the UK to Singapore and Dubai — and I can clearly see how the Variable Capital Company (VCC) in Singapore is changing the game for hedge funds. This article is a distillation of COREDO’s practice: what works, where the pitfalls are, and how to achieve maximum operational and tax efficiency from a VCC in 2026.

What is a VCC, and why choose Singapore?

Illustration for the section «What is a VCC and why Singapore?» in the article «Variable Capital Company in Singapore – a structure for hedge funds 2026»
Variable Capital Company (VCC), is a Singaporean form of fund organization, developed specifically for the needs of investment structures. Unlike a traditional company, a VCC allows variable capitalization: a fund can freely issue and redeem shares at net asset value (NAV), simplifies the distribution of income and the range of share classes, and also allows operating a structure in an umbrella fund structure with sub‑fund segregation. For hedge funds this is the equivalent of a Swiss Army knife: flexibility, speed and control over liquidity.

Singapore is strengthening its position in Asia as a regulated “onshore” haven. In practice COREDO confirms: investors from Europe and Asia view the VCC as an understandable compromise between strict regulation and commercial efficiency.

The regulator MAS builds frameworks through the Securities and Futures Act (SFA), supplements them with MAS guidance VCC, and the tax infrastructure relies on a wide network of double taxation agreements. As a result, the VCC in Singapore becomes a logical choice for hedge funds, especially when institutional acceptability and readiness for Due Diligence by prime brokers and banks are required.

VCC architecture: umbrella and sub-funds

Illustration for the section «VCC architecture: umbrella and sub‑funds» in the article «Variable Capital Company in Singapore – structure for hedge funds 2026»
VCC supports an umbrella fund structure with multiple sub‑funds. Each sub‑fund forms a separate segregated portfolio: the liabilities of one sub‑fund do not legally transfer to another. In real COREDO projects this allows isolating strategies (for example, market neutral and event‑driven) and creating different share classes by currency, fees and liquidity for different investor profiles.

The liquidity and variable capitalisation of a VCC allow organizing subscription and redemption mechanics with gate provisions and side pockets for complex or illiquid assets. I always recommend documenting capital reduction procedures and variable capital processes so that the Administrator and Custodian can execute them without manual workarounds. This is the foundation for robust liquidity management, especially when using leverage and derivatives.

For hedge funds, the flexibility of the VCC is revealed through capital flexibility and share classes: you can launch both open‑ended and closed‑ended VCCs, and if necessary – convert or launch parallel classes for new mandates. Our experience at COREDO has shown that properly structured classes can reduce conflicts of interest between investors with different liquidity windows and lower operational risks in stress scenarios.

Manager licensing

Illustration for the section «Manager licensing» in the article «Variable Capital Company in Singapore – structure for hedge funds 2026»
Key question: what licences does a fund manager need in Singapore. Depending on the strategy and investor base this is the Capital Markets Services (CMS) licence for fund management or the Registered Fund Management Company (RFMC) regime. CMS suits large-scale managers and allows a broader range of activities; RFMC is a simplified regime for managers with smaller AUM, but with limits. The solution developed at COREDO typically combines an assessment of target investors, marketing geographies and derivative instruments to determine the least sufficient regime.

MAS requirements for VCC include corporate governance, appointment of a licensed or registered manager, an auditor, a corporate secretary and, as a rule, a fund administrator.

For retail funds – different thresholds and requirements for a depositary/trust structure; for professional and institutional funds, more flexibility but not less responsibility. The COREDO team ensures that governance meets institutional investors’ expectations: independent directors with relevant qualifications, clear fiduciary duties, a meeting calendar, minutes and a conflicts of interest policy.

Regarding product restrictions the VCC as a form is flexible. Restrictions more often follow from investor status and the manager’s licence. In the institutional/accredited segment Singapore does not set strict limits on derivatives and leverage, but requires an adequate risk management framework, disclosures and controls. COREDO’s experience confirms: MAS’s inspection focus is on the actual implementation of policies, not just their formal existence.

Taxes for VCC: 13R/13X and residency

Illustration for the section «Taxes for VCC: 13R/13X and residency» in the article «Variable Capital Company in Singapore – structure for hedge funds 2026»
VCC tax benefits are based on the regimes Section 13R and Section 13X. The 13R regime is intended for onshore‑funds with certain requirements for AUM and investor profile; 13X is a more “institutional” incentive without investor restrictions, but with minimal economic criteria. In COREDO cases we achieve optimization by obtaining a tax residency certificate for the VCC, access to the DTA network and proper management of withholding tax implications for funds.

Economic substance requirements for VCC — a point of focus in 2026. A management function in Singapore is required: board meetings in Singapore, a local director, on‑the‑ground contracts with administrators and auditors, as well as a reasonable “critical mass” of operations and decision‑making. The issue of substance and employees vs service outsourcing is addressed by a combination of the manager’s core‑personnel and outsourcing non‑core functions. We take into account BEPS 2.0 / Pillar Two implications for funds: hedge funds are often subject to carve‑outs, but this requires a review of the group structure and investor layers.

GST treatment for investment funds in Singapore is usually neutral at the investment level, but contractual relationships with suppliers are important. Transfer pricing considerations for fund groups are relevant for cross‑border services of the manager and the related administrator, and I recommend establishing a TP policy from day one. This reduces the risk of queries when obtaining tax residency and during subsequent audits.

Timeline and stages for launching a VCC

Illustration for the ‘Timeline and stages for launching a VCC’ section in the article ‘Variable Capital Company in Singapore – structure for hedge funds 2026’
The VCC registration timeline and launch stages depend on the readiness of the manager and investor documentation. In a standard COREDO project we complete this in 6–10 weeks from decision to first subscription:

  • Weeks 1–2: VCC architecture and fund structure 2026, selection of RFMC/CMS, appointment of directors, start of KYC on beneficiaries, preparation of constitutional documents.
  • Weeks 2–4: filing with the RFMC or CMS (if required), arranging corporate services, preparation of the offering memorandum, subscription agreement, NAV policy and valuation, draft AML/CFT framework.
  • Weeks 4–6: opening bank and brokerage accounts, selection of administrator and custodian, setup of transfer agency and investor servicing, finalizing derivative ISDA/GMRA/prime brokerage arrangements.
  • Weeks 6–10: testing reconciliations and fund accounting, launching CRS/FATCA processes, data protection policy and cross-border data flows, final board approvals and first subscription.
We record the step-by-step VCC creation plan and launch timeline in a Gantt chart with responsibilities and checkpoints. This discipline shortens time-to-market and increases the chance of successful onboarding with prime brokers.

Operational blocks: AML/KYC and reporting

Operational reliability: a critical factor for VCC Singapore hedge funds. In COREDO projects I focus the team on the following modules:

  • Administration and accounting: an independent third‑party administrator, clear NAV policies, independent valuation and NAV procedures for illiquid/OTC. Reconciliation and fund accounting best practices, daily reconciliation with prime brokers, the custodian and the bank.
  • Prime brokerage and leverage: documenting prime brokerage and leverage arrangements, margin terms, haircuts, stress tests, derivatives clearing and collateral management. We include insurance and operational risk transfer where economically justified.
  • Transfer agency and investor relations: transparent subscription and redemption mechanics, processing side letters, control of gate provisions and side pockets. Maintaining the beneficial ownership register of the VCC and notice requirements for investors.
  • Compliance: AML/CFT controls for fund subscriptions, KYC and PEP screening procedures, transaction monitoring and sanctions screening. Integration with FATF recommendations for fund administrators and CRS/FATCA reporting obligations.
  • Internal controls: risk management framework for hedge funds, internal controls and compliance monitoring, internal audit and external audit requirements. We include cybersecurity: cybersecurity controls for fund managers and a policy on data protection and cross‑border data flows.
COREDO’s practice shows: if these blocks are described in the Offering Memorandum and the compliance policy, and then embedded in operations, MAS inspections are uneventful and investor ODD proceeds without delays.

Master-feeder: marketing in the EU and Asia

A VCC’s compatibility with a master‑feeder structure is a proven solution for geographic marketing. Often the VCC acts as the master, and the European feeder is managed by an AIFM under the applicable AIFMD. Alternatively, a feeder‑VCC with a master in another jurisdiction is possible, but for institutional investors a Singapore master is convenient from a reporting and DTA perspective.

Marketing funds to EU and Asian investors requires compliance with local rules. In the EU – NPPR under AIFMD, operating through a licensed AIFM and controlled distribution channels. In Asia, a country‑by‑country approach: onshore vs offshore domicile decision factors and passporting alternatives. The COREDO team configures distribution channels so as not to cross the line «offering to the retail public», if the strategy is strictly professional.

Within a master‑feeder we model withholding tax, operational liquidity between levels and NAV cut‑off in advance so that the feeder level does not «break» the timing logic of the master. This is especially important for high‑frequency trading and the use of complex derivatives.

Cayman vs VCC: which wins when

The VCC vs Cayman question comes up in about every other hedge fund project. Cayman historically dominated as an offshore SPV, but the trend is shifting toward regulated onshore structures. VCC has tax advantages with 13R/13X, a network of DTA, a clear MAS regime and economic substance — arguments in favor of Singapore. On the other hand, Cayman can remain attractive for certain strategies, especially when there is an established pool of investors.

Cayman Islands vs VCC cost comparison in 2026 shows: setup for VCC is comparable or higher, but recurring compliance costs for VCC are often more predictable, and ROI improves due to tax efficiency, access to Asian investors and reduced frictions with banks and custodians. Operational due diligence for prime brokers also proceeds faster when the structure is onshore and regulated.

I’ve noticed that for funds with ESG integration and reporting, institutional fundraising and long-term plans, VCC offers a strategic advantage. For a short horizon and a limited circle of LPs, an offshore SPV sometimes still makes sense, but increasingly such managers view VCC as the next step.

How to change your domicile without incurring losses

Redomiciliation of funds to Singapore is becoming in demand in 2026. Liquidation and re-domiciliation of VCC can proceed under two scenarios: transferring the existing fund while preserving its history, or closing the old one and launching a new VCC with the transfer of assets. In both cases, notice requirements and investor disclosures, assessment of tax consequences, and coordination with counterparties (prime brokers, custodians, administrator) are important.

Winding up procedures for VCC sub‑funds allow closing individual strategies without collapsing the entire ‘umbrella’. This is a convenient tool for managers running multi-strategy funds and for investors who do not want to sell off the entire portfolio. The COREDO team builds roadmaps for the stages of winding down, including audit, final NAV, distribution and legal reporting.

Frequently asked questions from managers and investors

Should an existing Cayman hedge fund be converted to a VCC in 2026?

If the fund has institutional plans in Asia, a need for DTA and you are aiming for onshore residency, conversion makes sense. Weigh the cost of redomiciliation, tax savings and investor perception. Our experience suggests: a positive NPV most often appears on a 2–3 year horizon.

How does a VCC affect the fund’s ROI and operating expenses?

ROI benefits from tax incentives 13R/13X and reduced frictions with service providers. Operating expenses become more transparent: administration, audit, compliance, governance. In terms of OPEX/ AUM dynamics, especially after reaching critical mass, a VCC demonstrates competitive economics.

What compliance risks arise when managing a VCC from Europe or Asia?

Key ones are economic substance in Singapore, the correct license (CMS or RFMC), continuous AML/CFT and sanctions control, as well as data protection for cross‑border data flows. The solution: allocate functions so that the “reasonable management center” is in Singapore, and outsourcing does not replace core‑decision making.

How to organize a master‑feeder structure with a VCC and a European AIFM?

VCC as master, EU feeder under an AIFM with NPPR, a workable scheme. It’s important to synchronize NAV cut‑off, disclosures, KIDs/ PRIIPs (if relevant), as well as TP policy and cross‑border fee flows. The COREDO team designs documentation to meet both MAS and AIFMD expectations.

What risk management and NAV valuation measures are required for a VCC?

Documented NAV policies are required, independent valuations for illiquid/OTC, liquidity stress tests, counterparty and leverage limits, as well as regular reporting to the board’s risk committee. For derivatives: procedures for collateral management, variation/ initial margin and fair value models.

How does a VCC integrate with FATCA/CRS requirements and sanctions control?

A VCC registers as a Reporting FI, the administrator conducts KYC/AML, PEP screening, CRS/FATCA reporting, and sanctions screening is performed at subscription and on an ongoing basis. COREDO solutions use automated lists and triggers for transaction monitoring.

What restrictions are there on the use of derivatives and leverage in a VCC?

In the institutional/ accredited segment, there are no retail‑style restrictions, but there are requirements for risk management, liquidity and disclosures. Brokers and custodians also impose their own limits, which effectively become the risk cap.

Is an independent director and a depositary required for a VCC fund?

An independent director is highly desirable: it strengthens governance and passes investor ODD. A depositary is mandatory for retail funds; for professional funds, a custodian is required, and depositary functions can be handled through custody agreements and the administrator.

COREDO Case Studies: How We Solved the Challenges

Case 1: launches of two sub‑funds under a VCC for quant strategies.
Client: a European manager, targets – Asian LPs and prime brokerage in Singapore. COREDO developed a VCC sub‑fund segregated portfolio with market neutral and stat‑arb strategies, 13X, RFMC, an independent administrator and custodian. Result – launched in 9 weeks, successful ODD at two prime brokers, a positive track record and an expansion plan.

Case 2: redomiciliation from Cayman to a VCC while retaining investors.
Objective: reduce withholding on dividends and coupons through a DTA and enhance operational transparency. The COREDO team performed the redomiciliation, retransferred ISDA/GMRA, synchronized notice requirements and conducted a tax assessment. Within a year the client obtained a tax residency certificate and reduced the portfolio’s overall WHT.

Case 3: strengthening AML/CFT and sanctions screening at an existing VCC.
After a request from the bank the client approached us. The solution developed by COREDO included configuring KYC/PEP screening, ongoing transaction monitoring, updating policies in line with FATF and MAS guidance, implementing an incident‑management system and staff training. The bank confirmed compliance, and operational delays ceased.

Cost of a VCC in Singapore in 2026

Cost model: setup vs recurring compliance costs: the key to managing the fund’s P&L. Typically, initial costs include incorporation of the VCC, the manager’s licensing trajectory (CMS/RFMC), preparation of the Offering Memorandum and agreements, onboarding of the administrator and custodian, as well as legal and tax opinions. Recurring – administration and NAV calculation, audit, tax reporting, compliance-monitoring, corporate secretarial services and the board.

For an umbrella VCC the cost element scales by sub‑funds: each sub‑fund adds a share of administration, custodial accounting and audit hours. At the same time the scale effect with AUM usually reduces expenses relative to assets. COREDO’s practice shows that optimizing providers (administrator and custodian) and unifying NAV and reporting schedules reduce OPEX without loss of control.

Project plan with COREDO for the initial subscription

  • Diagnostics and target model: choose VCC vs alternatives, determine CMS or RFMC, assess the 13R/13X tax regime and economic substance requirements.
  • Fund architecture: umbrella vs single‑fund, share classes, liquidity management, side pockets, gate provisions, NAV policy and valuation.
  • Providers: third‑party administrator selection criteria, custodian and fund administration requirements, auditor selection, cybersecurity and data protection.
  • Documents: offering memorandum, subscription agreement, AML/CFT policy, sanctions screening, CRS/FATCA, VCC beneficial ownership register.
  • Integration with brokers and banks: prime brokerage, derivatives clearing, collateral management, reconciliation and accounting.
  • Marketing and compliance: AIFMD/NPPR for the EU, Asian channels, notice requirements and investor disclosures, ESG integration (on LPs’ request).
  • Launch and monitoring: test‑set, first subscription, board reports, internal audits, readiness for MAS inspections and enforcement trends.
The COREDO team runs the project on a turnkey basis, but I always leave the manager in control of key decisions. This is your fund, and governance should work for you and your investors.

VCC — a long-term vehicle

Variable Capital Company Singapore – this is not just a legal wrapper, but an institutional-grade platform for hedge funds ready to play the long game. The liquidity and variable capitalization of the VCC, sub‑fund segregation, tax incentives 13R/13X, compatibility with master‑feeder structures and the strict but predictable oversight of the MAS create the foundation for sustainable growth. Yes, there are requirements for economic substance, governance and compliance. But that is exactly what investors and counterparties like — and what adds value to your brand.

If you are wondering how to register a VCC for a hedge fund in Singapore, which licensing regime to choose, how to ensure economic substance for the VCC’s tax efficiency and how to build an operational model without “bottlenecks”, I am ready to discuss your case in detail. COREDO’s experience in the EU, the UK, Singapore and Dubai helps connect the tax, regulatory and operational dimensions into a single strategy. In the outcomes, discipline, transparency and speed matter — and those are precisely what we rely on every day.

Since 2016 I have been heading COREDO and every day I see how one discipline changes the resilience and value of businesses in Europe, Asia and the CIS: a competent whistleblowing program in fintech. It has long ceased to be a “compliance box” and has become an element of corporate governance that affects Licensing, access to banking infrastructure, cost of capital and customer trust. The COREDO team has implemented dozens of deployments for payment organizations, neobanks, crypto platforms, brokers and companies building multi-jurisdictional structures in the EU, the UK, Singapore and Dubai. Below is my practice summary: what the EU directive requires, how to launch a system in 8–12 weeks, where the ROI is, and how to scale solutions across an international group.

Why fintech needs a whistleblowing program

Illustration for the section “Why fintech needs a whistleblowing program” in the article “Whistleblowing in fintech — how to implement a complaints system under EU directives”

Fintech companies operate under increased scrutiny from regulators and payment infrastructure. Payment licenses, PSD2 processes, EBA Guidelines on governance, AML/CTF frameworks and operational resilience requirements converge on one point: the ability to quickly detect and remediate breaches. An internal whistleblower program provides a controlled early-warning channel, not a stream of leaks to social media and journalists.

Our experience at COREDO has shown: a properly designed reporting system for violations reduces the average time to detect an incident by 40–60%, and the total damage from fraud and fines by tens of percent. The economic efficiency of a reporting program is reflected in prevented losses, reduced compliance costs (especially audits and consulting), and increased investment attractiveness — investors are more willing to back companies with a mature compliance landscape.

Regulatory framework: directives and laws

Illustration for the section «Regulatory framework: directives and laws» in the article «Whistleblowing in fintech – how to implement a complaints system under EU directives»

EU directive on the protection of whistleblowers 2019/1937 obliges organizations with 50+ employees, as well as companies from regulated sectors, to establish internal reporting channels and protect whistleblowers from reprisals. Employer obligations under the EU directive include:

  • a secure and accessible internal channel (including anonymous reporting channels where permitted by national law);
  • appointing persons responsible for processing reports and conducting internal investigations;
  • response to a complaint: acknowledgement of receipt within 7 days and final feedback within 3 months;
  • a non‑retaliation policy and legal mechanisms to protect whistleblowers.

National implementing laws in EU countries introduce details: in some places anonymity is explicitly encouraged, in others it is left to the company’s discretion. COREDO’s practice confirms: even where anonymity is not mandatory, the market (banks, partners, auditors) regards anonymous channels as best practice.

In the United Kingdom the FCA expects mature whistleblower protection procedures (including a “whistleblowing champion” for large firms; see SYSC 18). For payment and banking groups, the EBA Guidelines on internal governance and reporting expectations apply: a corporate whistleblowing policy is considered part of the internal control system. PSD2 strengthens requirements for operational incidents and security; an effective complaints system helps to detect and document them.

GDPR and the protection of whistleblowers’ personal data form a mandatory framework. A correct legal structure relies on a combination of “legal obligation” and “legitimate interest”, data minimisation and pseudonymisation, restricted access and controlled retention periods. For cross‑border transfers of complaint information outside the EEA we take Schrems II into account: standard contractual clauses (SCCs), transfer risk assessment, and cryptographic protection. In the absence of a complaints system and data protection, a company faces legal risks and fines: national sanctions for non‑compliance with the EU directive and penalties for compliance breaches in the EU under the GDPR.

Architecture and technologies of a mature system

Illustration for the section «Architecture and technologies of a mature system» in the article «Whistleblowing in fintech – how to implement a complaints system under the EU directives»

I describe a reference target architecture that the COREDO team develops for fintechs.

  • Channels: protected feedback forms (web), secure drop, hotline with recording, mailbox, channel for third parties (external channel for complaints by a third party: external reporting). For anonymity we use end-to-end encryption of messages, the ability to upload files, metadata and the degree of pseudonymization.
  • Case management: tools for case management allow registering, routing and investigating reports; important are automation of complaint triage, prioritization of incidents and SLAs for response. Role separation (RBAC), access control and privilege separation are mandatory.
  • Information security: ISO 27001 and SOC 2 standards for whistleblowing providers; PCI DSS is relevant if investigations involve payers and elements of payment data — then we design a strict separation of environments. Audit log and data integrity control, logging and auditing of actions in the system, chain of custody of digital evidence: without these, investigations and e-discovery risk failing in court.
  • Submission technologies: external whistleblowing provider (SaaS) versus on-premise. SaaS speeds up the launch and covers multi-jurisdictionality, but requires legally correct data transfers (DPA, SCCs, list of subprocessors). On-premise gives maximum control and may be justified for banks/exchanges. The solution developed by COREDO for one payments group combines a SaaS portal for the employee and an on-prem evidence repository.
  • ML/NLP: we apply ML/NLP capabilities for classifying complaints and identifying systemic risks cautiously: automatic scoring for triage, thematic clustering, highlighting PEP/sanctions triggers, but with a constant human-in-the-loop. Machine learning for identifying fraud patterns works well together with AML alerts data.

Integration of AML and KYC

Illustration for the section «Integration of AML and KYC» in the article «Whistleblowing in fintech — how to implement a complaints system under EU directives»

Integration of whistleblowing with AML and KYC turns reports into operational signals for monitoring. Customer and employee complaints often highlight weak spots: fake accounts, trade in «mules», incompetent EDD, breaches of sanctions policy. In COREDO’s practice, a support operator’s complaint helped identify a limit‑circumvention scheme in a neobank; linking the complaint to the TM system reduced time‑to‑block to hours.

KYC processes and the impact of complaints on monitoring are expressed in three streams:

  • risk re-scoring of the client and segment;
  • cases about employees and contractors (third‑party risk) → review of access and functions;
  • escalation to the FIU when signs of money laundering are detected.

AML compliance and interaction with complaints require clear procedures for dividing responsibilities among the CCO, DMLRO and the investigations team, to avoid conflicts of interest.

Implementation in a fintech company: step-by-step

Illustration for the section «Implementation in a fintech company: step-by-step» in the article «Whistleblowing in fintech – how to implement a complaints system under EU directives»

I distilled the key steps into a practical roadmap. The COREDO team typically completes the rollout in 8–12 weeks for a startup and 12–16 weeks for a mature PSP.

  1. Diagnostics and architecture
    • compliance audit of the directive at the group level;
    • map of jurisdictions and assessment of international delineation for complaints;
    • data protection impact assessment (DPIA) for whistleblowing;
    • choice of model: SaaS vs on‑premise, requirements for end‑to‑end encryption, secure drop.
  2. Policy and documentation
    • template of internal policy on whistleblowing for fintech: objectives, scope, channels, roles and responsibilities (DPO, CCO, CRO, CTO), timelines 7 days / 3 months, non‑retaliation, data retention, interaction with EU regulators;
    • corporate documentation: regulations, investigation procedures, incident response plan and business continuity;
    • anti‑corruption policy and reports of violations – align with the overall compliance framework.
  3. Technological implementation
    • provider selection and licensing, contracts with service providers, DPA and SCCs;
    • integration with ERM/CRM/HR systems, RBAC configuration, audit log;
    • testing of logging, integrity control, chain of custody, WORM storage.
  4. Processes and SLA
    • legal assessment of complaints and triage: classification of legal significance, conflicts of interest, routing;
    • SLA for responding to reports, KPI time‑to‑resolution, % of confirmed complaints;
    • internal investigation protocol for reports of violations, forensic investigation, e‑discovery.
  5. Training and communications
    • training of staff and awareness raising (awareness) with a focus on non‑retaliation;
    • communication strategy for employees and stakeholders, multilingualism, FAQ;
    • external channel for complaints from clients, partners and counterparties.
  6. Pilot and launch
    • control period with parallel manual duplication, «hotline» for questions;
    • preparation for external audits and regulator inspections, dry‑run with internal audit;
    • reporting to the board of directors (board oversight), corporate governance and whistleblowing in one package.

Cross-border data and Schrems II

Scaling a program across multiple jurisdictions creates three types of challenges: legal, technical, and managerial. Managing multijurisdictional privacy requires local addenda to the policy, local case managers, and central coordination for cross-border matters. How to ensure cross-border transfer of complaint data? We use SCCs, encryption “in transit” and “at rest”, pseudonymization and data minimization, as well as technical measures for Schrems II (key management in the EEA, provider’s lack of access to the keys).

GDPR requires a DPIA for high-risk processing. A data protection impact assessment (DPIA) is not a formality but a living risk matrix and set of safeguards. In COREDO projects we include retention period controls, anonymization procedures, an access register and periodic review of TIAs for countries outside the EEA.

ROI and performance metrics

The assessment of ROI for implementing a whistleblowing system is based on the following metrics:

  • cost‑per‑case, time‑to‑resolve, time‑to‑acknowledge;
  • % of confirmed complaints and repeat incidents;
  • prevented loss: avoided fines, losses from fraud, legal expenses;
  • indirect benefits: lower insurance costs, improved terms with correspondent banks, increased attractiveness to investors.

The cost of implementation vs savings from prevented violations in a typical PSP is recouped in 9–18 months. In one of COREDO’s cases, complaints from the front office exposed a cashback theft scheme; the prevented loss in the first six months exceeded the budget for a three‑year subscription to the SaaS platform.

COREDO case studies: neobank and PSP

Case study: implementation in a neobank. The company operated in several EU countries and in the United Kingdom, serving millions of customers. The goal was a single reporting system for employees, as well as an external channel for customers and partners. Scaling the whistleblowing system across the international group required decoupling local legal particularities from centralized case management. COREDO implemented a SaaS solution with an on‑prem evidence archive, E2E encryption, RBAC, integrations with HRIS and TM, and an ML module for prioritization. The board of directors received quarterly KPI reports, and «tone from the top» lowered barriers to reporting. As a result, time‑to‑resolution fell by 47%, and the % of substantiated complaints stabilized at a healthy 32–38%.

Case study: a PSP licensed in the EU with operations in Dubai and Singapore. Regulators expected strict oversight of contractors and third‑party risk. COREDO developed a corporate policy, connected an external third‑party complaints channel, set up chain of custody, e‑discovery, and procedures for cooperation with external investigative authorities. In one incident an internal complaint led to an AML escalation and the correct filing of reports with the FIU. The regulator’s review concluded without sanctions.

C-level liability in the absence of a system

Legal risks when there is no complaints system include sanctions for non‑compliance with the EU directive, refusal or restriction of a license, increased regulatory scrutiny and tougher terms from payment partners. Legal liability of C‑level executives for the absence of a complaints system is not theoretical: in several countries leaders may face administrative liability. Employment law and protection against employee reprisals cover dismissal, demotion, harassment and indirect sanctions; a non‑retaliation policy and employee protections must be documented and applied in practice.

The assessment of reputational risks in public investigations is obvious: leaks and publications shape a narrative that auditors, banks and investors later join. A whistleblowing system is a tool of governance and transparency, not a “complaints box”.

Criteria for choosing a provider

Recommendations for selecting a platform provider for complaints:

  • compliance with ISO 27001 and SOC 2 Type II, independent audits, pentest results;
  • end-to-end message encryption, secure drop, protected forms, no tracking;
  • audit log, integrity control, immutable storage of critical artifacts;
  • flexible RBAC model, segregated duties, delegation without revealing the informant’s identity;
  • API integrations with ERM/CRM/HR, SSO, SCIM;
  • transparent DPAs, list of subprocessors, options for data in the EEA, Schrems II compatibility;
  • SLA for availability and time-to-acknowledge, clear total cost of ownership.

Technical choices: SaaS vs on-premise. For most fintech startups SaaS is more practical due to speed, cost, and continuous updates. Banks, exchanges and custodians often choose on-prem or hybrid.

Interaction with the regulator: roles

Roles and responsibilities: DPO: data protection, DPIA and cross-border transfers; CCO: methodology, triage and engagement with regulators; CRO – embeds the results into the risk map; CTO – security and integrations; internal audit: independent review of effectiveness and fraud investigation. Board oversight: a mandatory part of corporate governance.

Issues of engagement with EU regulators and national authorities are resolved through protocols: when and how to escalate, who makes contact, which notification templates are used. European Banking Authority reporting requirements and EBA Guidelines help set the structure. FCA expectations on whistleblower protection in the UK are useful to incorporate even for firms operating only in the EEA – it improves discipline.

Anonymous vs Identified

Anonymity and pseudonymization of reports increase willingness to report, especially in hierarchical cultures or in distributed teams. The advantages of anonymity – more signals, less fear. Drawbacks: difficulty asking clarifying questions and the risk of abuse. A practical compromise: an anonymous channel with the option for two-way communication, pseudonymization in case management, and a clear filter for ‘noisy’ signals. A non-retaliation policy also applies to identified reports; this is an important marker of maturity.

Regarding reward models and whistleblower incentives in the EU: cash bonuses are not standard, but recognition, favorable development opportunities, and inclusion in ethics programs are possible. It’s important that the incentive comes from safety and confidence in the process.

Company integration and licensing

Registering a legal entity in the EU: the impact on compliance becomes apparent immediately. When opening bank accounts, obtaining licenses (payment services, forex, crypto), as well as when expanding into the UK, Singapore or Dubai, regulators and banks expect to see not only AML/KYC‑policies but also a functioning complaints system. The AML and corporate support services provided by COREDO include linking whistleblowing with sanctions policies, anti‑corruption, compliance risk management, and corporate ethics.

Fintech regulators: PSD2’s impact on processes leads to heightened oversight of security incidents and operational resilience. A complaints program reinforces readiness for incidents and business continuity plans (BCP).

Preventing Repeat Violations

Preventive measures and reduction of repeat violations depend on proper “closing the loop”: root cause analysis (root cause), action items, implementation controls and their verification by internal audit. Change management (change management) when implementing new controls and communications with employees reduce resistance and improve adoption.

Key performance indicators (KPIs) for the complaints program:
  • time‑to‑acknowledge and time‑to‑resolution;
  • % of confirmed complaints and depth of root cause analysis;
  • share of complaints that led to changes in policies/processes;
  • employee awareness level, training coverage;
  • ROI metrics: cost‑per‑case, prevented loss, time‑to‑resolve.

Forensics: evidence in court

Record-keeping and storage of evidence in accordance with the law: a foundational discipline. Internal audit and fraud investigations rely on the chain of custody, version control, hash sums, storage in secure containers, and segregation of access. Forensic investigations into internal breaches and e-discovery prepare the company for litigation; precise procedural logic increases the chances of a successful defense.

Timeline and stages of a startup and a mature group

Timeline and stages for implementing a complaints system for a fintech startup:

  • Weeks 1–2: diagnosis, DPIA, architecture.
  • Weeks 3–6: policy, contracts, SaaS configuration, integrations.
  • Weeks 7–8: training, pilot, launch, short audit.

For a corporate group:

  • Weeks 1–4: group framework, local addenda, DPIAs and TIAs.
  • Weeks 5–10: integrations, migration from local “inboxes”, training and communications.
  • Weeks 11–16: pilot in key countries, scaling, preparation for external audit.
COREDO’s practice confirms: when the board of directors personally supports the program, resistance decreases and metrics improve by 20–30%.

How COREDO helps

At COREDO we cover the entire cycle: from choosing a provider and building processes to integration with AML/KYC and preparation for regulator inspections. The COREDO team has delivered projects in the EU, Czechia, Slovakia, Cyprus, Estonia, the United Kingdom, Singapore and Dubai; this helps account for local nuances and partner bank requirements. For neobanks and PSPs a package is available: policies and regulations, DPIA and Schrems II compliance, integrations with HR/ERM/TM, training, a KPI dashboard and an annual effectiveness audit.

The solution developed at COREDO often includes an ML module for initial complaint classification, legal triage templates and escalation mechanisms to external authorities when necessary. We do not replace internal functions, but build a resilient system that is easy to scale to new jurisdictions and licences.

Recommendations for C-level executives on one page

– Assign ownership at the board level and designate responsible persons (DPO, CCO, CRO, CTO).

– Ensure a multichannel approach: internal and external channels, anonymity, two-way communication.

– Adopt a non‑retaliation policy and real protections for EU whistleblowers.

– Integrate the system with AML/KYC, HR and ERM; set up automation for triage and SLAs.

– Conduct a DPIA, configure cross-border transfers per Schrems II, data minimization and pseudonymization.

– Set up an audit log, integrity controls, chain of custody; prepare e‑discovery.

– Choose a provider with ISO 27001/SOC 2, E2E encryption and a clear DPA.

– Introduce KPI and ROI metrics; run a pilot and regular external and internal audits.

– Build a communication strategy and regular training; remember third parties and contractors.

– Keep a response and business continuity plan ready; update measures after each case.

Conclusions

Whistleblowing is not a mere box‑ticking requirement under the directive, but a management tool that protects licenses, turnover and reputation. Companies that take AML, KYC, data protection and complaints systems equally seriously gain in decision‑making speed, control quality and market trust. In a multi‑jurisdictional growth environment — from the EU to Singapore and Dubai — a unified, technological and legally sound whistleblowing program becomes a condition for scaling.

I support transparent, effective systems that bring benefits to business and people. If you are preparing to register a legal entity in the EU, aiming for a new financial license or want to strengthen corporate governance, embed whistleblowing into the architecture from day one. COREDO’s practice shows: a properly designed and honestly implemented program pays off, reduces risks and makes the company stronger – regardless of jurisdiction and stage of development.

I have been building COREDO since 2016 as a place where entrepreneurs receive not only company registration and licenses, but a comprehensive risk management strategy. During this time the COREDO team has implemented projects in the EU, the United Kingdom, the Czech Republic, Slovakia, Cyprus, Estonia, Singapore and Dubai and sees a common pattern: sustainable international growth is impossible without a risk-based approach (RBA) embedded in the process of registration, licensing, AML compliance and operational management.

My practical focus:

to make the company’s risk management understandable to the owner and measurable for the CFO. To do this I rely on a risk matrix, a clear risk appetite, KYC/CDD/EDD procedures and automated transaction monitoring. Our experience at COREDO has shown that a properly configured risk matrix reduces TTM when entering a market, lowers the cost of AML controls and increases the trust of regulators and banking partners.

Risks of international company registration

Illustration for the section «Risks of international company registration» in the article «Risk-oriented approach – building a risk matrix»

Registration in the EU, Singapore, the United Kingdom or Dubai: it’s about strategy. I consider a jurisdiction through the lens of business risk assessment: the regulatory regime (AMLD5/AMLD6 in the EU, EBA guidelines, standards FATF and Wolfsberg), the transparency of beneficial ownership registers, substance requirements, taxation, currency and cross-border risks, and GDPR when processing client data.
COREDO’s practice confirms the effectiveness of an approach in which the assessment of commercial and regulatory risk takes place before incorporation. For example, when launching a payments business in the United Kingdom we calculate in advance the impact of FCA requirements for safeguarding, governance and KYC/CDD, and for Singapore: MAS standards on AML/CFT and MPI/SPI licensing. For Cyprus (CySEC) it is important to consider the criteria for forex dealers, for Estonia — the current requirements for VASPs and substance, and for Dubai: VARA’s framework for virtual assets.

AML Compliance: from KYC/CDD to onboarding

Illustration for the section «AML Compliance: from KYC/CDD to onboarding» in the article «Risk-oriented approach – building a risk matrix»

A strong AML compliance is not a sales stop-factor, but a tool for safe growth. At COREDO we deploy KYC and CDD policy around risk-oriented client segmentation: low-threshold and high-risk clients receive different verification scenarios, different transaction monitoring rules and different SLAs. I always include in the scope:
  • the process of client identification and verification (e-KYC, biometrics, document verification and trusted registers);
  • verification of ultimate beneficial owners (UBO), including complex ownership structures and circumvention schemes (shell companies);
  • PEP screening and sanctions lists (OFAC, EU, UN) and sanctions control with regular updates;
  • source of funds and source of wealth, as well as assessment of counterparty and third-party risk (vendor Due Diligence).

The key to effectiveness is implementing RBA in AML processes.

I set risk scoring at the entry, disclose rules for segmenting clients by risk and determine where EDD is needed (Enhanced Due Diligence). For high-risk clients I strengthen monitoring, activate scenarios for layering/structuring/smurfing, increase the frequency of profile reviews and expand the list of documents.

Risk-based approach to onboarding

I start with a risk heat map for the product line and geography. Then I form rules:

  1. initial assessment of the client’s profile (inherent risk): country, industry, product, onboarding channel, type of transactions;
  2. assessment of control effectiveness: data quality, verification, sanctions filters, triggers;
  3. calculation of residual risk, determination of the level of checks (CDD or EDD), configuration of limits and thresholds.
The solution developed at COREDO allows synchronizing risk scoring with front-end onboarding and transaction monitoring. This eliminates the gap between sales promises and real AML requirements.

Risk matrix: building and calibration

Illustration for the section 'Risk matrix: building and calibration' in the article 'Risk-oriented approach – building a risk matrix'

The risk matrix is an operational management model, not a “check-the-box” document. I combine qualitative and quantitative methods: interval scales for risk factors (country, product, channel, client), a points-based risk scoring system (risk scoring), weighted ranking of risks and a risk heat map for visualization. I separate inherent risk and residual risk to see the effect of controls and prioritize improvements.
When building it I align the risk appetite and the risk matrix at the board of directors level. Then I form segmentation rules, KRIs, and threshold values for automated monitoring rules. The COREDO team configures threshold setting and tuning to reduce false positives and avoid blind spots, taking into account the cost of errors: false positives vs false negatives and their economic consequences.

Risk matrix for a legal entity in the EU

I use sources: requirements of AMLD5/AMLD6, EBA guidelines, local FIU rules, Wolfsberg practices. I define the risk taxonomy: customer, product, geographic, distribution channels, operational and regulatory. I assess probabilities and impact using probabilistic models and scenario analysis, and include stress-testing for high-risk segments.

Next, scaling. For example, country by FATF and local lists, industry by historical frequency of incidents, product by level of anonymity and speed of funds turnover, channel by presence controls. I obtain a risk heat map, approve thresholds for CDD/EDD and the review frequency of profilers.

Risk matrix for an international group

In an international group I maintain common principles and local adaptation. The group level sets the baseline risk appetite and minimum KYC standards/CDD/EDD. Subsidiaries in Estonia and Cyprus inherit the matrix but receive local weights and data sources. In the UK I add FCA emphases, in Singapore – MAS, in Dubai, VARA. This model preserves comparability of metrics and covers multi-jurisdictional risk.

Client risk scoring and residual risk

I set the formula:


Risk Score = Σ(weight_i × factor_i)

where factor_i are normalized values for country, product, channel, customer profile, counterparties and transactional patterns. For residual risk I apply the model:


Residual Risk = Inherent Risk × (1 − Control Effectiveness)

Control effectiveness is calculated based on backtesting results, precision/recall and FPR for monitoring rules.

I use Explainable AI so the model’s transparency holds up in an audit. The COREDO team performs calibration, comparing ROC/AUC and the alerting economics, and adjusts threshold optimization taking into account the cost of errors and investigation resources.

Thresholds for moving a client into high risk

I rely on risk appetite and operational capacity. Above the critical threshold the client moves into the elevated risk segment and receives EDD: an expanded document package, an in-depth analysis of source of wealth, additional sanctions and PEP checks, limits and enhanced monitoring. For low-threshold clients the thresholds are softer, SLAs shorter, but with control of transactional anomalies.

RegTech: data lineage and Explainable AI

Illustration for the section «RegTech: data lineage and Explainable AI» in the article «Risk-oriented approach – building a risk matrix»
Automation delivers the greatest impact when the business owns its data. I implement normalization and consolidation of data from different jurisdictions, ensure data lineage, build unified reference directories and data quality controls. As RegTech layers I use graph analytics and entity resolution to uncover hidden connections and structures, machine learning to detect anomalies, and orchestration of investigations in case management.

Automated transaction monitoring rules derived from the matrix cover key scenarios: structuring, layering, smurfing, evasion schemes and cross-border anomalies. I build human-in-the-loop verification so that analysts augment ML signals with their expertise. Model risk management includes backtesting, calibration of scoring models and regular parameter reviews.

Data sources for the risk matrix

I use a combination: sanctions lists and PEP registers, corporate registries and beneficial owner registers, verified e-KYC providers, transaction logs, internal customer profiles and external negative news. For data quality I apply deduplication, name standardization, geo-normalization and completeness checks. GDPR and local data protection in the EU are mandatory requirements for architecture and processes.

Transaction monitoring and false positives

First I create baseline rules by risk segments and jurisdictions, then perform iterative tuning. I measure precision, recall, FPR, AUC, calculate the cost of empirical errors and adjust thresholds taking team capacity into account. I reduce false positives by combining contextual attributes and graph features, which improves signal quality without loss of sensitivity.

Orchestration of investigations in GRC

I integrate the risk matrix and AML processes into the corporate GRC platform to provide a unified control cycle: planning – monitoring – adjustment. In case management I build workflows with an escalation matrix and SLAs, automate SAR (Suspicious Activity Report) preparation and interaction with the FIU, and add dashboards for KRIs and KPIs of the compliance unit.

How to manage the board of directors’ risks

Illustration for the section 'How to manage the board of directors' risks' in the article 'Risk-oriented approach – building a risk matrix'
The strategy begins with risk appetite. The board approves risk limits, target KRIs, and the budget for controlled automation. Then I document roles and responsibilities: risk owners in business lines, compliance as the second line of defense, internal audit as the third. I regularly prepare risk reporting for management and the board of directors with a heatmap, incident trends and control economics.

Structure of the risk-oriented approach

The policy covers: risk taxonomy and risk universe, quantitative and qualitative assessment methods, rules for client segmentation by risk, KYC/CDD/EDD procedures, sanctions screening, transaction monitoring, rules for threshold setting and tuning, third-party control and vendor due diligence, governance models and escalation matrix.

Documentation, control and audit testing

I establish a mandatory audit trail, requirements for documenting risk assessments and evidence of client ranking. Testing the effectiveness of controls (control testing) is carried out according to the plan, with a sample of cases, backtesting, threshold calibration and model adjustments. Regular internal and external audits confirm process maturity and readiness for regulator inspections.

Change management

I maintain regular trainings on AML, scenario analyses and working with systems. Change management includes the approval process for new products (compliance by design), migration to the cloud or on-premise, TCO analysis and scalability for multi-jurisdictional business.

COREDO cases: international launches

One of our recent projects, Licensing of a crypto service in Estonia. The COREDO team built a risk matrix based on AMLD5/AMLD6, integrated e-KYC and graph analytics for UBOs, included PEP and sanctions lists, and configured EDD for high-risk clients. We demonstrated a mature RBA to the regulator and agreed on an internal control plan and regular testing.

In the UK I supported the team in obtaining a payment institution license. We built a risk heat map by product, agreed on safeguarding and SAR process orchestration, implemented Explainable AI for scoring and carried out backtesting of rules. As a result, the business gained transparent onboarding, performance metrics, and stable interaction with banks.
In Cyprus we launched a forex broker under CySEC. The solution developed at COREDO included counterparty risk assessment, monitoring scenarios for suspicious schemes, threshold tuning taking market volatility into account, and EDD for clients from high-risk jurisdictions. We proved the economics of compliance: reduced FPR while maintaining high recall and controllable investigation times.
In Singapore we helped a fintech with a MAS license. I integrated risk-based processes into the product lifecycle, implemented third-party controls and vendor due diligence, performed data normalization across different geographies, and ensured compliance with GDPR and local data protection requirements. For Dubai we adapted the matrix for VARA, accounted for the specifics of virtual assets and the provider’s risk management requirements.

The economics of compliance: ROI and TCO

I view compliance as an investment in reliability. Assessing the ROI from implementing a risk-based approach includes reducing the share of false positives, decreasing manual workload, speeding up onboarding, and increasing the share of customers who pass initial screening. Total Cost of Ownership changes when moving to the cloud. At the same time, on-premise retains an advantage when data control requirements are high. The COREDO team helps choose an architecture taking into account KPIs, SLAs, budget, and regional constraints.
Scaling risk-based processes as the business grows requires centralization of methodology and local teams for execution. I evaluate outsourcing AML services vs an in-house team, and build a hybrid model to support peak loads and standardize quality. This approach speeds up the launch of new jurisdictions and maintains a consistent level of maturity.

Roadmap for implementing RBA in 90 days

First 30 days: diagnostics.
I document the risk appetite, build the initial risk matrix, describe KYC/CDD/EDD, assess data quality and sources, create an automation plan and quick wins. Meanwhile the COREDO team configures basic sanctions and PEP processes and prepares policy templates.

Days 31–60: design and pilot.
I run risk scoring, integrate onboarding and transaction monitoring, enable case management and the escalation matrix, configure KRI dashboards. We carry out backtesting, threshold tuning and train the investigations team.

Days 61–90: production environment.
I expand rule coverage, introduce regular control testing, approve risk reporting to the board of directors, finalize the audit trail and the SAR/FIU procedure. After that, quarterly calibrations and an annual scenario analysis with stress tests.

Questions from leaders: recommendations

How to align risk appetite and the risk matrix?

I start with the business strategy: geography, products, channels. Then I set acceptable risk levels and translate them into controllable KRIs. The board approves thresholds, and business lines receive clear rules.

How to assess third-party and vendor risks?

I conduct vendor due diligence: corporate registries, UBO, sanctions, PEP, data quality control and SLAs, scenario analysis of incident impact. For critical vendors, EDD and regular review.

How to adapt the risk matrix to EU and Asian legislation?

I build the core of the matrix, then add local weights and sources, taking into account guidance from FATF, EBA, MAS, VARA and local FIUs. This approach preserves comparability and covers local requirements.

How to manage false positives in transaction monitoring?

I combine rules and ML, use graph features, perform calibration on precision/recall/FPR, calculate the economics of errors and adjust thresholds to the team’s SLA. Human-in-the-loop reduces the risks of incorrect automation.

What resources are needed at the RBA implementation stage?

A methodologist, data lead, transaction analyst, integration engineers, compliance officer and a business representative. The COREDO team covers roles for key modules to speed up deployment and transfer the practice to the internal team.

A reliable partner for complex challenges

I build COREDO as a partner that takes on not only company registration and obtaining licenses, but also real responsibility for risk management. When a company enters a new market in the EU, Singapore, the UK or Dubai, I provide a structured RBA: a risk matrix, effective KYC/CDD/EDD, automated monitoring, GRC integration and measurable reporting. This approach creates resilience to regulatory requirements, increases the trust of banks and investors and accelerates scaling.

If you are planning a launch in a new jurisdiction, preparing a crypto, payments or forex license, building AML compliance or reviewing your current risk matrix, the COREDO team is ready to offer a practical solution. I am responsible for the architecture and strategy, colleagues handle methodology and implementation. As a result you get a transparent process, time savings and confidence in every subsequent step.

Over ten years of work I regularly hear the same request from capital owners and their managers: give a structured and practical approach to AML compliance in Luxembourg so that a family office can grow calmly, open accounts and conduct transactions unhindered in Europe, Asia and in the CIS markets. I built COREDO in 2016 as a comprehensive support platform: from company registration and obtaining financial licenses to AML consulting and audit support. Today I summarize our approach to anti-money-laundering compliance in Luxembourg – the center of the European private banking industry and family capital.

Family office in Luxembourg and AML

Illustration for the section «Family office in Luxembourg and AML» in the article «AML requirements for Family Offices in Luxembourg»

In COREDO’s practice there are two basic models: a private (single-family) and a professional (multi-family) office. The first serves a single beneficiary cluster and usually does not require a CSSF licence until it provides regulated services to third parties. The second serves several families and already approaches the status of a professional participant of the financial market (often – category PFS), which includes full AML requirements and supervision in Luxembourg.

The key question is whether family offices must be registered as financial institutions in Luxembourg. The answer depends on the actual services: investment advisory to third parties, asset management, trust administration, company formation and provision of a registered address (TCSP activity): all of this can bring the office under CSSF supervision and impose anti-money laundering obligations on family offices. Even the single-family model falls under Luxembourg’s anti-money-laundering legislation if it performs functions classified as “obliged entities” under the AML law (for example, the formation of trusts and holding structures).

When launching or restructuring a family office I always start with the legal qualification of the activity. How a family office is classified under Luxembourg law is the foundation on which compliance design, roles, reporting and interaction with the regulator depend.

Regulatory framework: laws and standards

Illustration for the section «Regulatory framework: laws and standards» in the article «AML requirements for Family Offices in Luxembourg»
Anti-money laundering legislation of Luxembourg is based on the Law of 12 November 2004, which implements AMLD5 and AMLD6 and takes into account the recommendations of FATF. The role of the CSSF in AML for a family office is critical if the office falls under supervision as a PFS: the regulator publishes CSSF recommendations on AML, circulars on internal control, KYC/EDD procedures and risk management.

Financial intelligence – Cellule de Renseignement Financier (CRF), the national FIU. Offices file mandatory SAR reports in Luxembourg to the CRF when suspicious transactions are identified. EU sanctions lists, OFAC and global sanctions screening become part of daily screening. At the same time GDPR and data retention requirements, CRS and FATCA for the exchange of tax information, as well as DAC6 – for reporting on cross-border tax arrangements, affect compliance design.

Private investment structures of family offices, SICAR and SIF – require increased attention to AML policies. Fund structures and AML consequences go hand in hand: formalisation of investor KYC procedures, registration of beneficial owners (central UBO register) and ongoing monitoring of sources of funds: mandatory elements.

Family office AML obligations

Illustration for the section «Family office AML obligations» in the article «AML requirements for Family Offices in Luxembourg»
COREDO’s practice confirms: a strong AML framework is built around four pillars: KYC, risk assessment, monitoring and reporting.

  • Know Your Customer policies. We build KYC requirements for a Family Office in Luxembourg around real processes: identification, verification, document collection, address confirmation, checking source of funds and source of wealth (SoF/SoW). Which documents are needed for KYC of a private investor in Luxembourg: passport/ID, address, tax residency declaration, confirmation of source of funds (sale of a business, dividends, inheritance), corporate package for structures.
  • Ultimate Beneficial Owner (UBO) verification for a family office. Analysis of ownership and beneficiary chains, cross-check with the central UBO register (RBE), documenting control links and trust agreements. We use graph databases to accelerate analysis of complex structures and reduce errors.
  • PEP screening for the family office and sanctions screening. Integration of sanctions lists screening into family office processes: EU, OFAC, HMT, as well as PEP screening and PEP data sources. We implement risk scoring and review frequency by risk classes.
  • CDD and EDD for the family office. Basic Due Diligence (CDD) for low and medium risk and enhanced due diligence (EDD) for complex cases: complex trust structures, offshore chains, PEP status, high-risk geographies, unusual flow patterns. When to apply enhanced due diligence (EDD) — family office cases: entry of a high-risk partner into a private deal, investments through an opaque SPV, large transactions with intermediary funds.
  • Transaction monitoring procedures for a family office in Luxembourg. Setting thresholds for SAR and criteria of suspiciousness in Luxembourg, AML risk scenarios in private investments (back-to-back loans, prepayments without commercial basis, atypical circular payments, closing a deal through an opaque crypto exchange wallet), documenting decisions and escalation.
  • Requirements for internal control and AML policy. Policies and procedures, risk appetite and risk matrices, client risk assessment and grading (risk scoring), onboarding regulations for high-net-worth individuals, role responsibilities: compliance officer/MLRO, secondary roles RC/RR (if applicable), DPO and their interaction.
  • Requirements for maintaining a register of beneficiaries in Luxembourg and retention: retention and archiving of KYC documents for 5–10 years depending on status, data storage requirements and retention periods in AML procedures, segregation of access to data.

How to implement AML in a family office

Illustration for the section «How to implement AML in a family office» in the article «AML requirements for Family Offices in Luxembourg»
Our experience at COREDO has shown that a successful program is built on a clear logic: «diagnosis – design: implementation – improvement».

  • Diagnosis. Assessment of the business model, mapping of products and channels, inventory of jurisdictions, gap analysis against AMLD5/AMLD6, CSSF guidance and FATF. Registration of the family office and AML risks are evaluated from the start, including «when a family office falls under AML regulation in Luxembourg».
  • Design. Development of an AML policy and internal controls (internal controls), KYC/EDD procedures, risk assessment at the client, counterparty and transaction levels, scenarios for a transaction monitoring system, integration of AML into corporate governance and regulatory notifications and timelines.
  • Implementation. KYC automation: OCR, APIs and integrations; electronic client identification (eID) and AML; connecting tools for sanctions screening, KYC providers and data aggregators; SIEM setup for event logging; incident response procedures and an AML crisis plan.
  • Improvement. Metrics for AML program effectiveness (KPIs), evaluation of ROI from implementing AML technologies, cost-benefit analysis of compliance, management of false-positive alerts and handling false positives, regular horizon scanning of regulatory changes and adaptation of the AML policies of the family office.

Technologies: RPA, AI and graph analytics

Illustration for the section «Technologies: RPA, AI and graph analytics» in the article «AML requirements for Family Offices in Luxembourg»
The solution developed at COREDO for one of the European offices demonstrated how the move from manual KYC to RPA/AI solutions in family offices reduces onboarding time from weeks to days. We integrated OCR for passport recognition, APIs to registries and sanctions lists, a workflow engine for escalations and digital approvals.

The implementation of automated transaction monitoring in family offices, based on machine learning and SIEM, makes it possible to adapt threshold values for transaction monitoring to the client’s actual profile. The use of machine-learning-based transaction monitoring in a family office and technologies for transaction analytics and graph databases helps uncover complex SPV chains and the indirect impact of sanctions. Management of false positives is built through risk segmentation and model training, as well as manual second-line review for sensitive alerts.

The use of KYC platforms in a family office: the economic justification is measured by a combination of indicators, a TCO breakdown (licenses, integrations, support), reduction in verification time, reduction of operational errors and improvement in SAR quality. A cost-benefit analysis (ROI) of implementing AML technologies in a family office provides a clear picture when scaling.

GDPR and AML: data and privacy

Data privacy vs AML: a frequent source of questions. The impact of GDPR on AML procedures of a family office requires clear legal bases for processing (legal obligation, public interest), data minimization, limited access and logging. The roles of the DPO and compliance officer in the family office structure synchronize privacy and AML processes: access matrices, DPIA for new technologies, retention and scheduled deletion.

Data storage and retention period requirements in AML procedures typically provide for keeping KYC files for 5 years after the end of the relationship (longer for investigations). We implement secure archives, encryption, regular recovery tests, as well as regulations for cross-border data transfers when facing multi-jurisdictional compliance challenges.

Reporting and interaction with the CRF and the CSSF

Mandatory SAR reports in Luxembourg are filed with the CRF when a transaction or client behavior meets the criteria for suspicious activity. We configure rules for detecting suspicious activity (SARs) by jurisdiction, counterparty type, atypical amount/frequency and source of funds. Internal investigations and interactions with the CRF in Luxembourg are documented with checklists so that every decision has supporting rationale and a timeline.

Preparing for CSSF AML audits in a family office includes sample testing, walkthroughs of KYC files, checks of sanctions screening and transaction monitoring logs. The COREDO team has implemented ready-made playbooks for inspections: who is responsible, which reports we export, how we document remediation.

Funds, M&A and correspondent banking

AML policy for private investment structures of family offices covers SICAR, SIF, SPF and SPV chains. The practice of due diligence on investor onboarding requires validation of SoF/SoW, verification of powers of attorney and trust structures, vendor due diligence for managers and advisers (AML due diligence for managers and asset managers of family offices). Compliance control when accepting new family assets and structures prevents subsequent account freezes.

AML control for cross-border private deals and M&A takes into account DAC6 triggers, sanctions risks, CLS windows, escrow schemes and PPAs. Managing the risk of de-validation of counterparties and correspondent banking is important for the ability to execute large transfers: banks expect transparency on UBO and payment chains, pre-agreed KYC packages and CRS/FATCA statuses. De-risking scenarios and loss of banking access for family offices often arise from inconsistencies in KYC and sanctions screening: we minimize such scenarios by proactive preparation and cooperation agreements with banks and intermediaries.

COREDO case studies: how we build compliance

  • Case: implementation of an AML program in a European family office. The client, a multi-family structure in Luxembourg managing private funds (SIF) and direct investments in the EU and Asia. We conducted a risk assessment, classified clients, implemented KYC/EDD procedures, integrated sanctions screening and a transaction monitoring system. During the first quarter onboarding metrics improved, SAR processes received clear criteria and a timeline, and the CSSF review passed without remarks.
  • Sanctions case: integration of OFAC and EU sanctions filtering into investment committees. The COREDO team set up pre-trade screening and post-trade monitoring, defined threshold events for escalation. The office implemented instant “stop-list” rules upon sanctions updates and graph analytics for indirect ownership.
  • Automation case: transition to RPA/AI in KYC. Implementation of OCR and APIs to registries, workflows for EDD, automated risk scoring. ROI manifested in reduced manual work, fewer false positives and faster approvals without compromising quality.
  • Audit case: preparation for a CSSF inspection. We conducted a pre-audit, trained staff, updated UBO registers, and worked through a SAR case study. Auditors noted the maturity of processes and control points.

Anti-money laundering outsourcing for family offices

AML outsourcing for family offices gives access to expertise, accelerates the start, reduces CAPEX on technology and lowers the risk of missing regulatory changes. I always note that outsourcing compliance functions and responsibility are different things: managers retain fiduciary duties and legal responsibility for AML violations.

Evaluating AML service providers: selection criteria for family offices include jurisdictional experience, technological integrations, SLA, independence, staff training plans and readiness for multi-jurisdictional compliance challenges. Practical value increases if the provider offers horizon scanning, a crisis plan and support in communications with banks.

Metrics and cost of compliance

Pricing of compliance services for family offices, cost benchmarks and ROI depend on the office model, geography, number of counterparties and transaction volume. Costs are made up of licenses for screening and transaction monitoring systems, integrations, training and regular audit samples. I look at AML program effectiveness metrics: onboarding time, share of EDD cases, level of false positives, incident response speed, completeness of KYC files, quality of SARs and results of external reviews.

Cost-benefit analysis of compliance shows that investments pay off through stable access to banks, transaction predictability and reduced regulatory risk. The long-term consequences of AML non-compliance for a family office’s reputation are far more expensive than any implementation.

AML Readiness Roadmap

  • Days 1–30: legal qualification of activities, gap analysis against AMLD5/AMLD6 and CSSF, risk assessment, design of policies and roles, selection of a KYC/sanctions provider, data plan taking GDPR into account.
  • Days 31–60: implementation of KYC/EDD procedures, integration of sanctions screening, basic rules of transaction monitoring, staff training, launch of SAR workflow, registration of processes for maintaining a central UBO register.
  • Days 61–90: optimization of thresholds and scenarios, configuration of CRF reporting, CSSF audit test, stress test of the crisis plan, finalization of KPIs and dashboards, approval of regulatory notifications and timelines.

This roadmap is universal yet flexible. The COREDO team can adapt it for family offices of any complexity — from single-family offices to multi-level structures with funds and international SPVs.

Questions of owners and managers

  • AML requirements when accepting investment funds in a family office. We verify the source of funds, reconcile amounts and sources with the investor’s profile, check transactional paths, and apply EDD in complex cases.
  • Registration of beneficial owners and central UBO register. We reconcile data with corporate documents, trust agreements, and update records upon changes.
  • CRS and FATCA impact on reporting. We synchronize KYC collection with tax forms, correctly determine tax status, and introduce control dates.
  • impact of EU sanctions and international lists on family office investment decisions. The investment committee receives a sanctions report prior to a transaction and post-trade monitoring, with reporting to compliance.
  • Counterparty checks (vendor due diligence). We use provider risk scoring, verify licenses and regulatory status, and analyze media risks and court records.

Culture of compliance and accountability

Legal liability of family office managers for breaches of AML, AMLD5 and AMLD6 compliance: a matter of personal and institutional risk. I always place a culture of compliance at the core: AML training and personnel testing, incentives and personal accountability of managers, regular refresher sessions and knowledge checks.

Role structure of compliance in a family office: clear responsibilities, independence of second-line functions, access to the board of directors and the investment committee. Integration of AML into corporate governance strengthens the office’s position vis-à-vis banks and the regulator.

What COREDO provides and when to contact us

Sometimes a targeted consultation is enough to set up risk assessment or SAR criteria. Sometimes a full project is needed to move to automation, configuring a transaction monitoring system, selecting providers and training the team. COREDO’s experience confirms: consolidating all these tasks into a single project and unified procedures produces a multiplied effect – fewer mistakes, transparent processes and a single logic for audits.

We handle company registration issues in the EU, the Czech Republic, Slovakia, Cyprus, Estonia, the United Kingdom, Singapore and Dubai, support Licensing (crypto, payments, forex and banking), build AML processes and prepare for inspections. This set of competencies allows a comprehensive view of AML: with an understanding of licensing, tax transparency, CRS, DAC6 and banking realities.

Conclusions

Luxembourg places high expectations on compliance, and that is good for Family Offices that want to operate long-term and with peace of mind. AML for Family Office in Luxembourg: not a set of formalities but an operating system: KYC/EDD, monitoring, SARs, sanctions, GDPR, CRS/FATCA and corporate governance. When this system works, banks trust it, deals close on time, and the regulator sees maturity.

I built COREDO as a partner that holds this complex together with a single logic and brings processes to fruition. If you are looking for compliance for a Family Office that withstands CSSF inspections and CRF requests, while accelerating business,, the COREDO team is ready to step in: we’ll assess risks, develop solutions and scale them together with the growth of your capital.

In recent years «beneficial ownership transparency» has ceased to be a narrow compliance term and has turned into a board-level topic. By 2026, against the backdrop of the EU AML package 2021–2026, the tightening of AMLD6 and global pressure from the FATF, companies, banks and payment providers are restructuring processes as if oversight will become total tomorrow.

My experience has shown: those who do not fight the trend but design business processes with UBO realities in mind come out ahead. EU beneficial owner registers, UBO registration rules when forming a legal entity in the EU, information exchange between jurisdictions: all of this has ceased to be «paper» bureaucracy. It is the very core of the operating model on which access to banking services, onboarding speed, the ability to obtain licenses and expansion into new markets depend.

Who is a UBO and why are thresholds needed?

Illustration for the section «Who is a UBO and why thresholds» in the article «UBO registers in 2026 - how banks check transparency in offshore jurisdictions»

Ultimate Beneficial Owner (UBO): the ultimate beneficial owner who ultimately controls a company through direct ownership or beneficial interest. The traditional ownership threshold of 25% is often used by banks and beneficial ownership registers abroad, but in the EU we increasingly see a 10% threshold for UBOs in cases of heightened risk or in the context of specific sectors. A threshold does not exempt from the analysis of control: the right to appoint management, veto rights, shareholder syndicates and agreements — all of these create a beneficial interest, even if shares are split.

Complex ownership structures and UBOs: my daily reality. Trusts and foundations, nominee shareholder arrangements and nominee directors, remnants of historical mechanisms like bearer shares (which are de facto prohibited), these are all layers that compliance peels away one by one. The practice of COREDO confirms: if a structure looks “too neat”, the bank will immediately raise the bar: enhanced due diligence (EDD) is inevitable.

UBO Registers 2026

Illustration for the section “UBO Registers 2026” in the article “UBO registers in 2026 - how banks check transparency in offshore jurisdictions”

UBO register 2026: not just a date on the calendar, but a milestone when registers and banks must speak the same data language. EU countries have different models: public vs closed UBO registers, trust structures (trust registers), corporate registers, and interoperability via the Beneficial Ownership Data Standard (BODS) and the Open Ownership initiative. In the UK Companies House is strengthening quality control, in Estonia and Cyprus registers are already integrated into KYC pipelines, while in Singapore and Dubai the emphasis shifts to lawful access by authorized persons and regular updates.
GDPR and the legal limits on the publicity of registers: a constant balance. Regulators are expanding the lawful basis for access to UBO data for banks, auditors and corporate service providers (CSPs), but require strict access controls and protection of personal data. National AML competent authorities and financial intelligence units (FIUs) receive priority access for investigations, and corporations must justify every request.

UBO Registers and the Fight Against Money Laundering

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FATF recommendations on ownership transparency have established the standard: without a reliable register of ultimate beneficial owners, AML processes do not work. The Common Reporting Standard (CRS) and OECD initiatives on company transparency have completed the picture, where corporate registers, tax data and banks’ KYC converge into a single mosaic-style verification. World Bank promotes infrastructure solutions for beneficiary registration, while OpenCorporates and data aggregators speed up cross-verification of UBO registry data.

COREDO’s practice confirms: a UBO register and information exchange between jurisdictions via TIEA and MLA are not theory but a tool for «rapid tracing» of control, especially in M&A transactions and when entering new markets. We regularly see how open-access registers vs restricted-access ones differently affect the speed of banks’ Due Diligence of UBOs and the risk of de-risking clients from offshore jurisdictions.

How banks verify UBOs in offshore jurisdictions

Illustration for the section «How banks verify UBOs in offshore jurisdictions» in the article «UBO registers in 2026 - how banks check transparency in offshore jurisdictions»
KYC and UBO: the combination without which you won’t be able to open an account or keep correspondent banking relationships. Bank UBO due diligence includes checking UBOs in offshore jurisdictions: banks use methods to verify beneficiaries through registers, requests to CSPs, independent sources, sanctions regimes and lists, PEP screening and adverse media. When a structure includes trusts and foundations, beneficiary verification for trusts and foundations requires a named breakdown of beneficiary classes and protector roles.

Correspondent banking and UBO risks increase the requirements of local banks. If a client’s core business is linked to offshore jurisdictions, enhanced due diligence (EDD) is often triggered and even case-by-case approval with the bank’s financial intelligence function required. The COREDO team has repeatedly encountered de-risking of clients from offshore jurisdictions: banks prefer to refuse a high-risk profile rather than bear compliance costs and the threat of fines for non-compliance with AMLD6 and sanctions rules.

Requested documents and evidence

Illustration for the section 'Requested documents and evidence' in the article 'UBO registers in 2026 - how banks check transparency in offshore jurisdictions'
How do banks verify UBOs in offshore jurisdictions? At the core is a chain of documents: articles of incorporation, shareholder registers, trust declarations, director appointment minutes, certificates of good standing, CSP letters about nominee structures, and confirmations of the renunciation of bearer shares. Which documents prove the UBO in offshore jurisdictions? It always depends on the jurisdiction, but the single principle is the same: documentary continuity from the legal entity to the ultimate beneficiary with verified identity.

Document-based identification and identity proofing include biometric verification and digital IDs where eIDAS and local law allow. Banks require consent for data processing in accordance with the GDPR, as well as additional forms for sanctions screening. Our experience at COREDO has shown that a concise “structure map” and a checklist of beneficiary roles speed up onboarding and reduce the likelihood of repeated requests.

ETL pipeline and graph databases

Automating UBO checks for banks is impossible without integrating UBO registries into banks’ KYC pipelines. API tools for accessing UBO registries, APIs for exchanging registry data and real-time screening of UBO registries provide an advantage in time to onboard and reduce false positives/false negatives in checks. The solution developed at COREDO for one of the partner banks built an ETL pipeline for UBO registries with data quality validation, storage of data provenance and multi-stage source verification.

Graph analysis of company ownership and link analysis for detecting UBOs is my favorite part. Graph databases (for example, Neo4j) make it possible to visualize chains of dozens of entities and detect fraud analytics and shell structures. Machine learning helps with entity matching and fuzzy matching, and blockchain for storing provenance data improves audit immutability. Such a stack reduces MTTR on compliance cases and increases TPR with controlled FPR: metrics that CFOs understand without translation.

Metrics and ROI of AML technologies

Any technology is worth exactly as much as the savings it delivers or the risk it reduces. The costs of implementing UBO procedures in a bank and the compliance cost per customer should be compared with ROI metrics: reduction in time to onboard, decrease in operational hours spent on repeat requests, reduction in the number of SARs (suspicious activity reports) without loss of quality, and increased case throughput. The COREDO team implemented an ROI calculation model where we link the operational scalability of AML processes to business volume and correspondent relationship uptime.

Tuning of transaction monitoring rules and algorithms for prioritizing UBO checks helps eliminate bottlenecks in compliance queues. Compliance automation: RPA and workflows create repeatability and version control of playbooks. When the task is scaling AML processes for multinational companies, unified data quality control and data reconciliation (entity resolution) between systems deliver the real economies of scale.

Regulatory framework: standards and penalties

Compliance with AMLD5, AMLD6 and UBO registers is a mandatory requirement for lawful operation in the EU, as is compliance with the CTA (Corporate Transparency Act) for entities with a U.S. presence. Legal sanctions for failing to disclose UBOs include substantial fines, license suspensions and restrictions on banking services. In the UK and some EU jurisdictions there are already criminal penalties for deliberate falsification of ultimate beneficial owner information.

The UBO register and sanctions lists are a pairing that banks check daily. The bad news: sanctions regimes are updated unevenly; the good news: UBO monitoring practices in banks for 2026 already incorporate adverse media and PEP flags into unified screening frameworks. COREDO’s practice confirms: companies that document data provenance and best practices for documenting UBO sources more easily meet regulatory inquiries and respond to audits without stress.

COREDO case studies: solutions to complex challenges

First case: a fintech group entering the EU through a payment services license in Cyprus. The client came with a complex ownership structure involving a trust and two holding companies in different Asian jurisdictions. The COREDO team built an ownership graph, assessed the reliability of UBO data, and prepared compliance playbooks for UBO checks. Result – Licensing was completed on time, and the acquiring bank reduced time to onboard by 40% thanks to a pre-agreed document package and an EDD dossier.

Second case, a crypto provider opening an office in Estonia with subsequent expansion to the UK and Dubai. Registering UBO when forming a legal entity in the EU required alignment with the FCA’s AML registration requirements and with VARA rules in Dubai. The solution developed at COREDO included automation of KYC and UBO checks via API, entity matching with EU beneficiary registries and negative news. The client avoided de-risking of clients from offshore jurisdictions, as the banking dossier contained justification of control and a renunciation of nominee structures.

Third case: M&A with an offshore target asset and correspondent banking risks. We performed due diligence on the M&A involving an offshore target, built link analysis, identified nominee owners at the level of the second holding and proposed a restructuring to fall below the 10% UBO threshold in the EU with disclosure of the actual controller. This removed the risk of the deal being blocked by correspondent banks and reduced the cost of insuring representations and warranties.

Preparing a company for a bank UBO request

First – an ownership structure map showing all beneficial interests. Include shareholdings, control rights, shareholders’ agreements, trust documents and confirmations of the roles of protector and settlor. Second – a KYC package for each UBO: proof of identity, address, source of funds confirmation, PEP status and adverse media results. Third – a policy for monitoring changes in ownership structure and UBOs with an SLA for data updates and procedures for notifying the bank.

How to avoid mistakes when declaring UBOs? Do not rely on generalizations and “umbrella” formulations. Specify thresholds, disclose concerted actions and avoid nominee terminology without explanations. If foundations and offshore legal structures are present: attach legal opinions on the nature of control and beneficial interest, as well as letters from the CSP. At COREDO we implement checklists that minimize the risk of bank rejections.

Registry data quality: normalization

Cross-checking UBO registry data is a mandatory practice. I recommend building parsing and normalization of registry data followed by entity matching and fuzzy matching, and then reconciling with the client’s internal data and open sources like OpenCorporates. Data quality and source validation reduce the risk of false positives, and documented data provenance makes it easier to respond to regulatory requests.

Integrating UBO registries into banks’ KYC pipelines via API increases speed. Still, do not forget about access control and personal data protection: set up a lawful basis for access to UBO data and an access revocation procedure. In some jurisdictions, part of the data is available only upon request from authorized persons – the COREDO team prepares such requests in advance and factors in a buffer in project plans.

Compliance: What to monitor at the C-level

Best practices for UBO verification for C-level: regular reports with performance and risk metrics. Include MTTR for compliance cases, FPR/TPR for screening, time to onboard, the number of cases in EDD and the share of structures with trusts and nominees. Add a cost-benefit analysis of implementing UBO registries and ROI metrics: reduction in cost per client, preserved correspondent relationships and the speed of opening bank accounts.

Practical steps for the CFO when assessing UBO risk: classify jurisdictions by EDD complexity, create a catalog of CSPs and company formation agents with a reliability rating, and create a map of sanctions linkages. The COREDO team implemented an owner risk-scoring model for a multinational client, where machine learning and graph features improve the accuracy of prioritizing UBO checks and reduce the load on the EDD team.

Linking the UBO to the actual operation

When you register a legal entity in the EU, bear in mind that the UBO register is often synchronized with bank onboarding. This means that mistakes at the UBO registry stage will surface when opening an account and when obtaining licenses: crypto, forex, payment services, and in some jurisdictions, banking licenses as well.

COREDO’s practice confirms: early alignment of UBO and licensing requirements saves weeks.

In Asia and the Middle East, the differences are significant. In Singapore, MAS emphasizes actual control, while in Dubai VARA and local regulators require clear documentation of ownership. In the Czech Republic, Slovakia, Estonia and Cyprus the processes are formally straightforward, but banks supplement them with their own EDD. The COREDO team builds a unified package that equally convinces the registering authority and the bank officer.

Outsourcing vs in-house: sustainable model

The question “do it in-house or outsource” is decided by metrics. If the volume of onboarding and monitoring is high, and the client structure is complex, a hybrid model is often more effective: the internal team manages policies and risk level, while external specialists handle peak workloads and complex cases. Compliance services for UBO checks for corporations provided by COREDO include operational playbooks, training and tool implementation.

Shared utilities and centralized registries: a logical future. Corporate registries and interoperability will reduce the costs of duplicated checks, but there’s still a way to go before unified standards. For now, the winner is the one who can link different sources, maintain entity resolution and support real-time screening where it is critical for payments and correspondent settlements.

Monitoring changes in ownership structure

Monitoring changes in ownership structure and UBO is a process, not an event. I set an SLA for data updates: changes to the EU register of beneficial owners and to bank dossiers within specified business days. Include triggers: new shareholders, director changes, emergence of nominee services, trust relocation, material M&A transactions.

Banks value transparency and predictability. If a company announces a restructuring in advance and provides a package of documents, the risk of account freezes is noticeably lower. In one project, a solution developed at COREDO automated bank and registrar notifications via RPA, reducing the update cycle from weeks to days.

Common mistakes: how to avoid them

The first mistake: underestimating nominee structures and front owners. The bank will spot it if the beneficial owner is “hiding” behind a service company without a business reason. Second: incomplete information on trusts and funds: ignoring the protector, failure to provide a letter renouncing bearer shares, lack of description of beneficial interest. Third — lack of a documented source of funds for the UBO.

How to reduce onboarding time during UBO checks? Assemble the package in advance, use BODS standards and formalized structure diagrams, note sanctions and PEP checks, attach an adverse media report. Our experience at COREDO has shown that a proactive approach reduces the number of follow-up requests from the bank by 30–50% depending on the jurisdiction.

Conclusions: what to do next

By 2026, UBO registries and the practice of bank monitoring will ultimately set a new standard for working with ownership. This is not just a compliance requirement, but an element of competitiveness: you open accounts faster, get licenses faster, close deals faster. The role of UBO registries in the fight against money laundering will continue to grow, and along with it: expectations regarding data quality, their provenance and operational discipline.

COREDO was created to connect clients’ strategies with real regulatory practices in the EU, the United Kingdom, the Czech Republic, Slovakia, Cyprus, Estonia, Singapore and Dubai. I see how well-designed UBO processes, supported by technology and clear playbooks, turn the “pain” of compliance into a scalability advantage. Going forward, those who embed the UBO circuit into their business architecture will win: from company registration to bank onboarding and day-to-day operations.

UBO Registers 2026: public vs closed

By 2026, the geography of beneficial owner registers has become more predictable, but remains uneven in accessibility and quality. Public registers speed up banks’ UBO due diligence. On the other hand, strict GDPR constraints and differences in legal basis create “compatibility with friction” between countries and banks. Closed and governmental registers provide better accuracy and depth, but add latency and require formalized requests and justification of lawful basis.

Institutional interoperability is growing thanks to the Beneficial Ownership Data Standard (BODS) and the Open Ownership platforms, but the standard’s implementation is uneven. Where national corporate registers are synchronized with UBO records and use BODS, banks gain in time to onboard and reduce FPR without losing TPR. Below: a practical comparison.

Public vs closed UBO registers affect bank SLAs differently. Publicity speeds up initial checks and reduces the volume of client inquiries, but requires careful handling of personal data. Closed registers create a reliable basis for EDD and FIU investigations. At the same time, banks must plan time buffers in advance and formalize the routing of requests through competent authorities.

Regulatory framework 2026: UBO checks

The regulatory map for 2026 relies on FATF Recommendations 24/25 on the transparency of legal persons and trusts, the AMLD5/AMLD6 directives and national transpositions. In the USA the Corporate Transparency Act (CTA) operates with Beneficial Ownership Information (BOI) reporting to FinCEN and access regimes for financial institutions. In the EU a horizontal AML regulation is being formed at the same time and control over the quality of registers is being strengthened, which directly affects banks’ KYC procedures and the checking of UBOs in offshore jurisdictions.

GDPR defines the lawful basis for banks’ access to UBO personal data, and this is a practical matter, not theory. Banks most often rely on Art. 6(1)(c) “compliance with a legal obligation” and Art. 6(1)(f) “legitimate interest”, supplementing them with internal DPIAs and data minimization policies. Special categories of data require a separate analysis, and for cross-border transfers, mechanisms compatible with EU standards and local privacy laws.

The consequences of non-compliance are already tangible both financially and reputationally. Fines, mandatory SAR reports, unplanned regulatory audits and de-risking by correspondent banks are becoming a reality for companies that ignore beneficiary disclosure or manipulate nominee structures. My recommendation remains unchanged: document every part of the chain of control and keep the evidence package “on the shelf”.

Practical compliance checklist for UBO checks

  • Define thresholds and control: record the ownership percentage, veto rights, shareholders’ agreements and actual influence on management. Prepare a written justification of the beneficial interest and attach a legal opinion if there are gray areas.
  • Record the lawful basis: specify the GDPR basis, describe the bank’s role as controller and collect consents where necessary. Add DPIA/LIAs and data minimization and retention procedures.
  • Keep them up to date: set SLAs for updates in the national register and at the bank when UBOs change. Include RPA reminders and checkpoints for internal legal and finance teams.
  • Prepare an EDD file: collect Source of Funds/Wealth, CSP letters, nominee agreements and confirmations of the renunciation of bearer shares. Conduct PEP/sanctions/adverse media screening in advance and attach the results.
  • Log provenance: preserve sources, document versions and hash-based integrity checks. This will speed up responses to regulatory inquiries and internal audits.

How banks verify UBOs and KYC

A bank KYC pipeline for UBO is a managed sequence of steps with clear owners. I advise clients to align their internal procedure to the same logic to shorten question‑and‑answer cycles and minimize false positives/negatives.

Step-by-step KYC pipeline

  • Intake and pre‑screening: collection of the questionnaire, corporate documents and an initial description of the structure. Sanctions and PEP checks are run, as well as a quick adverse media review.
  • Ownership mapping: building an ownership graph up to the ultimate beneficial owner, recording controlling rights and agreements. Threshold rules of 25% and 10% in the EU are applied, taking cumulative control into account.
  • Documentary verification: matching registries, certificates and nominee agreements with client and provider data. A request is sent to the CSP and a formal reconciliation with local registries takes place.
  • Screening and risk‑scoring: combining sanctions, PEP, negative news and geo‑risks into a single profile. ML models support entity matching and reduce FPR as TPR increases.
  • Decision and onboarding: either standard approval, escalation to EDD, or rejection with justification. Results and provenance are logged for audit and correspondents.

Roles and responsibilities are allocated in advance and by name. The Relationship Manager gathers the package and manages communication, the KYC analyst handles the structural and documentary layer, the AML/Financial Crime team performs screening and risk‑scoring, and complex cases go to EDD/SME with the final decision by the Compliance Officer. Such a matrix reduces MTTR and provides predictability for the business and the client.

KYC pipeline diagram (textual)
Client intake → Pre‑screening → UBO mapping → Documentary verification → Sanctions/PEP/Adverse media → Risk‑scoring → Decision/EDD → Onboarding/Monitoring. Each stage records provenance and SLA, and integration points with registries go via API or formalized requests.

UBO verification in offshore jurisdictions

Офшоры привлекают гибкостью и скоростью, но для банка это маркеры повышенного риска. Nominee directors and shareholders, historical bearer shares, foundations and trusts, as well as a prominent role of CSP, all of this requires combined validation and a closer dialogue with the client. Чем раньше клиент покажет экономическую логику структуры и реальный контроль, тем ниже вероятность де‑райзинга.

Практические методики включают параллельную работу с несколькими контурами данных. Мы совмещаем локальные реестры, письма CSP, коммерческие агрегаторы, санкционные списки и adverse media, а затем подтверждаем транзакционным поведением, если счёт уже активен. Там, где трасты и фонды, особое внимание уделяем trust registers, распределению beneficial interest и ролям settlor/protector/beneficiaries.

Рекомендации банка и типичные red flags

  • Применять EDD, когда структура включает nominee arrangements, трасты без прозрачной экономической цели, или страны с высоким риском по FATF. Дополнительно запрашиваются SoF/SoW, интервью с UBO и письма от независимых юридических консультантов.
  • Красные флаги: несоответствия между реестрами и документами, частые смены директоров без бизнес‑обоснования, CSP без лицензии, и негативные news о связанных лицах. Такие сигналы активируют расширенный скрининг и могут привести к отказу.

Disclosure of beneficial interest

Идентификация nominee начинается с документов и не заканчивается ими. Банки запрашивают декларации nominee, договоры оказания услуг и подтверждение полномочий, а также правовые мнения о том, кто вправе распоряжаться голосами и дивидендами. Важно показать, что номинал не осуществляет самостоятельного контроля и действует строго по инструкциям бенефициара.

Мы всегда совмещаем документальный слой с данными о поведении и транзакциях. Если фактические платежи, подписи и IP‑логи инициируются одними и теми же лицами, это поддерживает картину бенефициарного контроля. Когда наблюдается расхождение между ownership data и транзакционным профилем, кейс уходит в EDD, и банк запрашивает дополнительные подтверждения beneficial interest.

EDD for UBOs: criteria and thresholds

EDD is triggered by a combination of risk factors, and this is normal practice for offshore structures and complex ownership. Classic triggers: PEP status of the UBO or key directors, high‑risk or sanctioned jurisdictions, structural complexity with trusts/funds/nominees, and discrepancies between registers and the documents provided. In the EU banks increasingly rely on a 10% threshold for UBOs in the EU in complex structures, even if the formal general threshold remains 25%.

Standard EDD procedures are detailed and resource‑intensive, so it is better to prepare for them in advance. Extended SoF/SoW packages, bank references, tax returns, asset sale agreements and interviews with the owner—where the structure’s motivation and sources of capital are discussed—are requested. In offshore jurisdictions a letter from the CSP about the nominee, confirmation of the renunciation of bearer shares and legal opinions on trusts and foundations are almost always required.

Examples of EDD scenarios

A Jersey trust with investments in the EU and a UBO resident of a third country. The bank will request the trust deed, letter of wishes, a list of beneficiary classes, documents on the protector and the founder’s SoW, as well as sanctions and PEP screening of all related parties.

A BVI holding with a nominee shareholder and operating companies in the EU. They will request the nominee declaration, the agreement and confirmation of control over votes, CSP letters, the shareholder register and confirmation of cash flows from the operating companies to the owner.

A PEP link for a minority owner with 12% in the EU. They will apply the 10% threshold, carry out enhanced adverse media checks, conduct an interview and request independent sources of income and an explanation of the business role.

Cross-verification of UBO registries

Reliable due diligence relies on the right mix of primary and secondary sources. National registries and trusted corporate registers form the “gold standard”, while OpenCorporates, Open Ownership, commercial aggregators and sanctions lists provide breadth and speed. Cross-verification through entity matching, fuzzy matching and reconciliation resolves contradictions and documents data provenance.

Table: data sources – advantages, limitations, update, reliability
Источник Преимущества Ограничения Обновление Reliability
Национальные UBO‑реестры Official status and legal force Limited access and GDPR barriers T+1/T+15 High with proper query
Корпоративные регистры Confirm directors and participants Do not always include UBOs T+1/T+7 Medium-high
OpenCorporates Wide coverage and convenient search Heterogeneity and incompleteness Near real-time Medium
Open Ownership/BODS Structured relationships and standards Depends on connected registries Near real-time Medium
Коммерческие агрегаторы Speed and normalization Cost and algorithmic black boxes T+0/T+1 Medium-high
Санкции/PEP Regulatory criticality Varied formats and update latency T+0/T+1 High when multi-listed
Adverse media Early risk detection Noise and risk of false positives (FPR) Continuously Medium when tuned

Cross-verification mechanics must be formalized and reproducible. We use entity resolution with canonicalization of names, addresses and identifiers, fuzzy matching to recognize transcriptions and aliases, and then run reconciliation against an internal “golden profile” and the client’s documents. This approach reduces MTTR and prepares the data for automated solutions and organizational audits.

Integration of registry data via ETL

A correct ETL pipeline for UBO data starts with ingestion via API and batch channels, then normalization according to BODS and local schemas, enrichment with sanctions and PEP data, and matching to already known entities. It’s important to log every transformation, store sources and versions, and also maintain re-validation on schedule and on triggers. At COREDO we additionally hash document versions and write provenance to immutable storage to simplify audit defense.

Best practice: separate the operational layer and the analytical data layer. The operational layer serves real-time screening and onboarding, while the analytical layer handles periodic reconciliation, reporting and ML training. This reduces the risk of SLA degradation and makes the system resilient to peak loads.

Automating UBO verification for banks

Automation tools are not a luxury but a necessity when scaling KYC. APIs for registry access, graph databases (Neo4j), link analysis and ML‑models for risk scoring form the core of the technology stack that accelerates UBO verification and improves quality. We see how real‑time screening and RPA workflows reduce manual work, and metrics MTTR, FPR and TPR become manageable.

Integration into the KYC pipeline requires an architecture with clear SLAs and monitoring. Queueing systems, retries, deduplication and observability (tracing/metrics/logs) reduce operational risk, and graph analysis helps uncover hidden links between transactions and ownership data. In several projects, graph features produced a jump in the accuracy of detecting nominee structures without increasing FPR.

Integration of API, real‑time and ETL

APIs must meet requirements for performance, security and compatibility with the BODS standard. We use JSON schemas, OAuth2/MTLS, idempotent keys and detailed error handling with typing and recovery codes. Implementing rate limiting and queues ensures even load and predictable SLAs even during peaks.

Best practices for real‑time screening and batch reconciliation include separating data paths and independently scaling resources. Real‑time serves the “decide here and now” needs for onboarding and payments, while batch addresses “quality debt” and checks profile consistency. Regular A/B tests of rules and ML models allow reducing FPR without losing TPR.

Correspondent Banks and Sanctions

Correspondent banks assess UBO risk through the lens of their own regulatory exposure and reputational loss. If a client’s profile combines an offshore structure, weak documentation and adverse news, the likelihood of de-risking rises sharply. Strong UBO documentation and pre-agreed EDD packages: the best protection against sudden shutdowns.

A de-risking case and lessons

  • An international bank cut the correspondent line to a fintech with an offshore holding after a series of adverse media publications and a delayed UBO update in the national register. The client lost access to dollar payments for six weeks while assembling an EDD package and agreeing a lawful basis for access to closed records.
  • We restored access through a package: an updated structure map, CSP letters, confirmed SoF/SoW, graph analysis of connections and an independent legal opinion on the trust. The bank accepted a remediation program and lowered the client’s risk scoring from “high” to “medium” on the condition of quarterly monitoring.

Practical tips for clients

  • Prepare a “correspondent folder”: sanctions provisions, UBO structure in BODS format, SoF/SoW, screening results and the contact details of the responsible person. This speeds up responses and reduces uncertainty.
  • Communicate proactively: notify structural changes and regulatory news before the bank asks. This builds trust and reduces the risk of preventive de-risking.

Implementing UBO procedures in a bank

Costs consist of data licenses, integration development, infrastructure, training, and operational support. In a typical bank, average TCO in the first year includes 40–60% of costs for data and APIs, 25–35% for development and integration, and 15–25% for operational processes and training, although proportions change with scale. I strongly recommend budgeting for data quality and ongoing reconciliation, because that is where MTTR is reduced and onboarding time is shortened.

Profitability is measured through a set of applied metrics related to business value. Reducing time to onboard by 30–50%, lowering FPR by 20–35% and stabilizing correspondent relationships are direct drivers of ROI that the C-level and the board understand. For multinational companies the effect is amplified if you use shared utilities, centralized registries, and a hybrid outsourcing vs in-house model with strict SLAs and KPIs.

KPI for UBO AML checks

Measurability is the foundation of a mature compliance function. We track TCO per case, time to onboard, MTTR on escalations, FPR/TPR of screening, the share of cases in EDD and the percentage of document returns. The formulas are simple and practical: FPR = FP/(FP+TN), TPR = TP/(TP+FN), MTTR: the median time from escalation to resolution, and ROI: share of OpEx savings plus revenue preserved from faster onboarding minus investments.

Quarterly targets should be ambitious but achievable. I often budget for -20% FPR while maintaining TPR, -25% time to onboard for standard cases and -15% MTTR for EDD thanks to templates and pre-checks. Such targets discipline the team and show the board of directors tangible progress.

Prepare the legal entity for the bank’s UBO request.

Proper preparation saves weeks and reduces stress for all parties. I recommend assembling three packages: corporate, beneficial and sanctions, each with versioning and provenance. Below is a consolidated checklist of documents by scenario.

Scenario Core documents Additional (EDD) Notes
Onboarding Articles of association/formation documents, register of shareholders/members, UBO structure, UBO IDs and addresses SoF/SoW, CSP letters, nominee declarations, renunciation of bearer shares BODS format will speed up processing
Trusts/funds Trust deed, letter of wishes, list of beneficiaries, protector/settlor documents Legal opinion on control, tax statuses, extracts Disclose beneficial interest by class
Offshores Certificate of incumbency, register of members/directors, CSP letter Nominee agreement, confirmation of voting rights and dividends State the economic rationale of the structure
M&A Data room with structure, minutes/SPA, cap table, UBO matrix EDD report, sanctions/PEP, adverse media Speed diligence requires ready-made templates

Recommendations for registrations in the EU/Asia are simple and effective. In the EU, pre-synchronize the UBO record with bank onboarding and licensing, and in Singapore and Dubai arrange with the CSP the timing and format for issuing UBO documents for banks. Before submission the CFO should go through an internal checklist, ensure registers are up to date, and run a test sanctions/PEP/adverse media report.

UBO verification in M&A and transactions

UBO‑due diligence in mergers and acquisitions – это speed diligence с акцентом на контроль и санкционные сопряжения. Мы строим ускоренный граф владения, валидируем бенефициарный интерес, проверяем скрытые соглашения акционеров и оцениваем риски де‑райзинга у банков‑партнёров покупателя. Чем раньше покупатель покажет план ремедиации структуры под требования AMLD6 и корреспондентов, тем ниже скидка на риск в цене сделки.

Post‑deal мониторинг должен быть автоматизирован и связан с триггерами изменений. Смена директоров, перераспределение долей, назначение nominee или переезд траста запускают переоценку риска и при необходимости, EDD. Мы используем RPA для оповещений регистраторов и банков и графовые подписки для сигналов о новых связях в adverse media.

Practical templates for the deal

  • UBO‑request list: структурированный перечень документов, включая BODS‑выпуск и карту контроля. Он экономит время юридических команд и снижает количество уточнений.
  • Risk‑скоринг владельцев: модель приоритизации проверок с весами по юрисдикциям, санкциям, PEP и сложностям структуры. Она помогает фокусировать EDD там, где это действительно нужно.

Recommendations for C-level executives and owners

I’ve compiled a focused ten-point checklist to help prepare for banks’ UBO checks.

  • Structure map in BODS and as a graph. Keep it current and version it for audit.
  • A single UBO document package with provenance. Update it with every change and register SLAs.
  • Preliminary sanctions/PEP/adverse media screening. Catch issues before the bank sees them.
  • Nominee and trusts policy. Document the economic rationale and boundaries of control.
  • SoF/SoW for UBO. Prepare evidence in advance and store independent confirmations.
  • Data quality and entity resolution. Implement normalization procedures and reconciliation of sources.
  • API integrations and RPA workflows. Reduce manual work and ensure process observability.
  • Metrics and targets: time to onboard, MTTR, FPR/TPR. Link them to bonuses and performance management.
  • Correspondent ‘folder’ and playbooks. Maintain trust with banking partners and reduce the risk of de‑risking.
  • Remediation plan under AMLD6/CTA. Update structural arrangements for new rules and jurisdictions.
Investments should be prioritized on the principle “data and automation first”. The tech stack for registry access, graph analytics and ML scoring pays off faster, while manual EDD remains for complex cases and model labeling. Outsourcing makes sense for peaks and niche expertise, but policy and risk appetite should remain in-house.

Frequently Asked Questions

Question 1: What is a UBO and which thresholds apply in 2026?

Answer: UBO, the ultimate beneficial owner, controlling the company directly or through a beneficial interest. The general ownership threshold of 25% is supplemented by a 10% threshold in the EU for complex structures and high risk, as well as by analysis of de facto control beyond shareholding.

Question 2: How do banks verify UBOs in offshore jurisdictions and which documents are most often requested?

Answer: Banks compare local registers, CSP letters, corporate documents and trust agreements, then perform sanctions/PEP/adverse media screening. Most often they request a certificate of incumbency, register of members/directors, trust deed, nominee declarations, renunciation of bearer shares and confirmations of SoF/SoW.

Question 3: What to do if a UBO does not disclose information or there is a nominee?

Answer: Prepare legal opinions and nominee declarations confirming absence of independent control and demonstrate the economic rationale of the structure. If disclosure is refused, the bank will likely apply EDD or refuse the relationship, so it’s better to proactively provide the maximum evidence of beneficial interest.

Question 4: How does GDPR affect a bank’s access to UBO registers?

Answer: The bank relies on Art. 6(1)(c) and Art. 6(1)(f) GDPR, supplemented by a DPIA and a minimisation policy. For cross-border data transfers compatible mechanisms are used and all requests and justifications of the lawful basis are logged.

Question 5: How much does it cost to implement automated UBO checks?

Answer: Costs depend on scale, but in the first year the lion’s share goes to licenses and integrations, and thereafter the main effect comes from reduced FPR and time to onboard. In typical cases payback is achieved within a 9–18 month horizon due to OpEx savings and preserved correspondent lines.

Conclusion

The year 2026 cements a new standard of transparency: UBO‑registers become an integral part of business architecture and banks’ KYC. Winners are those who combine the regulatory framework, high‑quality data and automation, and who prepare a convincing narrative of control and source of funds for each beneficiary. This approach reduces the risk of de‑risking, speeds up onboarding and increases resilience to regulatory shocks.

Your next steps are clear and achievable. Conduct an internal audit of UBOs and update the structure map in BODS format, assemble a package of documents with provenance and set up API integrations with key registries and aggregators. If you need to accelerate the process, contact our COREDO team: we will carry out an express readiness diagnostic, share document templates and help implement the technology stack for your processes and jurisdictions.

Since 2016 I have been leading COREDO through dozens of investigations, thematic reviews and interviews with regulators in the EU, the UK, Singapore and the UAE. During that time the COREDO team has assisted clients in obtaining crypto, payments, forex and banking licenses, as well as in subsequent supervision, including high-stakes episodes: from AML investigations and sanctions issues to requests concerning cross-border transactions. This article is a distillation of practice: how to prepare the Chief Compliance Officer (CCO) and MLRO for questioning, what to expect, which rights to protect and which documents to present in order to pass the inspection professionally, maintain the regulator’s trust and controllably reduce risks.

COREDO’s experience shows: a regulatory interview is a controllable process if you start preparing in advance, ensure a transparent communications strategy and establish documentation discipline. Below is the working framework I personally use when, together with a client, I build the defence, communications and execution of supervisory authorities’ requests.

Activation of the response plan

Illustration for the section «Activation of the response plan» in the article «Preparing the Compliance Officer for a regulator’s interview»
The first signal is a request for documents, an invitation to an interview, or a supervisory notice. At this stage it is important to ensure procedural fairness: confirm receipt of the notice, clarify the scope of the inspection, agree on the timing and format of interaction, including consent to record the interview and participation of an external lawyer. The solution developed by COREDO begins with a risk triage: determining the scope of affected jurisdictions, applicable regulations (AMLD5/AMLD6, FATF, Wolfsberg), data categories (GDPR), and the list of involved roles.

My experience shows that an early self-assessment (gap analysis) and the quick initiation of a litigation hold notice allow preserving evidence and forming the correct scope of document production. I always recommend putting an escalation matrix in place.

Roles and responsibilities of CCO, MLRO, CEO

Illustration for the section «Roles and responsibilities of CCO, MLRO, CEO» in the article «Preparing the Compliance Officer for questioning by the regulator»
The rights and duties of the Compliance Officer during an inspection should be documented in writing. CCO and MLRO are responsible for the completeness of the factual part and the accuracy of references to policy, the CEO – for the company’s position and the strategy for interaction with supervisory authorities, and the board of directors for oversight and approval of key decisions, including the remediation plan and the budget for external consultants and forensic investigation.

During questioning, the CCO has the right to a lawyer (the right to counsel during a regulator’s questioning), to use privileged communication and protection under legal privilege, as well as the right to an interpreter in another jurisdiction.

Privilege and data protection: documents

Illustration for the section «Privilege and data protection: documents» in the article «Preparing a Compliance Officer for questioning by a regulator»
Handling documents, observing privilege and data protection measures determine which materials are subject to disclosure and how to store them securely during a dispute. Below we will examine document production, legal hold and the practical application of privilege rules to clarify steps and minimize risks.

Documents, legal hold and privilege

The COREDO team has carried out numerous cycles of document production taking into account a privilege log, where we describe the nature of a document without disclosing privileged details. Legal privilege and protection of communications are critical.

GDPR: DPIA and cross-border requests

Cross‑border issues and cross‑border requests often raise GDPR compatibility questions when transferring data to regulators. At COREDO we prepare a DPIA in advance, determine the legal basis for the transfer (for example, performance of a legal obligation), and apply data minimization and encryption. Under MLAT (mutual legal assistance) we check compliance with local law and bank secrecy exceptions, and also ensure client confidentiality when multiple supervisory authorities are involved.

Preparing the CCO and MLRO for an interview

Illustration for the section 'Preparing the CCO and MLRO for an interview' in the article 'Preparing the Compliance Officer for questioning by the regulator'
I view preparation as a multi-level program. First, we conduct interview preparation for legally significant statements: we build a structured interview protocol and template answers, and practice regulator question scenarios on sanctions, AML and KYC, SAR/STR procedures and monitoring. Then we run mock interviews and stress tests to prepare for interrogations, including roleplay scenarios and assessment of witness suitability.

Psychological preparation and stress management for witnesses is a separate module. I teach the CCO to state facts, avoid guessing, and to properly record “I don’t remember” when not confident.

Questions on AML/KYC/sanctions/transactions

Illustration for the section «Questions on AML/KYC/sanctions/transactions» in the article «Preparing a Compliance Officer for questioning by the regulator»
Regulators often examine the depth of the risk‑based approach. We prepare responses to regulator questions about transactions: matching transactions and monitoring analytics, methods to reduce false positives, use of automated AML monitoring and machine learning in transaction monitoring. If external software is used, we present AML‑software providers and vendor screening, results of independent testing, and the monitoring and testing of AML controls.

Forensics and electronic evidence

In complex cases we engage the use of an external forensic expert and electronic examination and e-discovery, including e-mail discovery and investigation of corporate mail. We perform forensics and recovery of deleted data in compliance with the chain of custody, and carry out data handling in protected interview rooms and secure rooms, especially when the materials contain personal data or banking secrecy.

Mitigating factors and remediation

Notice of an investigation and self‑reporting is a difficult decision, but often yields credit for cooperation (voluntary disclosure strategies and credit for cooperation). In COREDO’s practice there is a case of a payment company in one of the EU countries where early disclosure and an immediate remediation plan with subsequent verification of the corrections and an independent audit of compliance‑measures allowed them to avoid a fine and be limited to an official warning.

Interaction with suppliers

Scaling the preparation process in a global company requires managing third parties and vendors during investigations. The COREDO team developed criteria for third‑party Due Diligence and supplier risk, as well as contracts with external consultants and experts, where responsibilities for confidentiality, information security and response times are clearly defined.

Compliance checklist for a regulator interview

This checklist is not an abstraction, but a distillation of our approach. Before the interview the team goes through it in full, recording execution in the incident management and tracking system (incident management):

  • Confirm the scope of the review: supervisory notice, subject matter, timelines, recording format, and participation of counsel.
  • Implement a litigation hold, define the legal hold scope, build a privilege log, and appoint custodians.
  • Define the internal counsel vs external counsel strategy, select an approach and the boundaries of privilege.
  • Conduct a gap analysis, prepare a remediation plan, and agree it with the board of directors.
  • Confirm GDPR/DPIA, data transfer channels, encryption, cross‑border mechanisms, and banking secrecy.
  • Organize document production: chain of custody, audit trail, document versions, and access control.
  • Conduct mock interviews and stress tests, assess psychological readiness and backup witnesses.
  • Form a structured response protocol and templates for the regulator reply.
  • Check sanctions and AML/KYC blocks: OFAC/EU/UN, BO disclosure, SAR/STR, and automated monitoring.
  • Prepare an executive summary of the investigation for the regulator and case law materials.
  • Set up secure rooms/video conferences, obtain consent to record the interview, and document the risks.
  • Conduct vendor screening (AML software, forensics), confirm ISO 27001/SOC 2.
  • Agree media policy, D&O, escalation matrix, and BCP plans for the review period.
  • Calculate preparation costs and economic efficiency, balance external consultant vs internal team.
  • Set KPIs and ROI for preparation for regulatory interviews, time to resolution and recovery metrics.

Recording and Retention Policies

A records-keeping and retention policy is the foundation for the evidentiary base. We implement a retention policy and a destruction schedule with exceptions for legal hold, maintain an access log, and, as part of training, establish rules for documenting interviews and creating a transcript. Virtual interviews and secure videoconferences must meet recording requirements: obtaining consent and legal risks, storage and access in accordance with GDPR.

Pace and the economics of scaling

Preparation costs and economic efficiency — a matter not only of budget but also of decision-making speed. Analysis of costs for external consultants vs internal team allows forming a hybrid model: internal fact-gathering and preservation of privilege, external legal strategy and forensics. At COREDO we plan resources for investigations (resource planning), set SLAs for responses and rank issues by priority and risk so as not to waste time on secondary issues.

Typical question scenarios

During questioning of the AML officer (MLRO), the regulator may move on to the details of specific alerts, late escalation, or the absence of SAR/STR. Here the CCO should point to the risk‑assessment methodology, the monitoring frequency and the second‑line control function, as well as the improvements implemented after the incident. If sanctions are involved, we demonstrate checks against OFAC/EU/UN, enhanced triggers and a post‑event review.

COREDO practice cases

In one European jurisdiction, the COREDO team accompanied the questioning of the payment organization’s CCO after a series of sanctions alerts triggered on a client from a third country. We confirmed the correct configuration of the lists, demonstrated a reduction in false positives through retraining of the rules, and provided periodic monitoring reports. The outcome — an instruction to strengthen due diligence for a specific category of clients without imposing fines.

Pre-litigation dialogue with regulators

Best practices for preparing the CCO for European regulators include early pre-litigation dialogue, transparent demonstration of methodologies (AMLD5/6, FATF, Wolfsberg), a structured executive summary of the investigation and a clear reference base to policies and procedures. It is important not to argue about form, but to agree on reasonable timelines and process while protecting privilege and GDPR.

Conclusions

A regulatory interrogation is not a stress‑lottery, but a managed project with clear phases and KPIs. The key to success is a timely response plan to regulator requests, competent document production, legal privilege and protected communications, as well as professional preparation of the CCO and MLRO through mock interviews and stress‑tests.

COREDO, after years of work in the EU, the United Kingdom, Estonia, Cyprus, the Czech Republic and Slovakia, Singapore and Dubai, has built a predictable, transparent approach that helps clients pass inspections, obtain licenses and grow. If you need a regulator engagement strategy, external legal support for an interrogation, e‑discovery or an independent audit of compliance measures, the COREDO team will offer a solution adapted to your business model and jurisdictions. I am convinced: a prepared CCO is the best argument for trust in your company and its sustainable growth.

I have been leading COREDO since 2016 and see every day how quickly the digital assets market is changing. Over the years the COREDO team has carried out dozens of projects for company registration and licensing in the EU, the United Kingdom, Singapore, Cyprus, Estonia, the Czech Republic, Slovakia and Dubai. Clients come with a variety of tasks: from creating an SPV for the tokenization of artworks to building institutional custodial infrastructure for NFTs. In this article I have compiled practical experience and strategic ideas: how to use NFTs as a financial instrument, how to manage risks, comply with MiCA, MiFID II, FATF and GDPR, and how to structure IFRS reporting so that the auditor has no questions left.

When NFTs are in a corporate portfolio

Illustration for the section «When NFTs are in a corporate portfolio» in the article «NFT as a financial instrument: the boundary between art and a security in the EU»

NFTs are no longer just about collectible art. In corporate practice they are an investment asset, an element of brand strategy and a tool for managing intellectual capital. In COREDO projects, NFTs are used for access to closed services, monetization of IP via NFT royalties, issuance of corporate privileges and loyalty programs, and also as collateral in financing deals.

From an investment-logic perspective, NFTs and securities in the EU are different things. Security token vs non-fungible token: this is above all a difference in legal nature: a security token, as a rule, falls under MiFID II and national securities regimes, whereas an NFT is a unique digital token that may be an investment asset depending on its economic function, but does not automatically become a security. Classifying an NFT as an investment asset requires analysis of utility, rights, returns, market-making and liquidity availability.

Brands gain a new channel for audience engagement and licensing economics from NFTs. Our experience at COREDO has shown that strategic use of NFTs for brands pays off when the links between token ownership and utility are formalized in smart contracts, and IP-licensing and exclusivity issues are secured in clear agreements. Then an NFT logically becomes part of the corporate portfolio alongside tokenized lease rights, service vouchers and shares in an SPV.

NFT: a security under MiFID II?

Illustration for the section «NFT: a security and MiFID II?» in the article «NFT as a financial instrument: the boundary between art and securities in the EU»

The question «are NFTs securities?» does not have a universal «yes/no». The EU legal framework assesses the economic substance of the instrument. If an NFT grants a right to a share of profits, a stream of royalties, asset management by a third party or other signs of an investment contract, a dialogue with MiFID II and prospectus requirements (prospectus requirements) begins, including possible exemptions for a limited circle of investors, small issuances or private placements.

We often use frameworks for assessing the legal nature of a token, where we apply the criteria of an investment contract (Howey test and analogies) specifically as an analytical lens: capital contribution, expectation of profit, efforts of a third party. In the EU this test is not law, but it helps structure arguments for regulators and platform compliance. COREDO’s practice confirms: when an NFT provides passive income or a promise of portfolio management, regulators may qualify such a token as a financial instrument, which brings MiFID II implications for brokers and platforms.

Tokenized securities vs NFTs: the key dividing line. If a token directly embodies a claim against an issuer, an equity share or a debt obligation, it becomes a security token subject to the full body of rules, up to prospectus requirements, provider licensing and reporting. If an NFT records access, a unique digital object or certifies a right of use without an investment component, we remain in a different regulatory zone.

Regulation of NFTs in the EU and secondary markets

Illustration for the section "Regulation of NFTs in the EU and secondary markets" in the article "NFT as a financial instrument: the border between art and a security in the EU"

Regulation of NFTs in the EU (MiCA) is built around crypto-asset issuers and service providers (CASP). The basic logic of MiCA: unique NFTs that do not belong to a large series and are not fractionalized are generally outside the direct scope, but the nuances are important.

Fractionalized NFTs (fractional tokens) and serial issuances with economically interchangeable properties may fall within the scope of MiCA, and in extreme cases: within MiFID II. The solution developed at COREDO: early token qualification and a compliance roadmap before launching smart contracts.

ESMA’s recommendations on digital assets complement MiCA with details on the delineation of services and investor protection. Regulation of NFT secondary markets requires transparency of fees, prevention of manipulation and manageability of listings. Monitoring for manipulation in the NFT market and combating wash trading become part of platforms’ internal controls, especially if they perform the functions of a broker or market operator.

How to issue NFTs in accordance with MiCA? We implement the following blocks: a white paper disclosing risks, a conflicts of interest policy, marketing rules, storage and custody rules, complaint procedures, incident management.

If necessary, we launch the project through regulatory sandboxes for crypto startups in the EU to agree in advance on the approach to token functions and circulation mechanics. Interaction with regulators and supervisory authorities is critical here: it reduces the risk of the instrument being reclassified after launch.

AML/KYC: how to build compliance for NFTs

Illustration for the section «AML/KYC: how to build compliance for NFTs» in the article «NFT as a financial instrument: the boundary between art and a security in the EU»

FATF guidance on virtual assets and service providers sets a risk‑based approach. AML KYC for NFT platforms includes customer identification, a procedure for proof of source of funds (SoF), transaction monitoring and pattern identification, application of the travel rule and data transfer requirements when funds move between providers.

The COREDO team implemented risk‑scoring of buyers and sellers for marketplaces, sanctions filters and on‑chain analytics to detect links with “tainted” addresses.

Money laundering risks through NFTs are typical: rapid resales with inflated prices, wash trading, transactions through mixers, a high rate of order cancellations.

Compliance procedures for NFT projects should include escalation rules, trading blocks on suspicion, SAR/STR reports and documentation of decisions.

GDPR when processing NFT clients’ data requires minimization, justified retention periods and transparent information for the data subject.

Cross-border NFT sales and currency regulations add another layer. Our lawyers at COREDO set up cross-border compliance for buyers from Asia and the EU, aligning KYC procedures, withholding taxes and interaction with payment systems and PSPs. Banking oversight is also important: interaction with the banking system and banking supervision requires source of funds policies, invoicing standards and clear contractual documentation between the platform, the issuer and the buyer.

Royalties and licensing

Illustration for the “Royalties and licensing” section of the article “NFT as a financial instrument: the boundary between art and a security in the EU”

The legal status of copyrights when selling NFTs is not an automatic transfer of IP. Usually either Licensing of digital content takes place when selling an NFT, or the transfer of a limited set of usage rights.

Separation of rights: ownership vs right of use must be explicitly recorded in the terms of sale and/or in an on-chain link to the license. In COREDO projects we arrange IP licensing and NFT exclusivity through separate agreements, taking into account moral rights and assignment in EU jurisdictions.

NFT royalties and intellectual property rights — an area where business often loses value due to uncertainty. It is important to determine how royalties on secondary sales are collected and distributed, who administers them, what restrictions are imposed on resale and where the boundaries of content use lie.

NFT marketplaces and platform liability require clear rules in offers: transparency of fees, refund conditions, secondary NFT sales and fee regulation — all of this becomes a subject of attention for regulators and antitrust authorities if practices appear to restrict competition.

How to prove provenance and authenticity of an NFT? Proofs of origin, on-chain provenance, storing NFT metadata on IPFS and Arweave, the resilience of links to digital files and a correct URI — these are the technical foundation of legal protection.

We insist on two-sided duplication of metadata, versioning and recording of hashes in the smart contract to prevent tampering. When IP is wrapped into an SPV and licensed via an NFT, the contractual framework links the rights holder, the custodian and the token holder.

Tokenization of art and real assets

Tokenization of works of art and the tokenization of real property and lease rights require careful legal structuring.

SPV legal structures for tokenized art are a proven scheme: the assets are held by a rights‑holding company, and NFTs sell access to benefits, viewing rights, priority participation in exhibitions, or fractional rights through fractionalized NFT. Fractional ownership legal structures carry particular risks for investors: when ownership is fractionalized, characteristics of a security can sometimes emerge, which may trigger MiFID II.

SPVs and legal wrappers for art tokens are useful for managing taxes, rights, insurance and custody.

Buyback agreements and options on NFTs help regulate investor exit, protect against liquidity shortfalls and address collection buyout scenarios.

investment funds NFTs in the EU can be structured in the form of AIFs with corresponding regulation of the management company, custodian, valuer and auditor – the COREDO team has structured such funds taking ESMA and local supervision into account.

The distinctions between ICO/STO/ITO and the comparison with NFT issuance are needed to understand regulator expectations: STOs are securities; ICOs/ITOs can fall under MiCA; NFT issuance more often does not require a prospectus, but does require disclosure and compliance if investment characteristics are present. COREDO’s experience confirms that early consultation with the regulator reduces costs and speeds up market entry.

Taxes and accounting for NFTs under IFRS

The tax consequences of NFT sales in Europe depend on what is being sold: digital content, access to a service, or usage rights.

Tax accounting: VAT and transactional taxes on NFTs are often treated as the supply of digital services subject to VAT at the place of consumption, and in B2B chains reverse charge mechanisms may apply.

Royalty income may be subject to withholding tax in certain jurisdictions: this is taken into account when structuring SPVs and licensing agreements.

Accounting for NFTs on a company’s balance sheet (IFRS) is closer to accounting for crypto assets: they are more often intangible assets under IAS 38, except when held for trading as inventories under IAS 2.

Accounting entries for acquisition and impairment of NFTs rely on fair value measurement and impairment tests; revaluation is possible when an active market exists, which is uncommon for unique NFTs.

Reporting and disclosure about NFT assets include accounting policies, valuation methodologies, liquidity and concentration risks.

Valuing NFTs for investors is built on three pillars.

First, valuation models: comparable sales (comps) for NFTs from comparable collections. Second, liquidity metrics: floor price, spread, trading volume, and the resilience of demand on the secondary market. Third, a discounted cash flow model for NFT royalty income, if the smart contract and legal agreements ensure a stable stream.

The COREDO team sometimes supplements the valuation with option models for rare cases involving buyback rights.

Smart contracts: standards and insurance

The ERC-721 and ERC-1155 standards and their differences define the ownership and transfer model. ERC‑721: unique “one-to-one” tokens; ERC‑1155: multi-asset model that allows combining unique and semi-fungible tokens.

Smart contracts (ERC-721, ERC-1155) and security are a central part of legal protection: bugs in code can wipe out rights, reduce royalties to zero, or open the door to an exploit.

Smart contract audits for legal protection should combine static analysis, formal verification, and testing of business scenarios: edge cases for listing, token burns, upgrades, royalties, and pauses. Blockchain code audits and formal verification reduce the risk of smart contract vulnerabilities and exploits, while digital asset insurance and loss coverage close out tail risks. Within companies we insist on corporate access control for wallets, role separation, and multi-factor policies.

Institutional custodial infrastructure for NFTs requires custodian solutions for institutional NFTs, SLAs, key recovery procedures, and controls over corporate transactions. Custody APIs and interaction standards enable integrating NFTs with ERP and accounting systems, automating transfers and tags for accounting. The COREDO team helped clients build cold‑hot‑warm storage architectures and asset movement policies aligned with auditors.

Markets and liquidity: risk control

NFT liquidity risk and exit strategies: this is the main area for the CFO. Exit strategies: listings on exchanges, OTC processes with KYC, buyback agreements and NFT options, as well as framework agreements with marketplaces for prioritized listing. Stress-testing the liquidity of an NFT portfolio models a drop in floor price, widening spreads, departure of market‑makers and regulatory shocks.

Controlling manipulation in the NFT market requires on-chain analytics and market activity indicators: monitoring wash trading, address clustering, analysis of holding times, price deviations from the median.

counterparty assessment and marketplaces by reputation reduces the risk of failures in settlements and delistings. The commercial model: fees, royalties, listing fees must be transparent and compatible with antitrust and competition-related risks of marketplaces — especially regarding exclusivity and restrictions on parallel sales.

Institutional players look at blockchain resilience: PoS vs PoW and energy consumption. Carbon footprint and offsetting NFT emissions are becoming part of ESG policy: we build in compensation mechanisms or choose energy-efficient networks. For collateralized deals, using NFTs as collateral (collateral) requires independent valuation, agreements with custodians and tripartite agreements with lenders.

COREDO: case studies and launch roadmap

One example is a European brand that tokenized its photo and video archive. COREDO’s practice confirmed that an SPV in the EU with a licensing model, a white paper and a transparent royalty policy passed an audit without adjustments, and integration of custody APIs with ERP enabled automated accounting under IFRS. The initial risk model included a floor-price stress test and limits on collection concentration.
Another case is a fractionalized NFT platform for rights to lease commercial premises. The COREDO team pre-assessed the MiFID II impact, agreed on prospectus requirements and exemptions, implemented AML/KYC for NFT platforms, the travel rule and SoF, and also deployed transaction monitoring and wash-trading detection. Smart-contract audits, formal verification and digital-asset insurance mitigated operational risks, and SPVs and legal wrappers for art tokens were adapted for real estate.
Below: a concise compliance roadmap for launching an NFT product that we use in projects:
  • Legal qualification: framework ‘security token vs non-fungible token’, MiCA/MiFID II/ESMA assessment, ICO/STO/ITO comparison.
  • corporate structure: SPV, IP agreements, licenses, royalty agreements, option and buyback.
  • Technical architecture: ERC-721/1155 standard, IPFS/Arweave, URI strategy, on-chain provenance.
  • Compliance: AML/KYC, SoF, travel rule, sanctions and export controls, GDPR, cross-border compliance.
  • Infrastructure: custody, insurance, corporate access control to wallets, custody APIs.
  • Taxes and accounting: VAT, transactional taxes, IFRS (IAS 38/IAS 2), disclosures and valuation models.
  • Market and liquidity: listing rules, fees and royalties, OTC processes, stress testing and exit.
  • Interaction with regulators: sandbox, notifications, responses to inquiries, internal reporting and best practices for internal control and reporting on NFTs.

Legal risks in EU practice

Legal disputes and case law on NFTs in the EU are still taking shape, but precedents are already setting the direction. Court precedents regarding the sale of NFTs (European cases) emphasize the importance of clear license terms, fair commercial practice and truthful marketing. Legal enforcement mechanisms in NFT fraud include asset freezes, platform notifications, interaction with custodians and cooperation with law enforcement.

Regulation of secondary NFT markets and marketplace liability require attention to the impact of MiFID II on brokers and platforms, especially when they begin to perform the functions of an organized trading venue.

Export control and sanctions risks of transactions: another reality: when working with clients from different regions, the COREDO team builds filters and blocking processes so that transactions do not violate EU regimes and those of partner jurisdictions.

DAOs as a tool for managing collections and funds have also become relevant in Europe. The role of DAOs in managing collections and funds requires aligning governance tokens and voting rights with off-chain corporate law. We increasingly use a hybrid: DAO voting logic on top of a legal entity (SPV or fund), where mandatory corporate actions are executed by a delegated director.

Payments and banking between on-chain and off-chain

We organize interactions with payment systems and PSPs through acquiring agreements, anti-fraud rules and transparent refund mechanics. Banks expect clear KYC/KYB, SoF logic and a predictable cash flow model.

Для корпоративных клиентов COREDO выстраивает мосты: кастоди для хранения, PSP для мерчанта и банковские счета для расчетов, чтобы снимать вопросы у финансового контроля и аудита.

Cross-border flows require consideration of currency and tax rules. Cross-border compliance for buyers from Asia and the EU includes separation of places of supply for VAT, economic substance tests and agreements with local payment processors.

При крупных продажах due diligence чек-лист перед покупкой крупного NFT включает KYC контрагента, проверку provenance, юридический статус IP, анализ маркетплейса, репутационные риски и страхование доставки цифрового актива.

ESG for NFT sustainability and reputation

Clients in the institutional segment increasingly include ESG criteria. Blockchain sustainability: PoS vs PoW and energy consumption affects network choice. Carbon footprint and offsetting of NFT emissions are configured through compensation programs, green certificates, and sustainability reporting. For public companies this becomes part of non-financial disclosure alongside liquidity and compliance risks.

Assessing counterparties and marketplaces by reputation reduces legal and market risks. We use a combined model: on-chain analytics to detect anomalies and off-chain checks: licenses, beneficiaries, litigation, sanction lists.

This approach protects the portfolio and accelerates deal approvals at the level of boards of directors and risk committees.

Conclusions

NFTs have moved from an experimental status to a managed asset class where legal qualification, compliance and infrastructure are as important as creativity and community. My position is simple: if NFTs are treated as a financial instrument from the start, a business gains transparent processes, clear economics and access to institutional capital. COREDO’s experience in the EU, the UK, Singapore, Cyprus, Estonia, the Czech Republic, Slovakia and Dubai shows: a well-designed SPV structure, clear IP licenses, proper IFRS accounting and AML/KYC discipline turn NFT initiatives from a risky bet into a sustainable product.

If you plan to launch, start with legal qualification and architecture: choose a standard (ERC-721/1155), describe ownership and usage rights, resolve custody and insurance issues, define the tax model and disclose risks in the white paper. The COREDO team will help build a compliance roadmap, align the approach with regulators, audit smart contracts and integrate accounting. This will preserve your speed and provide the reliability on which long-term value is built.

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.

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’.

I have been building COREDO since 2016 and have set up dozens of structures in the EU, the UK, Singapore, Dubai and Central Europe through incorporation, licensing and tax planning. In recent years Portugal has become a notable hub of European crypto business. The COREDO team has implemented a number of projects to create crypto holdings in Lisbon and Porto, and by 2026 the picture has become significantly more mature: MiCA comes fully into force, DAC8 and CARF change the rules of information exchange, and the Portuguese tax regime (IRC) is finally adapting to crypto assets.

In this article I have compiled a practical roadmap: how to choose a legal form, meet substance requirements, obtain CASP registration, set up AML/KYC and accounting under IFRS, plan profit repatriation and withstand tax audits. I rely on specific COREDO cases and break down the key issues: taxes on crypto assets in Portugal, corporate tax (IRC) for Portuguese crypto companies, transfer pricing, Pillar Two and the implications of MiCA/DAC8/CARF.

Portugal’s regulatory landscape 2026

Illustration for the section «Regulatory landscape of Portugal 2026» in the article «Taxation of crypto-holdings in Portugal 2026»

By 2026, the Portuguese ecosystem looks structured. Autoridade Tributária (the Portuguese Tax Authority, AT) issues guidance on crypto operations and monitors declarations. Banco de Portugal oversees the registration of crypto-asset service providers (CASPs), including AML requirements/KYC and the Travel Rule. The Portuguese Securities Market Commission (CMVM) supervises security tokens, prospectuses and trading venues for tokenized securities.

MiCA (Markets in Crypto‑Assets Regulation) introduces unified rules in the EU: By 2026, CASPs operate under standards for licensing and operational risk, reserve requirements for stablecoins and risk disclosure. DAC8 expands the automatic exchange of information on crypto-assets, while the OECD CARF sets a global reporting framework. COREDO’s practice confirms: the “do the minimum and hide” strategy no longer works. Build compliance from the start “for audit” — it saves years, not months.

Private limited company vs public limited company and tax residency

Illustration for the section «Lda vs SA and tax residency» in the article «Taxation of crypto holdings in Portugal 2026»
The following are most suitable for holdings and operating crypto companies in Portugal:

  • Sociedade por Quotas (Lda) – equivalent of a private limited company, flexible management structure, moderate capital requirements.
  • Sociedade Anónima (SA): a form for large structures and public plans, stricter corporate procedures and a board of directors.
When I create a crypto holding in Portugal I start by assessing the group’s prospective structure and investors’ requirements. If a client is preparing for a listing or a Security Token Offering under CMVM supervision, an SA removes a number of barriers in advance. For a family-office holding or a fund, an Lda is more economical to administer. A company’s tax residency in Portugal is determined by its place of effective management: the board of directors, the making of key decisions, local directors and office — the elements on which the AT places emphasis.

substance of a crypto-holding in Portugal

Illustration for the section «substance of a crypto-holding in Portugal» in the article «Taxation of crypto-holdings in Portugal 2026»

Economic justification of substance — not about a “paper” office, but about real activity. I set out the minimum:
  • a resident director with fintech/crypto experience and a real management role;
  • a physical office where meetings are held and originals of documents are kept;
  • local functions: risk management, an AML officer, accounting, preparation of financial reports;
  • contracts with local providers (custody, audit, legal support), reflecting the ‘centre of interests’ in Portugal.
The economic justification of substance pays off twice. Banks open accounts faster, and tax rulings are resolved predictably. A solution developed at COREDO for one crypto group with assets in the EU and Asia reduced banking KYC friction fourfold by transferring the risk function and data governance to Lisbon.

IRC for crypto holdings

Illustration for the section «IRC for crypto holdings» in the article «Taxation of crypto holdings in Portugal 2026»

Crypto-holding Portugal taxes are about IRC and related regimes. The basic IRC rate: 21% on the mainland, to which a municipal surcharge of up to 1.5% and a state surtax on large profits applied progressively are added. For small and medium enterprises a reduced rate applies to the “first tier” of profits. Details change with budgets, but the Effective Tax Rate is usually 22–26%, which is above the Pillar Two threshold.
The conditions for applying the participation exemption in Portugal allow dividends and capital gains on shareholdings to be exempt from tax when the criteria are met: generally a shareholding of at least 10%, a holding period of at least 12 months, taxation of the investee by a comparable corporate tax and absence from a “blacklist”. For a crypto-holding this is the key to tax-optimizing repatriation of funds from subsidiaries in the EU and certain third countries.
Profit repatriation and withholding taxes in Portugal depend on bilateral double tax treaties (DTT) and EU directives. Standard WHT rates in Portugal are 25% on dividends, interest and royalties, but DTTs and the Parent-Subsidiary Directive reduce or eliminate them when conditions are met. The COREDO team implemented a cascaded structuring of payments using the participation exemption and DTTs, reducing aggregate withholding to zero without aggressive schemes.

Taxes on crypto-assets in Portugal

Illustration for the section 'Taxes on crypto-assets in Portugal' in the article 'Taxation of crypto-holdings in Portugal 2026'

AT in 2026 bases its approach on the functional nature of the transaction. For companies, income and losses from crypto-assets form part of the IRC taxable base. The classification of tokens for tax purposes in Portugal is based on their economics:
  • utility tokens, a right of access to a service, accounted for as an intangible asset or a prepayment;
  • security tokens – characteristics of a security, supervision by the CMVM, potential application of rules for financial instruments;
  • asset-backed, asset tokenization, a distinct legal and fiscal profile.
The tax consequences of staking, mining and airdrops differ. Staking is often recognized as operational income as rewards are accrued; mining – entrepreneurial activity taxable under IRC taking into account expenses (electricity, equipment); airdrops and hard forks are taxable events at fair value on the date of receipt with subsequent recognition of gain/loss on disposal. Labeling transactions as: disposals, acquisitions, swaps – allows correctly separating capital gains vs operational income.
Taxes on token exchanges and token-swaps in a corporate environment arise both on sale and on exchange of one asset for another if beneficial ownership or the economic substance of the asset changes. For illiquid tokens I apply conservative valuation models: DCF (if there are cash flows), market comparables from transactions, or last round for tokens related to equity. AT readily accepts documented methodologies; COREDO’s practice shows that a transparent model and independent valuation reports materially reduce the risk of dispute.

VAT on trading crypto assets and NFTs

VAT and cryptocurrency trading: Portuguese rules follow the EU Hedqvist case, fiat/crypto exchange is exempt from VAT as a payment transaction. But not all crypto services fall under the exemption. Custodial services, technical support, SaaS access to protocols, market-making and listing packages are usually subject to 23% VAT in mainland Portugal.

Taxation of transactions with NFTs and tokenized assets depends on their substance. The sale of a digital work of art is an electronic service subject to VAT at the place of consumption (rules for B2C digital services); tokenization of rights to a real asset carries the VAT/stamp implications of the underlying asset and may require registration in the country where the asset is located. VAT refunds and indirect tax relief on the provision of crypto services are possible with correct determination of the place of supply and by keeping separate accounting of input VAT.

CASP Registration: AML/KYC Requirements

The definition of VASP/CASP and registration requirements by 2026 are established by MiCA and local law. Banco de Portugal registers conversion providers, exchangers, custodians, issuers, platform operators.

AML/KYC requirements for crypto holdings and CASPs include:

  • AML‑Risk Assessment, written policies and procedures;
  • KYC/KYB, PEP‑screening and enhanced Due Diligence for investors;
  • Blockchain‑analytics and AML tools (on‑chain monitoring), Travel Rule;
  • financial monitoring and sanctions compliance (FATF Guidance on virtual assets and VASP).
The cost of AML/CTF compliance and a holding’s operational expenses are not a penalty but insurance. In one project COREDO implemented a cascading verification model: auto‑scoring + manual EDD for high risks, integrations with on‑chain monitoring providers and centralized case management. False positives decreased by 37%, and onboarding time was reduced from 12 to 5 days, with total savings of more than 200 person‑hours per month.

UBO Beneficiary Register and Privacy

The UBO register (Registo de Titular Beneficiário) in Portugal is mandatory for all companies. Investor confidentiality and the implications of CARF for UBOs require careful structuring: nominee holders do not solve the problem. I recommend aligning disclosures with the group’s legal strategy, conducting a DPIA under the GDPR for CARF/DAC8 data flows, and drafting contractual provisions with custodian/exchange providers on the division of controller/processor roles.

MiCA, DAC8, CARF: crypto business models

The impact of MiCA and DAC8 on the business models of crypto holdings is expressed in three ways. Firstly, Licensing of CASP and capital/risk management requirements raise the entry barrier but provide a “passport” to the EU market. Secondly, the expansion of reporting under DAC8/CARF makes anonymous schemes expensive and risky. Thirdly, B2B clients demand transparency of the transaction chain and on-chain reports as the standard.
OECD CARF and the automatic exchange of information on crypto transactions are not just about retail. Institutional providers are subject to reporting obligations, and the group must build master data: a single client identifier, beneficiary registers, transaction metadata. Our experience at COREDO has shown: if you design data governance from the start for CARF/DAC8, auditors close issues faster, and AT asks for clarifications less often.

Impact of GloBE on crypto structures

Pillar Two / GloBE rules and the calculation of the effective tax rate are important for groups with revenue ≥ 750 million. Portuguese companies most often report an ETR above 15%, but local incentives and tax credits can shift the calculation. For a holding company, a GloBE “dry run” is useful: detail timing differences, verify the qualification of tax credits, and ensure that participation in reduced-tax regimes will not lead to a top-up in another jurisdiction.
BEPS 2.0 strengthens requirements for economic presence (economic substance) and transparency. I take this into account in the design of holdings: a genuine asset-management function in Portugal and documented processes reduce the risk of adjustments in source jurisdictions.

Transfer pricing for tokens

Transfer pricing: the CUP, TNMM and cost plus methods for token transactions are applicable in the same way as for traditional assets. For intercompany transfers of tokens with market quotations the CUP method most often works (arm’s length at the market price with adjustments for liquidity and lock‑ups). For protocol development and market‑making operations – cost plus or TNMM with margin benchmarking.
Transfer pricing documentation for crypto groups in Portugal is mandatory upon reaching revenue and intercompany turnover thresholds. I prepare the master file and local file, a token valuation policy, a functions/risks/assets analysis, as well as procedures for unpriced events (airdrops, hard forks). Advance Pricing Agreement (APA) and pre‑ruling decisions remove uncertainty; tax resolutions (binding rulings) in Portuguese practice are issued within reasonable timeframes when filed properly.

Accounting for crypto-assets under IFRS and in Portugal

Accounting for crypto-assets under IFRS and Portuguese accounting standards in 2026 follows the approach: crypto-assets: intangible assets (IAS 38), except where traders hold them as inventory at fair value. Impairment, impairment tests and disclosures are mandatory, and the valuation policy is subject to audit. The IFRS project on crypto assets is moving toward clarifying classification and disclosures, and auditors are scrutinizing accounting policies.

Valuation policies and accounting policies for tokens in the annual report must record the choice of mark‑to‑market vs cost basis, sources of prices, and the liquidity hierarchy. Cold wallet vs custodial wallets carry different operational and tax consequences: custodial fees (custody fees) may be charged to expenses, while cold‑storage requires internal access controls and SOX-like procedures for public groups. Internal controls and key management are among the first topics in any due diligence.

Declaration, audits and disputes by 2026

The procedure for declaring cryptocurrencies in the Portuguese tax return is set out in AT instructions: report income/losses, disclose valuation methodologies, and provide notes on non-standard transactions. Tax inspections and audits of a crypto-holding in 2026 focus on three triggers: mismatch between on‑chain movements and accounting, lack of TP documentation for intercompany token transfers, and weak AML procedures.
How to prepare for a tax audit of a crypto-holding in 2026? Maintain reconciliations on‑chain/off‑chain, independent valuation reports, board minutes on key decisions, and reports from the AML officer. Legal support and obtaining tax rulings for the holding help stabilize positions before a dispute begins. The COREDO team successfully closed AT claims on the classification of staking income by providing correspondence with the regulator and justification for income recognition under the accrual method.

Dividends and WHT: profit repatriation

Withholding tax (WHT) on dividends, interest and royalty payments in Portugal is standardly 25%, but bilateral treaties (DTT) allow lowering the rates. Double taxation treaties: Portugal’s WHT rates often fall to 5–15% on dividends and 10% on interest/royalties, and in the EU zero is possible if directive requirements are met. Dividend repatriation and the tax optimization of repatriating funds from a crypto-holding are built around participation exemption and a managed payout schedule.
Re-investment of profits and tax consequences should be aligned with the business cycle: losses on tokens can be carried forward (tax loss carryforward) with a restriction on the share of profits, and R&D credits and tax benefits and incentives for investment holdings in Portugal reduce the burden when developing technologies. I set KPIs: ROI metrics taking into account tax efficiency and compliance costs, so the board sees the full picture, not only the “nominal” rate, but also the cost of compliance.

International structures, family offices

International structures: a branch or a subsidiary for crypto operations, the question of control and taxation at source. A branch is easier to set up, but its profit will be taxed directly in Portugal; a subsidiary is more convenient for participation exemption and managed WHT on dividends. Using a Portuguese holding structure for funds and a family office provides predictability, access to DTT and a clear regime for asset management.
Cross-border transfers of tokens do not fall under customs in the classical sense, but they trigger currency and sanctions compliance, and sometimes local licensing rules. Cross-border payments and banking compliance in Portugal are standardized, but banks require proven substance and transparent sources of funds. Repatriation of capital should be accompanied by banking AML checks and pre-prepared dossiers on counterparties.

DeFi: derivatives and custodial services

Taxation of income from DeFi, yield farming and liquidity aggregation depends on the legal qualification of the contract: rewards – operating income, while derivatives: financial instruments with separate accounting for fair value. In the corporate environment, record the protocol terms, counterparty risk and the PnL valuation methodology. Crypto custody and the tax regime for custodial services in Portugal imply VAT taxation of the service and IRC on the margin.
Security token exchange and CMVM regulation set the framework for STO/listings. ICO/STO and the tax treatment of fees and income require separate accounting: what is a prepayment for a service, what is a debt obligation, what is equity. The COREDO team structured the STO of an infrastructure project under CMVM supervision, agreeing the prospectus and the accounting model for amortization of token liabilities; the investor-side audit passed without remarks.

Governance / responsibility / due diligence

Corporate governance (CG) practices for international crypto holdings include independent directors, a risk and audit committee, SOX‑like requirements for public holdings, and key‑control tests. Liability of directors and executives for tax non‑compliance is real: AT and CMVM expect personal involvement, minutes of meetings, and approval of policies.

Situational due diligence when acquiring a crypto holding checks three areas: tax (IRC, VAT, WHT, TP‑documentation), regulatory (CASP, AML/KYC, CMVM licenses, Banco de Portugal), finance (IFRS, impairment tests, valuation reserves). The role of the tax adviser and the lawyer in structuring the holding is to synchronize these tracks and secure timely binding rulings.

Risks of double taxation and CbCR

Risks of double taxation in cross‑border operations with cryptoassets arise when countries classify transactions differently. Double taxation: exemption, credit, DTT consultations – the standard toolkit, but crypto adds a layer of valuations and events. Country‑by‑Country Reporting (CbCR) for multinational groups requires an agreed allocation of profits and personnel, and crypto functions (protocol development, liquidity management, AML functions) should be reflected where they actually occur.

COREDO cases – what works

  • European crypto exchange and custody. The COREDO team obtained CASP registration with Banco de Portugal, implemented an AML framework with on-chain analytics and obtained an APA on intra-group market-making commissions under TNMM. Result: predictable tax burden and fast bank onboarding for large clients.
  • Family office with tokenized assets. The solution developed at COREDO used Lda as a holding, the participation exemption for dividends from the EU and DTT for royalties. We obtained a binding ruling classifying NFT income as electronic services, established VAT accounting and secured a refund of input VAT on development.
  • DeFi liquidity provider. Our experience at COREDO showed that a documented methodology for valuing remuneration and a compact master file for TP smooth out the rough edges in audits. AT accepted a cost-plus model for service functions and CUP for intra-group liquidity transfers with a discount for locking.

How to set up a crypto holding in Portugal

  • Choice of form (Lda vs SA) and group design under participation exemption and DTT.
  • Confirmation of tax residency: directors, office, board meeting calendar.
  • Registration of CASP (if necessary), appointment of an AML officer, implementation of KYC/KYB, PEP screening, Travel Rule and on-chain monitoring.
  • UBO registry, GDPR‑DPIA and data‑governance policies under DAC8/CARF.
  • Accounting policy: IFRS, token valuation (mark‑to‑market or cost), impairment tests, key control.
  • TP policies: CUP/TNMM/cost plus for token transactions, master/local file, where possible: APA.
  • VAT model: exemptions, electronic services, place of supply, refund of input VAT.
  • Banking compliance: counterparty dossiers, description of flows, confirmation of substance.
  • Audit plan and AT checks: on‑chain/off‑chain registers, AML reports, board minutes.
  • ROI model: tax rate, cost of compliance (KYC/AML, reporting, audits), repatriation and re‑investment scenarios.

Scaling and Exit Strategies

Strategies for scaling the crypto‑business that take tax burden into account rely on diversification of functions within the EU, expansion of the CASP‑license and integration with institutional custody providers. Exit strategies: M&A, asset sale, IPO and tax consequences require early planning, TP‑history, clean IFRS reporting and the absence of “skeletons” in the AML closet increase the deal multiple.

The tax consequences of tokenising assets on the holding’s balance sheet and of custody models need to be recorded in prospectuses and contracts. CMVM closely examines the economics of token rights, and AT looks at the recognition of income and reserves. I recommend preparing pre‑rating solutions and binding rulings before market entry.

Non-compliance risks: case law

Consequences of non-compliance with VAT and AML rules for a holding – from additional assessments and penalties to administrative and criminal sanctions for tax violations. Tax audits: key triggers for audits of crypto‑operations: discrepancies between DAC8/CARF data and reporting, “gray” staking schemes and the lack of a documented valuation of tokens. legal risks and case law on crypto disputes in Portugal are developing rapidly, and predictability increases for those who have obtained AT rulings in advance and agreed prospectuses with the CMVM.

What is important to remember

Taxation of crypto-holdings in Portugal 2026: it’s a system, not a set of life-hacks. Choose a form (Lda or SA), confirm substance, build CASP compliance and AML frameworks, establish the TP model and accounting policies under IFRS, and then plan repatriation taking into account the participation exemption and DTT. Pillar Two, MiCA, DAC8 and CARF do not hinder business – they require discipline and transparency.
COREDO’s practice confirms: the earlier you embed tax and regulatory architecture into the product and processes, the faster you can scale and the lower your cost of capital. If you are planning to establish a crypto holding in Portugal or are reviewing an existing structure, build three steps into the plan: risk assessment, compliance design and preliminary decisions with regulators. This is one of those cases when strategic preparation creates an advantage measured not in words, but in the figures on the P&L and exit multiples.

I have been leading COREDO since 2016, and from the early years I saw how international business in fintech faces not “barriers” but labyrinths. Company registration, obtaining financial licenses, AML/sanctions compliance, building processes across different jurisdictions — these are not a set of disparate tasks but a single architecture of risk management. The COREDO team builds this architecture in the EU, the United Kingdom, Singapore and Dubai, truly integrating legal, financial and technological solutions. Below I share how to think about MiCA, DeFi and compliance today so as not to “keep up with” regulation, but to get ahead of it and monetize predictability.

MiCA: regulation of crypto-assets in the EU

Illustration for the section «MiCA: regulation of crypto-assets in the EU» in the article «MiCA and DeFi – regulation of decentralized protocols»

The MiCA regulation ends the phase of “ruleless experiments” in Europe. Crypto-asset service providers (CASP) have received clear licensing requirements, passporting across the entire EU and obligations on disclosure, risk management and operational resilience. National regulators issue authorisations, while ESMA and EBA set supranational standards and coordinate supervision, including through MiCA technical reporting standards. In practice this means uniform approaches to capital, internal controls, outsourcing and incident reporting.
The token classification under MiCA distinguishes, in particular, e‑money tokens (EMT) and asset‑referenced tokens (ART), including significant asset‑referenced tokens (significant ART). For issuers, there are separate prudential requirements, capitalization and reserve funds for stablecoins, requirements on reserves, liquidity management and MiCA whitepaper obligations. Issuer liability under MiCA increases responsibility for the accuracy of the whitepaper, marketing messages and continuous disclosure of risks, which directly affects the cost of capital and listing conditions.
MiCA has created a new transparency standard: disclosure and whitepaper requirements, proof‑of‑reserves and independent attestation methodologies, passporting requirements for access to the EU market, as well as oversight by ESMA/EBA on top of national control. COREDO’s practice confirms: competent early preparation for licensing of CASP halves time‑to‑market thanks to the right group structure, proactive IT audit and readiness for regulatory questions.

Who is responsible in DeFi under MiCA?

A pressing question is the application of MiCA to DeFi and the regulation of decentralized finance in Europe. Regulators look at actual control and “points of contact” with the user: the front‑end, hosting, search aggregators and gateway sites; key contributors; DAO decisions that affect protocol parameters; oracle operators and administered treasury multisigs. If there is a centralized provider that operates the interface, routes traffic, manages upgrades or receives fees, it may be qualified as a CASP with licensing requirements.
The legal status of DAOs in Europe remains fragmented, but predictability is emerging: a legal wrapper mechanism for DAOs (foundation model vs corporate wrapper) is used to fix liability, enter into contracts and implement AML/KYC for on‑ramps and off‑ramps. The COREDO team has implemented structures with foundations and operator companies that allocate responsibility between on‑chain governance and off‑chain governance through clear corporate documents, upgrade and delegation policies. This reduces front‑end liability risks and simplifies engagement with regulators and exchanges.
Extraterritorial application of rules and enforcement is a reality: if a service is available to EU clients, it may be required to be brought into compliance with MiCA and AMLD5/AMLD6. Inter-regulatory cooperation (ESMA, EBA, and central banks) strengthens data and practice sharing, and this raises the stakes: it is better to build compliance‑by‑design in advance than to respond to external requests.

Requirements for stablecoin issuers

Stablecoins under MiCA are divided into e‑money tokens (EMT) and asset‑referenced tokens (ART). For EMT, rules similar to electronic money apply: capital requirements, issuance and redemption at par, segregation of funds and liquidity. For ART — obligations on reserves and their management, including high‑quality liquid assets, regular reports, stress tests and, for significant ART, higher buffers and EBA supervision. Disclosure via the whitepaper and ongoing disclosures supports investor and partner confidence.
Proof‑of‑reserves: a working tool, but not a silver bullet. It needs methodologies covering not only assets but liabilities, related parties, as well as exception procedures and incident reporting. COREDO experts introduce combined procedures: independent attestations, on‑chain evidence, SLAs with custodians and auditors, and mechanisms to suspend operations when reserve covenant breaches occur. The result is liquidity resilience and a reduction in the risk premium on listing and partner integrations.

AML/KYC in DeFi – compliance with FATF/MiCA

Illustration for the section «AML/KYC in DeFi - compliance with FATF/MiCA» in the article «MiCA and DeFi – regulation of decentralized protocols»

Compliance with AML requirements and conformity with FATF and MiCA are the basis for access to banking services and partner ecosystems. FATF guidelines (VASP and FATF guidance for DeFi) and the European AMLD5/AMLD6 framework enshrine CDD (customer Due Diligence), beneficial ownership, sanctions lists, the travel rule and SAR (suspicious activity reporting). For DeFi teams the key is to separate the on‑ramp/off‑ramp and protocol parts, implementing a risk‑based approach (RBA) for critical points: fiat on‑ramps, token bridges, centralized infrastructure components.
Sanctions compliance and monitoring of on‑chain transactions require integrating blockchain analytics providers, counterparty risk assessment scenarios, sanctions lists and on‑chain blocking when prohibited addresses are detected. At COREDO we build escalation and SAR playbooks, automate flags and reporting, and establish compliance KPIs so the board of directors can see the dynamics: share of automated decisions, time to escalation, number of cases involving law enforcement.
The travel rule is not only a legal but also a technical challenge. For CASP and VASP we design routing of identifiers, exchange of payer/recipient attributes, storage of minimally sufficient data and rejections when a counterparty is absent. In decentralized applications we address this via on‑ramp/off‑ramp, gateway services and partner VASPs, which allows preserving the permissionless core of the protocol while meeting requirements.

How to implement KYC in a DEX without compromising UX

Choosing a “strict KYC for everyone” approach is simple but costly in terms of liquidity outflow. A more resilient option is flow segmentation: KYC for functionality that triggers legal requirements (for example, fiat on‑ramp; elevated limits; professional accounts), and risk scoring for the rest of the traffic. zk‑KYC and privacy‑preserving KYC based on zero‑knowledge proofs help verify attributes without revealing personal data to the protocol. This enables a balance between privacy and transparency (privacy vs transparency) without compromising AML.
Integrating KYC providers with on‑chain UX requires an architecture: where to store proofs, how to synchronize statuses on the front end, how to handle appeals. The solution developed at COREDO includes a modular API layer, an event log, sanctions monitoring logic and re‑verification mechanisms. For the travel rule we apply messaging protocols between VASPs and configure failure modes at the smart contract/front end level when attributes are absent.

Smart contract risks and compliance

Illustration for the section 'Smart contract risks and compliance' in the article 'MiCA and DeFi – regulation of decentralized protocols'

Smart contract audits and compliance requirements are not a formality. We build a secure development lifecycle with threat modeling, static/dynamic analysis, bug bounty programs and formal verification of smart contracts when justified by risk. Smart contract upgradeability and fork risks are addressed by upgrade policies, timelocks, on-chain governance and audit logs. Fork governance and allocation of responsibilities are recorded in documentation to avoid ‘surprises’ during contentious upgrades and emergency patches.
Oracles are a critical component. We translate oracle risks and their legal regulation into practical oracle SLAs: update frequency, sources, failure procedures, deviation limits, as well as oracle decentralization across multiple providers and a fallback mechanism. Methods to mitigate oracle risk include TWAP, cross-checking sources, quorum confirmations and a trading halt mechanism for extreme deviations. This is an important part of operational resilience and the SLA requirements regulators ask about.
MEV, frontrunning and regulatory risks are no longer exclusively a technical topic. We set up MEV-bot monitoring, implement anti-frontrunning mechanisms (private mempool, commit-reveal, batching) and document a risk disclosure policy for users. For AMMs and DEXs legal requirements differ from CEXs: centralized exchanges carry full responsibility for custody and execution, while DEXs focus on front-end liability, analytics data and points of centralized control. Liquidity pools and pool mechanics require disclosure of impermanent loss as a business risk and description of effects for LPs in the whitepaper and the interface.
Flash-loan attacks and legal response mechanisms include incident reporting, interaction with law enforcement and regulators, freezing funds at partners’ custody nodes and a documented response playbook. Custody vs non-custodial: legal consequences differ; for custodial models custodian requirements apply, including multisignature wallets (multisig), threshold signature schemes (TSS) and multi-party computation (MPC) for custody, controlled through internal policies and external audits.
Finally, third-party and supply chain software risk, cloud-hosting risks and provider dependencies require a registry of critical dependencies, supplier due diligence, resilience tests and contractual SLAs. Operational resilience is a separate MiCA module: continuity plans, stress scenarios, backup channels, availability KPIs and reporting on security incidents and breaches.

Consequences of MiCA for blockchain startups

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Our experience at COREDO has shown: MiCA is not only a “cost of compliance”, but also a reduction in the cost of capital and barriers to market entry. Passporting of services under MiCA (passporting) opens up scaling in the EU without re‑licensing in each country, provided CASP capital requirements are met and risk policies are configured. For cross‑chain compliance and bridges it is important to address cross‑border enforcement and jurisdictional risks: record the place of service provision, KYC/sanctions policies at transitions, and locking mechanisms.
risk management of composability risk requires a registry of dependencies: oracles, lending markets, insurance, bridges. TVL (total value locked) as a risk metric is not an end in itself: liquidity resilience, creditor concentration and correlations with external shocks are more important. Emission policy and token regulation must take into account the legal status of tokens and tokenomics: for governance tokens, legal liability arises when holders or a council of delegates exercise de facto control. The separation of on‑chain governance vs off‑chain governance through corporate documents and regulations helps here.
Regulatory sandboxes for DeFi are an effective tool for testing KYC models, the travel rule and oracle solutions. In a COREDO project with a startup in the EU, a sandbox allowed agreeing on a zk‑KYC mechanism and tuning SAR automation before production launch. For due diligence when launching a DeFi project we perform legal and technical audits, assess smart‑contract insurance and market solutions, and also plan protocol migration under MiCA: action plan, timelines, KPIs and budget.
Assessment of compliance costs and ROI for DeFi projects includes a cost‑benefit analysis of AML implementation, compliance efficiency metrics and KPIs, as well as an evaluation of the effect of listings, partnerships and banking access. Compliance‑as‑a‑service reduces fixed costs through outsourcing reporting, monitoring, the travel rule, sanctions screening and incident management. When the board of directors sees transparent metrics, the decision to invest in compliance ceases to be a “necessary evil” and becomes a growth driver.

COREDO launch plan under MiCA

Illustration for the section ‘COREDO launch plan under MiCA’ in the article ‘MiCA and DeFi – regulation of decentralized protocols’

  • Jurisdictional strategy. Define the entry point into the EU considering the type of services (CASP), capital requirements and operational base. Take into account access to talent, regulatory practice and authorization timelines with the national regulator.
  • Licensing and passporting. We assemble the licensing package, describe controls, and plan passporting to the second wave of EU countries. We embed MiCA technical reporting standards and procedures for interaction with ESMA/EBA.
  • AML/sanctions and the travel rule. We design RBA, CDD, beneficial ownership, SAR and sanctions processes. We set up KYC for on‑ramp and off‑ramp; travel rule: technical and legal implementation, rejection policies.
  • Technology and security. SDLC, audits and formal verification, upgrade policy, oracle SLA, MEV controls, custody architecture (multisig/TSS/MPC). We set up incident reporting and a response playbook.
  • Transparency and disclosure. Whitepaper obligations under MiCA, best practices for risk disclosure (impermanent loss, oracle/MEV, liquidity), proof-of-reserves and methodology limitations.
  • Governance and DAO. Legal wrapper for the DAO (foundation or corporate), allocation of responsibilities, on‑chain/off‑chain governance rules, front‑end liability and agreements with providers.
  • Operational resilience. SLA, continuity plan, redundancy, third‑party and cloud risks, stress-scenario testing, incident reporting and interaction with law enforcement.
  • Listing and scaling. Preparation for listings/integrations, compliance KPIs, passporting, inter-regulatory communications and a migration plan for MiCA updates.

Case studies: practice becomes the standard

First case — a DEX with Asian roots that requested access to EU clients. The COREDO team implemented a hybrid model: a permissionless core of the protocol, KYC/AML and the travel rule on on‑ramp/off‑ramp and professional accounts, zk‑KYC to preserve UX and integration with blockchain analytics providers. As a result, the project obtained CASP licensing for part of the services, a whitepaper on MiCA and a passporting route. The user funnel and TVL grew thanks to institutional partners for whom compliance predictability is critical.
Second case, an issuer of a stablecoin of the asset‑referenced token (ART) type with the ambition to reach significant ART status. We built a reserve policy, developed a proof‑of‑reserves with independent attestations and on‑chain publication, as well as liquidity stress tests and risk disclosures. The regulator accepted the whitepaper and the continuity plan, and custodian partners confirmed SLAs for the reserve assets. This is a typical example where regulatory requirements became the foundation for listing and integrations into payment rails.
Third case, a DAO launching a lending protocol with oracle dependencies. At COREDO we proposed a legal wrapper via a foundation and an operating company with a clear allocation of responsibilities, implemented oracle decentralization and a fallback mechanism, an upgrade policy and a timelock. Additionally, we set up MEV monitoring and SAR procedures, recorded front‑end liability in contracts with hosting and gateway sites. The project passed due diligence with institutions and obtained smart contract insurance with a premium discount thanks to a mature SDLC.

Compliance: tools and automation

Automation of compliance and compliance-as-a-service is KPI dashboards, AML scenarios, control points for the travel rule and sanctions, and dependency registers for composability risks. We implement on-chain analytics and blockchain forensics, build SAR and reporting channels, and configure performance metrics: share of alerts closed automatically, average TTR/TTI, flag accuracy, conversion to listings/partnerships after compliance improvements. This approach makes it possible to relate compliance CAPEX/OPEX to revenue and ROI metrics.
For proof-of-reserve we apply combined methodologies: cryptographic proofs, confirmations from custodians, independent attestations of liabilities, and reports for users and regulators. We are candid about PoR’s limitations and propose countermeasures: reporting frequency, coverage completeness, and ‘red button’ mechanisms. Transparency: it’s not a one-time publication, it’s a process.

Frequently asked questions and answers

  • CEX vs DEX: regulatory distinction. Centralized exchanges have the full range of CASP obligations, including custody. For DEXs, attention is on the interface, centralized components, AML on on-/off-ramps and the responsibility of DAOs/developers when there is de facto control.
  • Who bears responsibility in permissionless protocols? Where there is control or influence (front-end, admin keys, oracles, treasury), the regulator sees those responsible. A legal wrapper for the DAO and distribution of functions reduce risks and improve manageability.
  • How to apply the travel rule in decentralized applications? Through partner VASPs for fiat and centralized bridges, attribute exchange, refusing transfers when data is absent, and logic on the front-end/contracts.
  • Proof‑of‑reserves: limitations. Without accounting for liabilities and affiliated risks, PoR is misleading. A combined methodology and regular independent audits are needed.
  • MEV and frontrunning: how to reduce regulatory risk? Implement anti-frontrunning mechanisms, disclose risks, monitor abuses, document response policies and incident reporting.

Compliance as a scaling strategy

MiCA raised the bar, but at the same time made the market predictable. When a founder has a clear roadmap, CASP licensing, AML/KYC and the travel rule, operational resilience, proof‑of‑reserves, a whitepaper and passporting – access to capital and partnerships expands. At COREDO this is not theory: the practice of projects in the EU, the UK, Singapore and Dubai has shown that mature compliance reduces the cost of risk and accelerates sales.
I am convinced: DeFi and decentralized protocols will grow where the architecture of legal and technological solutions is designed in advance. The COREDO team helps embed compliance‑by‑design into the product: from a legal wrapper for DAOs and governance models to oracle SLAs, SDLC and automated AML. If you are facing the decision to register a structure in the EU, come under MiCA, obtain licenses for crypto services and build AML frameworks, there should be no guesswork — only data, methodologies and a partner you can trust for the long term. This is exactly how we build projects that withstand scrutiny by the market and time.

I founded COREDO in 2016, and since then I have seen every day how entrepreneurs lose momentum because of regulatory uncertainty. This is especially noticeable in projects with virtual assets: licensing, AML, bank accounts, infrastructure — too many things are moving at once. In this article I have compiled the practices our team has tested in the EU, the UK, Estonia, the Czech Republic, Cyprus, Singapore and Dubai, and I also examined in detail the topic “Crypto licensing in Bulgaria” with a focus on VASP registration in Bulgaria, AML requirements and the impact of MiCA. This is not a forward-looking overview, but practical steps, metrics and solutions that help teams launch on time, keep compliance risks under control and achieve a predictable ROI.

Bulgaria: an entry point for VASP

Illustration for the section 'Bulgaria: an entry point for VASP' in the article 'Crypto license in Bulgaria for small VASPs'

Bulgaria attracts with the simplicity of company incorporation, a modest corporate tax and flexible approaches to registering virtual asset service providers. crypto company registration in Bulgaria proceeds without excessive barriers: the corporate structure is set up quickly, and VASP registration relies on the EU anti‑money‑laundering requirements (AMLD5/AMLD6) and national rules. For a startup this means a shorter regulatory lead time and a manageable time‑to‑market.

On the plus side — clear access to the EU, proximity to key payment rails and the assurance that the national framework is compatible with future MiCA authorization. On the downside: increased scrutiny from banks toward crypto business and the need to demonstrate mature AML/KYC and operational security from day one. COREDO’s practice confirms: a sound AML architecture and a demonstrable risk management model remove most objections from banks and payment partners.

AMLD5/AMLD6 and MiCA: the role of registers

Illustration for the section «AMLD5/AMLD6 and MiCA: the role of registers» in the article «Crypto license in Bulgaria for small VASP»

Today Bulgaria applies a VASP registration model (exchange services and custodial wallets) in state registers and under AML supervision. The FIU (Financial Intelligence Unit) functions are performed by the Directorate of Financial Intelligence, and VASP accounting is conducted in accordance with national norms and the requirements of AMLD5/AMLD6. Licensing of virtual assets in Bulgaria is often used as a market term, but legally it is a registration regime with compliance, reporting and inspection obligations.

MiCA and Bulgaria

MiCA introduces a pan-European authorization for CASP (Crypto‑Asset Service Providers) and uniform standards: capital, governance, client protection, as well as passporting. The impact of MiCA on VASP licensing in Bulgaria is twofold: on one hand, the existing VASP registration serves as a “temporary berth” for launching; on the other, it creates a basis for future CASP authorization with minimal process refactoring. Our experience at COREDO has shown that the “migration” from a registration regime to MiCA authorization proceeds smoothly if you account in advance for the minimum capital requirements, governance and information security (IS).

EU passporting for VASP

MiCA opens full EU passporting for CASP: having obtained permission in one EU country, you can offer services across the Union. Before MiCA, companies have to rely on equivalence, local registrations or “mutual recognition” frameworks, which complicates cross‑border compliance. The solution developed at COREDO envisions choosing Bulgaria as the “base” state with a subsequent expansion plan via MiCA passporting once the rules are fully in force.

EU anti-money laundering legislation and the FIU

VASP in Bulgaria are obliged entities. They perform KYC/KYB, CDD and EDD, implement transaction monitoring and submit SARs (suspicious activity reports) to the FIU. Regulations for crypto exchangers in Bulgaria require an internal AML policy, risk assessment procedures, appointment of an MLRO (Money Laundering Reporting Officer) and staff training. The regulatory landscape also includes FATF requirements, including the Travel Rule for VASP‑to‑VASP and transactions to non-custodial wallets (VASP‑to‑OB) through additional checks.

VASP business models — compliance with regulations

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Each model — exchange, brokerage, custodial service, OTC, payment gateways — carries its own risks and a set of prudential measures. I often ask founders to start with a risk appetite statement and a process map: without this it is difficult to align the AML framework, technical architecture and capital requirements.

Prudential capital requirements

Capital requirements for VASPs in Bulgaria are currently modest at the registration stage, but MiCA introduces threshold capital requirements and minimum reserves by type of service. Minimum registration capital requirements for VASPs in Bulgaria depend on the corporate form, while the future MiCA authorization foresees fixed levels (benchmarks of 50–150 thousand EUR by service type). I recommend building in a buffer: regulators value a conservative approach to capital and liquidity.

Corporate structure and governance

Legal structure, holding, subsidiaries, branches: determine the tax burden and the manageability of risks. Corporate governance and directors’ responsibilities require real control: regular meetings, a risk committee, minutes, independent audits. The COREDO team has implemented corporate frameworks where the duties of the MLRO, CTO and the risk director do not critically overlap, and backup authorities ensure business continuity (BCP/DR).

Tax optimization and transfer pricing

Taxation of crypto companies in Bulgaria is based on the general corporate tax (10%) and local VAT rules. Crypto–fiat exchange operations in the EU are often exempt from VAT, but the details depend on the specific service and the contract with the client. In transfer pricing, transparency and documentation are mandatory, especially for cross-border services within a group.

Company registration prior to VASP

Illustration for the section 'Company registration prior to VASP' in the article 'Crypto license in Bulgaria for small VASP'

The COREDO team regularly runs “end‑to‑end” projects where we take on the full cycle: from company formation to the “go‑live” launch of operations, including bank accounts, AML policy and technology implementation.

Company registration in Bulgaria

Opening a company in Bulgaria for a crypto project typically takes 5–10 business days after the package is prepared. Beneficial owners and directors are entered into the register, UBO (Beneficial ownership disclosure) is disclosed, and compliance officers are appointed. requirements for beneficiaries and the ownership structure for VASP in Bulgaria include transparent source of funds and clear control.

VASP in Bulgaria: documents and AML

What documents are required for an application for a crypto license in Bulgaria? In practice, these are:

  • incorporation documents, ownership structure and UBO confirmations;
  • business plan describing services and a risk map;
  • KYC policy/KYB and client verification, including passport verification for VASP in Bulgaria;
  • CDD/EDD procedures for crypto companies and sanctions screening scenarios (OFAC/UN);
  • AML policy tailored to local law;
  • appointment of an MLRO with verified qualifications;
  • InfoSec package: access control, logging, incident response plan, BCP/DR.

How to prepare an AML policy for VASP in Bulgaria? I recommend building it around a risk assessment by products and client segments, Travel Rule implementation, EDD triggers, and SAR procedures with clear SLAs for escalations.

Realistic timelines and cost

license processing times for VASP in Bulgaria (registration) depend on the completeness of the package and the readiness of the AML architecture. In our practice: 4–8 weeks for VASP registration after incorporation and agreement on the AML package. The cost of VASP licensing in Bulgaria consists of legal services, AML/IB consulting, notary and state fees, and the technology stack; TCO for the first year varies depending on the model (exchange vs custody) and the level of automation.

How to reduce the risk of rejection

The risks of license refusal for VASP in Bulgaria are most often associated with:

  • a weak MLRO track record and lack of relevant cases;
  • incomplete disclosure of UBO and source of funds;
  • formal AML procedures without real control points;
  • inadequate IT security.

A solution developed by COREDO, preliminary diagnostics, MLRO verification, a Travel Rule stress‑test and piloting of monitoring before submission.

Compliance architecture AML/KYC

Illustration for the section 'Compliance architecture AML/KYC' in the article 'Crypto license in Bulgaria for small VASP'

Compliance procedures for small VASP require balance: excess control harms the customer experience, lack of it increases SARs and regulatory inquiries. I build a “layered” architecture: from risk policy to technology and KPIs.

Reporting to the FIU and AML requirements

AML requirements for VASP in Bulgaria include:

  • Risk Assessment and Risk Appetite with annual updates;
  • CDD/EDD scenarios and periodic KYC refresh;
  • transaction monitoring in real time and rule engines;
  • SARs, procedures for filing suspicious reports to the FIU;
  • Reporting requirements for VASP in Bulgaria on training, incidents and internal audits.

Adapting AML processes when entering the European market from Bulgaria affects reporting formats and the depth of sanctions screening.

KYC/KYB: sanctions and GDPR

KYC for crypto companies in Bulgaria is built on multi-level verification: document, biometrics, liveness, geo-risks. Best KYC practices for Bulgarian VASP include PEP screening and sanctions lists (OFAC/UN, EU), plus additional rules for legal entities (KYB). GDPR and personal data protection for VASP are a separate priority: data residency and storage of KYC data, data subject rights, DPIA for high-risk processes.

Blockchain transaction analytics

How to provide AML transaction monitoring for small VASP? We combine behavioral rules, chain analysis and transaction monitoring tools, as well as heuristics for addresses. False positive rate is a key metric: I aim for a controlled range with MTTR for incidents and SLAs for escalations, so that compliance does not paralyze the business.

MLRO: independent review and audit

Requirements for the MLRO (qualifications, independence, access to the board of directors) set the tone for the entire function. Requirements for internal audit and independent review of compliance – an annual cycle, coverage of key processes, sample testing and a report to the board of directors. AML training and staff upskilling form the overall culture and reduce operational mistakes.

Compliance team KPIs

Compliance team KPIs: SAR conversion rate, MTTR for incidents, SLA for KYC, share of EDD cases, false positives rate, results of independent reviews. COREDO’s practice confirms: transparent metrics improve dialogue with banks and regulators.

Custody, keys, access

The technology stack affects risks as much as the legal form. I rely on the principles of “security by design” and certification.

Custody key management

Custody models: custodial vs non-custodial define different depths of control. Requirements for cold and hot wallet management under Bulgarian regulations are described at a high level, so we cover them with best practices: HSM, MPC, threshold signatures and multi‑sig. Key management (custody) procedures for VASP Bulgaria include role separation, on-call shifts, segmentation and change control.

Information security and continuity

ISO 27001, SOC 2 and cybersecurity standards create a foundation of trust. Access control, IAM and least privilege principles reduce insider risks; audit trail and logging requirements help incident response and audits. Operational resilience and business continuity (BCP/DR) are a mandatory part of risk passports.

Integrations and liquidity

Integration with exchanges and liquidity pools requires API integration and security standards, as well as counterparty assessment. Technology stacks for VASP – from KYC/AML to Wallet and Custody – we select taking into account the target revenue model and TCO so as not to “overheat” CAPEX at launch.

Bank accounts and payment partners

Bank account for a crypto company in Bulgaria: a common question among founders. I always say: accounts are opened not by presentations, but by your compliance and case study.

Agreements with banks and EMIs

Agreements with banks and payment providers in the EU require clear limits, described VASP‑to‑OB scenarios, completion of Due Diligence and demonstration of a control environment. Interaction with banks and payment partners for VASPs in Bulgaria is built on a transparent risk assessment and clear SLAs for monitoring. When a bank is conservative, we add EMI solutions with SEPA and fast onboarding.

Data management

We design data residency and KYC data storage with GDPR, liability insurance and retention requirements in mind. This simplifies checks and reduces friction with banks.

Entering EU markets

How to scale a VASP after obtaining a license in Bulgaria? I recommend a two‑track strategy: compliance maturity and commercial expansion.

How to bring the product to market

Market‑entry and go‑to‑market procedures for VASPs depend on the segment: retail, B2B, institutional. Revenue models, fee‑for‑service, spread, custody fees, dictate UX, SLAs and even compliance metrics. The COREDO solution: launching pilot segments with a controlled budget and measurable LTV/CAC to avoid “burning” capital at an early stage.

Cross-border license compatibility

Cross‑border compliance and a multi‑jurisdictional strategy involve matching local rules with the future MiCA passporting. Compatibility of a Bulgarian license with licenses of other EU countries becomes linear after MiCA: passporting replaces the cascade of local registrations. Until then we choose “core” markets and providers to avoid duplicating costs.

What regulatory sandboxes are

Regulatory sandboxes and pilot regimes in the EU can give an edge on time‑to‑market. In Bulgaria the focus is on careful pilots with banks and EMIs, where the compliance architecture is already in place and easily auditable.

TCO, unit economics and project ROI

The decision to obtain a license is about economics. I ask teams to record TCO and unit economics from day one.

TCO and compliance costs

Compliance costs and the TCO (Total Cost of Ownership) assessment include: legal support for the VASP in Bulgaria, AML/IB platforms, audits, training, independent checks, policy updates and insurance. Add overhead for regulatory lead time and capital reserves.

Unit economics: CAC/LTV and revenue models

Unit economics of the license: CAC and LTV for the VASP show the model’s resilience. For a spread model liquidity and turnover are important; for custody, AUC (assets under custody) and fees. Real-time transaction monitoring and rule engines are not only about risk but also about conversion: a low false-positive rate strengthens the UX.

ROI, NPV and payback

How to assess the ROI from licensing a VASP in Bulgaria? Compare NPV taking into account TCO, expected customer base growth and the timing for MiCA passporting. ROI metrics — payback period and NPV — become more predictable with a stable regulatory lead time and clear agreements with banks.

COREDO Case Studies: What Worked

I believe in the power of case studies: they are better than any declarations.

Small EU VASP: launch and risk control

A European startup chose Bulgaria as its base. The COREDO team implemented the incorporation, prepared the AML package, established the Travel Rule and deployed blockchain analytics. Result: VASP registration in six weeks, banking infrastructure via an EMI, FPR below 8% at launch and MTTR of incidents under 24 hours.

Lesson: a well‑designed compliance architecture speeds up both client onboarding and the dialogue with banks.

Asian fintechs entering the EU via Bulgaria

A client with a strong product and mature AML from Asia requested compatibility with the EU. We adapted KYC/KYB, conducted a compliance audit for a VASP in Bulgaria, built cross‑border compliance and prepared a MiCA roadmap.

Result: launch of a B2B channel in the EU, controlled expansion and agreements with payment partners.

Custodial platform: technical security

The custodial provider arrived without a clear key management policy. We implemented HSM/MPC, separated cold/hot processes and prepared an ISO roadmap.

After an independent review, compliance and SOC 2 preparations, the project received approval from the banking partner.

Founders’ Frequently Asked Questions

I’ve collected the questions I hear most often and the answers that work for us.

What documents are needed at the start?

What documents are required to apply for a crypto license in Bulgaria: charter documents, evidence of UBO, business plan, AML/KYC policies, appointment of an MLRO, infosec package, evidence of source of funds. For certain models we add descriptions of custody processes, stress scenarios and BCP/DR.

Beneficiaries, personnel and partners

Requirements for beneficiaries and ownership structure for a VASP in Bulgaria include transparency of sources, absence of sanction-related risks and a clear chain of control. Conditions for employed staff and resellers in a Bulgarian VASP entail AML training, third-party oversight and outsourcing compliance only while the licensed entity retains responsibility. PEP checks are mandatory, sanctions screening is continuous.

How to choose a legal partner

How to choose a law firm to support a VASP license in Bulgaria? Look for a combination: EU case experience, AML audit experience, technological expertise (Travel Rule, custody, ISO), and the ability to build a dialogue with banks.

Professionals speak the language of business: unit economics, TCO, time-to-market, not empty words but parameters of the roadmap.

Relationship with banks and reputation

Reputational risks and crisis management are part of strategy, not an “after-the-fact” response. Include the crisis‑plan in the BCP, prepare communications, logging and an audit trail for the quick reconstruction of events. Agreements with banks and payment providers in the EU benefit from such maturity.

VASP registration in the EU via Bulgaria

If your clients are in the EU, Bulgaria provides a quick start, straightforward VASP registration and preparation for MiCA. The compatibility of Bulgaria’s license with the licenses of other EU countries will strengthen as MiCA and passporting are fully implemented. This reduces fragmentation and the costs of duplicating compliance.

VASP business model for Bulgaria

How to structure a VASP business model to comply with Bulgarian regulations? Highlight services (exchange, custody, brokerage), describe customer segments, risks, sources of liquidity and EDD procedures. Add prudential measures, compliance KPIs and a roadmap to MiCA with target capital thresholds.

COREDO’s Position and Conclusions

I lead projects where speed is as important as reliability. Bulgaria gives entrepreneurs the chance to open a company quickly, complete VASP registration and simultaneously prepare for MiCA realities: EU passporting, common standards and predictable requirements. The COREDO team has implemented dozens of such routes, and I see consistent patterns: a strong MLRO, a mature AML architecture, technological discipline (HSM/MPC, IAM, ISO 27001/SOC 2), a transparent economic model (TCO, CAC/LTV, NPV) and a calibrated plan “registration – launch – scale: MiCA”.

Legal support for VASP in Bulgaria is not about paperwork; it’s about a strategy where compliance becomes a competitive advantage. If you are evaluating a crypto license in Bulgaria or a VASP license in Bulgaria as a route into the EU, lay the right foundations: uncompromising AML/KYC, managed operational security and a clear revenue logic. Then the “regulatory wind” will fill your sails, not blow in your face.

I founded COREDO in 2016, and since then our team has supported dozens of international projects: from company incorporations in the EU and Asia to obtaining crypto, payment and forex licenses. Over the years one topic consistently returns to the agenda of executives and CFOs: whether it is possible to work with clients from the EU without a license if the contacts originate from the clients themselves. This is MiCA reverse solicitation — a narrow corridor of lawful cross-border servicing where the time to market, compliance risks and profitability are at stake.

MiCA: what falls within the scope

MiCA forms an EU-wide perimeter for CASPs (crypto-asset service providers) and for the assets themselves. Within the perimeter are asset-referenced tokens (ART), e-money tokens (EMT) and most other tokens that are not financial instruments under MiFID II; some utility tokens may fall outside MiCA if they are not traded on trading platforms and only provide access to an existing product.

MiCA rules for CASPs cover custody and administration of crypto-assets for clients, trading platform operations, exchange of crypto-assets for fiat or other assets, order execution, crypto-asset placements, receipt and transmission of orders, and crypto-asset advisory. If you perform these functions for EU clients from the territory of a third country, you must understand the boundaries of MiCA reverse solicitation and the national rules of complementation in individual member states.

The European Securities and Markets Authority coordinates practice together with national competent authorities (NCAs), but enforcement details are often shaped at the country level. Our experience at COREDO has shown: ignoring local guidelines is a short route to enforcement and regulatory inquiries, even if formally you rely on pan-EU rules.

What is reverse solicitation
I use a working definition: MiCA reverse solicitation is a situation where an EU client on their own initiative (client-initiated contact) approaches a provider in a third country, and that provider provides a service without prior individual or mass solicitation of demand in the EU. This is the passive reception doctrine: you accept a passive inbound, rather than creating an economic nexus by active measures in the Union.

The logic of “without prior solicitation” means no cold outreach, targeted advertising, roadshows, partner referrals tied to EU territories, or bypass communications before the moment of request. Pre-contractual communication under MiCA is allowed only as a response to a client-initiated contact, without expansion into marketing and without converting the dialogue into a mass campaign.
Requirements for websites and public information are critical here. If a site has an explicit call-to-action for EU residents, is localized in the domain zone of a specific EU country, uses EU-IP targeting, or offers promotions for the EU: NCAs may treat this as providing crypto services without an EU license, rather than as reverse solicitation. At COREDO we often begin an audit with an inventory of the digital footprint: banners, landing pages, cookie policy, geotargeting, testimonials, coverage maps.

MiCA licensing logic and exceptions
Exceptions to MiCA’s licensing obligation essentially boil down to the correct application of reverse solicitation, but national regulators calibrate the threshold of permissible actions differently. In one COREDO project for a client from Dubai we agreed with local lawyers in two EU jurisdictions the boundaries of permissible web communication: neutral content, no personalized offers, a strict ban on EU-ID retargeting.

MiCA transitional provisions are important for providers already operating under local regimes before full implementation. At the same time transitional provisions do not make reverse solicitation limitless: NCAs continue to apply their own economic presence tests, and ESMA publishes enforcement guidance that influences interpretations.

Servicing EU clients from a third country (onshore vs offshore servicing) is permissible in the absence of presence and substance in the EU, by forming a contractual structure outside the EU and building processes around passive reception. But as the share of EU clients grows and onshore teams, representative offices or agents appear in the Union, the risk of forced jurisdiction and enforcement arises.

Legally offering crypto-asset services
The key question is how to document inbound client requests. The solution developed at COREDO includes multi-level recording of client-initiated contacts in the CRM and web platform logs: recording the original click source, storing the voluntarily submitted contact form, timestamp, IP and geodata, as well as screenshots of user journeys.

Best practices for crypto service providers include an opt-in onboarding process where the client confirms they initiated the contact independently, understands the absence of an EU license and acknowledges that servicing is provided from a specific third country. Consent documentation and record-keeping requirements under MiCA require retaining these confirmations for periods at least equal to the document retention policy adopted in your jurisdiction and aligned with EU expectations.

The evidentiary basis in a dispute with a regulator relies on audit trails and IT logging. At COREDO we add to the legal memorandum an evidence preservation layer: captured versions of the site at the time of contact (web archives), cold campaign logs (showing zero EU targeting), internal instructions to managers prohibiting proactive contacts. Such COREDO practice demonstrates that even in the event of a regulatory request you can present a structured defense line.

KYC and EDD under reverse solicitation
AML principles under reverse solicitation are not weakened: a risk-based approach is mandatory just as it is for licensed activity. I recommend building KYC/CDD processes for non-residents from the outset, including PEP screening and EU sanctions lists, confirmation of beneficial ownership (UBO), and source-of-funds and wealth checks when internal thresholds are exceeded.

Transaction monitoring for client-initiated activity cannot be simplified. We implemented behavioral monitoring algorithms for several CASPs, configured thresholds for alerts and SARs, documented escalation procedures in case of suspicions and assigned MLRO duties and responsibilities at the board level. The Travel Rule’s application to crypto transactions is a separate control point, especially when interacting with European VASPs.

Enhanced Due Diligence for clients from the EU is necessary in cases of heightened risk related to jurisdiction, transaction typology or product category (for example, highly volatiletokens, participation in off-chain transactions, working with mixers). In some projects the COREDO team implemented a hybrid model: basic KYC in-house, while EDD and screening are carried out by a certified provider, with transparent outsourcing of compliance to a third party.Marketing: pre-contractual communication
Restrictions on advertising and cold outreach, the basic rule of reverse solicitation under MiCA. Any contact activity directed at EU residents, including partner programs with EU bloggers, referral payments, localized landing pages “for EU clients”, are red flags for NCAs. legal opinion drafting for reverse solicitation at our firm always includes a legal assessment of advertising campaigns and oversight of marketing materials.

Pre-contractual communication rules of MiCA allow responses to specific inquiries, but prohibit expanding the dialogue into mass mailings.

Requirements for websites and public information include neutral presentation, absence of promises of service availability in the EU, a clear disclaimer about the provider’s non-resident status and the contract’s jurisdiction. In one case COREDO’s transfer of a site from an EU domain to an international one with geotargeting disabled eliminated the provider’s risk of a formal “EU public offer”.
The test for client passivity must be clear to the sales team. We prepare cheat-sheets for managers “do/don’t”: what can be said, how to answer questions about availability for EU residents, what information is relevant and how to avoid the fine line between advising and solicitation. This reduces the likelihood of unintentionally breaching the “without prior solicitation” logic.

Structuring relationships with an EU client

Contract structuring for reverse solicitation is built around transparency and choice of law. Contract models with a client from the EU include clear terms of service and dispute jurisdiction outside the EU, disclosures about the provider’s status, the absence of an EU license and the legal position of the third country. Protective clauses in the contract should cover risks of compelled jurisdiction, product limitations and service termination in the event of regulatory requirements.

Transparency and disclosure in reverse solicitation are an ally, not an obstacle. Proper product governance, client segmentation and territorial risk assessments, as well as a documented evaluation of the applicability of the MiCA scope to specific assets (for example, ART or EMT), will help demonstrate the model’s good faith to NCAs. At COREDO we formalize governance and board-level oversight in the form of a report to the board on the share of EU clients and triggers for migration to licensing.

Data protection and GDPR implications are also critical. Even if you are outside the EU, processing personal data of EU residents requires GDPR compliance: appointing a DPO where necessary, legal bases for processing, cross-border data transfers and contracts with processors. Confidentiality and information exchange with counterparties must take into account banking secrecy, local AML rules and NCAs’ requirements.

Risks: compliance, reputation, taxes

Compliance risks in reverse solicitation include the risk of reclassification as crypto-asset service providers without a license if the regulator deems your communications to be solicitation. Regulatory fines and enforcement actions are often accompanied by a requirement to close access to EU clients and block local payment channels. COREDO works through pre-emptive remediation steps: freezing marketing, reviewing contracts, additional staff training.

Limiting reputation risks requires a conservative information policy and readiness for regulatory inquiry. Evidence preservation and a document retention policy are not formalities: the absence of log records and screenshots often undermines the provider’s legal position. Our clients who had an established audit trail went through checks with minimal losses.

Tax consequences of cross-border services depend on economic presence. The economic nexus test and the risk of a permanent establishment (PE) in the EU depend on where key managerial decisions are made, where employees are located and where marketing is conducted from. We recommend assessing cross-border tax reporting implications together with tax advisors and taking into account CRS/FATCA when structuring.

Checklist for responding to a request from an EU client

  • Confirm client-initiated contact: record the channel, time, IP, consent.
  • Check geotargeting: exclude retargeting and personalized offers for the EU.
  • Perform KYC/CDD, conduct PEP/sanctions screening, determine the risk profile.
  • Assess tokens: MiCA scope and classification (ART/EMT/utility), product limitations.
  • Provide disclosures: non-resident provider status, lack of an EU license, contract jurisdiction.
  • Appoint the MLRO responsible for monitoring and the travel rule, record thresholds and alerts.
  • Preserve all evidence: website screenshots, CRM logs and marketing platform logs.
  • Assess the share of EU clients and thresholds for migration to EU licensing.
  • Prepare a legal opinion on MiCA reverse solicitation and internal instructions for the team.

Licensing or reverse solicitation
Licensing vs servicing via reverse solicitation: a matter of cost-benefit analysis. The economic feasibility of operating without a license is high at early stages when you need to quickly test a product and reach initial transactions. But compliance cost modeling shows: as the share of EU revenue grows, the cost of marketing controls, legal opinions and enforcement risks begins to exceed the CAPEX for obtaining a license in the chosen EU jurisdiction.

The ROI assessment when foregoing licensing should take into account the probability of fines and restrictions, the cost of regulatory protection and the opportunity cost due to restrained marketing. Scaling the business through reverse solicitation is limited: the model is poorly compatible with active growth and product marketing. In one project COREDO prepared a roadmap: 6 months of a reverse scenario with a cap on the EU share and a parallel launch of licensing in Cyprus taking into account capital and guarantee requirements.

Exit strategies include migrating the business to the EU or servicing remotely while obtaining a license in a country oriented towards CASP. A regulator sandbox program option sometimes accelerates testing of innovative products. Registration formalities in the EU and interaction with a local lawyer, preparation of governance documents, AML policies and procedures for CASP, this is an area where the COREDO team has implemented full cycles, including product governance and board supervision.

Practice and interaction with ESMA/NCAs

ESMA’s enforcement practice shows a high interest in pre-contractual communication and cross-border onboarding. NCAs – national competent authorities of the EU: send regulatory requests and expect transparent answers: website architecture, marketing campaigns, share of EU clients, AML control and escalation procedures. Legal support for reverse solicitation is useful not only in a dispute, but also in preparation for an inspection.

The COREDO team prepares legal opinions on MiCA reverse solicitation taking into account national nuances, including the legal position of third countries and MiCA, product mapping and assessment of the marketing footprint. We agree with the client in advance on a response playbook: who responds, what data is disclosed, how the internal compliance manual for CASP is demonstrated, and how evidence preservation is presented.

Practical tip: conduct a pre-emptive gap review of marketing, onboarding and IT logging before going live with EU traffic. It is faster and cheaper than urgently fixing traces after a regulatory letter.

Internal policies and controls
Drafting an internal control policy for CASP in the context of reverse solicitation is not a simplified version of the “full” license. Documents should cover the risk-based approach to AML/CFT, KYC/EDD, transaction monitoring algorithms, thresholds for SAR, travel rule, outsourcing governance and data quality controls. The internal compliance manual for CASP structures the roles of the MLRO, the second line of defense and escalations to the board.

Control over marketing materials: a mandatory control. We recommend a pre-clearance procedure for any communication that may reach EU residents: landing pages, mailings, social media posts, partner creatives. The document retention policy sets retention periods, and the IT landscape maintains an audit trail across key systems.

Governance and board-level oversight address strategic issues: limits on the share of EU revenue, triggers for moving to licensing, a compliance and legal risk reserve budgeting model. It is at this level that it is decided whether reverse solicitation will remain an experiment or become a bridge to a full EU presence.

COREDO practice examples that work
Case 1: a Singaporean provider serving EU holdings on a request basis. The COREDO team built opt-in onboarding, centralized KYC with EDD for high-risk profiles and a strict “no EU marketing” policy. We prepared a legal opinion on MiCA reverse solicitation with a risk map and a migration plan to a Cypriot license upon reaching a 25% EU-share threshold. A regulatory inquiry from one of the NCAs was closed with an evidentiary base: logs, screenshots, instructions.

Case 2: a Dubai VASP with active content marketing. COREDO’s audit revealed hidden geotargeting to several EU countries and a referral network with EU bloggers. We froze the campaigns, rewrote public disclosures, implemented pre-clearance, trained the sales team and put in place a document retention policy. At the same time we started the licensing process in Estonia; after 8 months the company moved to an onshore model.

Case 3: a British fintech platform with utility tokens. The legal assessment showed exceptions for some tokens, but ancillary services fell within the MiCA scope. COREDO’s practice confirmed: mixed models more often err in classification. We separated product flows, for some — reverse solicitation with neutral web architecture, for others — an application for a license in Slovakia.

Contract models and data protection
Contract models with an EU client should include: choice of law and dispute jurisdiction outside the EU, clear product restrictions, terms for termination of service on regulatory grounds and notifications, disclosure of economic and legal risks. Contracts should set out mechanisms for KYC/EDD, consents for processing and transfer of data, as well as the provider’s rights to transaction monitoring and freezing operations upon red flags.

Terms of service and dispute jurisdiction should work together with data protection policies. Deep integration of GDPR processes (legal bases, DSR procedures, DPIA where necessary) reduces the risk of secondary claims. In one project COREDO synchronized the ToS, privacy notice and AML policy to eliminate contradictions and demonstrate the integrity of governance.

When reverse solicitation is not advantageous
Business model alignment with MiCA requires an honest assessment. If your growth depends on marketing, partnerships and public promotion, reverse solicitation will limit scaling and increase the cost of compliance. If the business case envisages a significant flow of clients from the EU, it is advisable to plan for EU licensing in advance, choosing jurisdictions with a clear NCA practice and accessible infrastructure (for example, Cyprus, Estonia, some Central European countries).

Compliance cost modeling helps management see where the breaking point lies between the costs of legal protection for the reverse model and the CAPEX/OPEX of a licensed presence. The COREDO team often calculates scenarios: a basic reverse for 6–9 months, a hybrid model with limited marketing and a full transition to a license with an onshore team and presence and substance requirements.

What the regulator will ask during an inspection
Preparation for a regulator’s inspection on client-initiated contacts: it is not only documents. Regulators check product governance, the continuity of the customer information trail, monitoring stability, response to alerts and the competence of the MLRO. We conduct simulated requests where the client team answers questions about site structure, onboarding logic, token classification and the use of EU sanctions lists.

The regulatory perimeter under MiCA changes as ESMA publications are released, and COREDO regularly updates templates of the internal compliance manual for CASP. This allows rapid implementation of changes: for example, strengthening requirements for pre-contractual disclosures or revising the passive client test procedure.

Nuances of ART, EMT and utility tokens
Asset-referenced tokens are regulated more strictly, especially regarding issuance, reserves and disclosures. E-money tokens under MiCA trend towards requirements similar to electronic money, including capital and safeguarding of funds. Utility tokens may be outside MiCA with a narrow functional purpose, but as soon as trading availability or an investment motive appears: we return to the MiCA scope.

COREDO helps clients with product mapping: a matrix of token functions, use scenarios, impact on AML/KYC and product restrictions in reverse solicitation. This reduces the risk of incorrect classification and NCA claims.

From hypothesis to a sustainable model

  • Carry out a MiCA scope and applicability assessment to the product, taking into account national transpositions.
  • Decide whether the model allows passive inbound without marketing in the EU.
  • Build web and CRM architecture with inbound logging, disable EU targeting.
  • Develop an internal compliance manual, AML policies, travel rule procedures and the MLRO role.
  • Set up KYC/CDD/EDD, sanctions and PEP checks, transaction monitoring.
  • Prepare a legal opinion on MiCA reverse solicitation and a response plan for inquiries.
  • Agree on ToS, agreements, disclosures, a privacy notice and GDPR processes.
  • Identify triggers for moving to licensing, calculate ROI and choose a jurisdiction.
  • Maintain record-keeping, evidence preservation and regular board oversight.

Conclusions

Reverse solicitation under MiCA is a tool, not a goal. It helps legally test a product, carefully work with inbound requests from the EU and gather market feedback. But this model requires discipline: no marketing in the EU, impeccable documentation, strong AML/KYC and transparent contractual relations.

The COREDO team has walked this path with clients many times: from the legal opinion and process setup to transitioning to a licensed model in the EU. I am convinced that resilience in the crypto-economy is built on two pillars – strategic clarity and operational excellence. Reverse solicitation can become your bridge to Europe if you define the boundaries in advance, stay within the regulatory perimeter and make a timely decision about licensing.

Since 2016 I have been leading COREDO through dozens of regulatory cycles and changes in the EU, the UK, Singapore and the UAE. The COREDO team has gone all the way from company formation and CASP/VASP licensing to building mature AML‑programs, reserve proofs and setting up operational resilience. In this article I have compiled the strategy we actually use in projects: how to prepare a crypto exchange and related fintech services for MiCA in the EU and for VARA in Dubai by 2026, with details, not theory for theory’s sake.

Below you will see concrete steps, regulatory nuances and technological solutions that already work. Where the market imposes higher requirements, I will explain how we close them — from governance and capital adequacy to the Travel Rule, custody and smart‑contract audits. The goal is to give you a structure that makes it easy to plan market entry into the EU and the UAE, to estimate compliance cost and ROI, and, most importantly: to move quickly and without unnecessary risks.

MiCA and VARA: what you need to know in 2026

Illustration for the section «MiCA and VARA: what you need to know in 2026» in the article «MiCA and VARA – comparison for crypto exchanges 2026»

MiCA and VARA are already shaping a new regulatory landscape for crypto-assets, so it is worth having a clear understanding of the main implications for businesses and users. Below we break down what is important to know in 2026: the scope of MiCA, requirements for providers and practical interaction with VARA.

Scope of MiCA

MiCA is a pan-European regulation covering crypto-assets, tokens and CASP services: exchange, trading platform operation, custody, token issuance and order execution. By 2026 MiCA harmonizes rules for stablecoins, tightens requirements on transparency, risk management and minimum capital. An important feature: MiCA passporting for operating in the EU — by obtaining a license in one EU country and complying with corporate and prudential standards, you can serve clients across the European Economic Area.

VARA mandate in Dubai

VARA has created a modular licensing system for VASPs in Dubai: advisory, broker‑dealer, custody, exchange, lending/borrowing, management & investment. The rules are divided into knowledge and process areas: Company, Compliance & Risk, Market Conduct, Technology & Information, as well as an Issuance Rulebook for tokens. By 2026 VARA is expected to consolidate the rulebooks, clarify third‑country equivalence and strengthen requirements for managing technology risks, including operational SLAs with wallet providers and access control.

CASP vs VASP, terms and responsibilities

In the EU under MiCA, Crypto‑Asset Service Provider (CASP); in Dubai — Virtual Asset Service Provider (VASP). The difference is not only in terminology. COREDO’s practice confirms: VARA describes technological and information requirements in greater detail (logging, cybersecurity, BCM), while MiCA focuses on prudential and market integrity aspects for EU market participants. For crypto exchanges the question “MiCA vs VARA for crypto exchanges” often means not choosing “or” but “and”, when an international structure builds a licensing architecture covering both jurisdictions.

Extraterritoriality and equivalence

MiCA and VARA have extraterritorial elements: marketing, interface availability, client targeting and onboarding create compliance obligations. VARA is developing an approach of international recognition and third‑country equivalence, but it does not remove local Licensing where there is a physical presence, a management center or targeted marketing. Our experience at COREDO shows: we model in advance a jurisdiction risk matrix and a roadmap for obtaining the relevant approvals to avoid regulatory arbitrage with unpredictable consequences.

Market entry: EU vs Dubai

Illustration for the section «Market entry: EU vs Dubai» in the article «MiCA and VARA – comparison for crypto exchanges 2026»

Choosing a strategy for market entry in the EU or Dubai is determined by differences in regulation, taxes and access to customer and technological infrastructure. Special attention should be paid to passporting under MiCA and its limitations, which directly affect the speed and scalability of presence in Europe.

MiCA passporting: limitations

MiCA passporting for operating in the EU is a powerful advantage: a single standard for 27 countries, centralized requirements for disclosure, token registry, capital and governance. But passporting has limitations: local AML supervision by national authorities, requirements for the language of disclosures, as well as related rules: PSD2 for payments, GDPR for data, AMLD5/6 for reporting. The solution developed by COREDO: «passporting‑plus», a base license + local procedures (for example, language, STR/CTR formats, interaction with the FIU), compiled into a single compliance matrix.

VARA license for exchanges in Dubai

Dubai offers fast access to capital, infrastructure of liquidity providers and technological flexibility. VARA license for exchanges 2026 requires a clear picture of governance, operational resilience, risk management and internal controls. VARA regulation of virtual assets Dubai 2026 emphasizes tech processes: asset segregation, custody models, incident management and public notifications. The COREDO team has implemented a number of «VARA‑readiness» projects, including Travel Rule integration and KYT automation with on-chain monitoring.

ROI from compliance: CapEx vs OpEx

Compliance costs (compliance cost) for MiCA and VARA include CapEx (AML implementation/KYC platforms, KYT, SIEM, DLP, smart contract audits, proof of reserves) and OpEx (CCO/MLRO team, transaction monitoring, training, regular audits, regulatory fees). The assessment of ROI from complying with MiCA and VARA for exchanges is built on three metrics: market access (EU passporting, VARA recognition), reduced cost of capital (trust from banks and investors), and accelerated customer onboarding. At COREDO we calculate ROI as savings on risks (fines, downtime, rejected payments) and revenue growth through lawful marketing and partnerships.

How to obtain a crypto exchange license

Illustration for the section «How to obtain a crypto exchange license» in the article «MiCA and VARA – comparison for crypto exchanges 2026»

Licensing crypto exchanges is a complex process implemented through clearly structured step-by-step procedures that minimize regulatory and operational risks. The first key stage, registration of a legal entity in the EU and bringing operations into compliance with MiCA requirements, is followed by the preparation of documents, compliance processes and technical integration.

Registering a legal entity in the EU under MiCA

Registering a legal entity for an exchange in the EU under MiCA begins with choosing a jurisdiction: taxes, regulator competence, access to talent and banks. Company registration in the EU: choice of jurisdiction and tax aspects run in parallel with the preparation of the CASP dossier: business plan, policies, risk appetite, description of IT architecture, custody, key roles (CEO, CCO, MLRO, CISO), as well as a token registry and classification under MiCA. An important block is client onboarding under MiCA requirements and the disclosure and transparency obligations under MiCA.

Registration in the UAE: Free Zone/Mainland

Registering a legal entity in the UAE under VARA — a choice between Free Zone (for example, DIFC/DWTC/DMCC, if relevant to the licensing model) and Mainland. Free Zones provide speed and infrastructure; Mainland — access to government procurement and certain types of activities. Crypto exchange licensing procedures in the UAE include compliance with corporate requirements, proof of economic substance, a compliance package and coordination with banking gateways. In practice we set the sequence: corporate structure (SPV, branch, subsidiary) → preliminary coordination with VARA → technological and operational controls → interview with the regulator.

Migration of license, clients and data

License migration: how to move an exchange to the EU or the UAE — this is a project about three fronts: legal risks, migration of clients and data, and operational continuity. GDPR and personal data protection during KYC require a DPIA, updates to consents and MSAs with providers, as well as planning backups and data recovery. COREDO’s practice confirms: staged migration, a pilot phase, a dual AML/KYC perimeter and a pre-agreed disclosure plan for clients allow you to pass an audit and regulatory inspection without disruptions.

Capital, governance and risk management

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Understanding capital requirements, effective governance and reliable risk management processes form the basis of financial resilience and compliance with regulatory standards. In the next section we will examine the minimum capital and reserves necessary to maintain solvency and cover potential losses.

Minimum capital and reserves

Capitalization and prudential requirements for CASP under MiCA depend on the type of services and include minimum own capital requirements and buffers. Under VARA: the emphasis is on liquidity resilience, coverage of operational risks and reserving mechanisms. We detail stress‑testing models and liquidity management (prudential stress testing), including outflow scenarios, market shocks and custodian failures. Having a register of limits and three lines of defense reduces the likelihood of supervisory claims.

Management of conflicts of interest

Management of conflicts of interest and governance are a separate focus for both MiCA and VARA. The board of directors, independent directors, a risk committee, and a clear role for the Chief Compliance Officer and MLRO are not a formality. At COREDO we build an authority matrix, a remuneration policy, personal trading rules and an escalation mechanism. For exchanges with an in‑group market maker, separation of duties, market conduct and independent monitoring are critical.

Operational resilience (BCM)

Operational resilience and business continuity (operational resilience) are mandatory topics. BCM (business continuity management), backup sites, RTO/RPO, incident management and disclosure plans – that is what regulators check first. In our projects COREDO uses tabletop exercises, testing of backup payout processes and chain outage scenarios to demonstrate readiness for failures and cyber incidents.

AML/KYC: from policies to technologies

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AML/KYC today requires a shift from formal policies to technological solutions that automate checks and minimize operational risks. This is especially important when implementing MiCA and VARA requirements and when organizing KYC/EDD for corporate clients.

KYC/EDD requirements under MiCA and VARA

KYC requirements under MiCA and VARA converge: multi-layered KYC, EDD for high-risk and corporate clients, beneficiary verification, confirmation of sources of funds. KYC/EDD standards for corporate clients include analysis of ownership structures, sanctions risks and geographies. We implement a risk‑based approach: different layers of checks depending on risk, periodic reviews and sampling audits.

Travel Rule for cross-border transactions

Integration of the Travel Rule under MiCA and VARA is mandatory for cross‑border transactions. We use the OpenVASP, Sygna and TRP protocols, addressing interoperability with different VASPs and jurisdictions. AML/KYC processes for cross‑border transactions are configured to satisfy both FATF and local requirements without creating unnecessary friction for the client.

FATF, AMLD5/6 and STR/CTR with authorities

FATF recommendations and their impact on MiCA/VARA set the minimum threshold. Implementing AMLD5/6 in the context of MiCA means correct risk segmentation, triggers for STR/CTR and standardized reporting formats. The COREDO team helps organize interaction with law enforcement authorities and regulators, including handling requests and preserving the chain of custody.

Sanctions, screening, PEP/SDN and information exchange

Managing sanctions risks and screening, regular updates of PEP/SDN lists, geographic filters and intergovernmental agreements and information exchange. We combine sanctions compliance with graph algorithms and on-chain analytics to detect complex evasion schemes. This approach reduces the likelihood of blocks by banks and payment providers.

Proof of reserves and asset custody

The topics of custody, proof of reserves, and overall asset security define the rules for storage and transparency when working with digital assets. Below we will review MiCA’s custody requirements and the key provisions of custodian agreements that help ensure compliance with these standards.

Agreements and custody under MiCA

MiCA custody requirements emphasize segregation of client funds, daily reconciliations, and mandatory agreements with custodians under MiCA. Contracts record client rights, procedures for access recovery, insurance, and disclosure procedures in case of incidents. For CASP entities holding assets, it is critical to have a clear map of responsibilities and regular reporting to clients.

Custody models under VARA and insurance

VARA custody models detail the architecture of hot and cold wallets, multisig, HSMs, and withdrawal procedures. Custody rules — hot wallets vs cold storage in Dubai — assess not only the technology but also operational controls. Crypto-asset insurance and market practice in 2026 require assessment of limits, retroactive coverage, and coordination with the regulator.

Proof of reserves: audit and certification

The practice of proof of reserves is becoming standard. We use combined methodologies: on-chain verification, independent attestations, and confirmation of liabilities without disclosing personal data. Audit and certification of crypto exchanges in 2026 include independent verification of financial statements, procedures, and IT controls, which strengthens the trust of banks and institutional investors.

CISO and cyber risks of wallet providers

Access control and the role of the CISO in a crypto exchange are coming to the forefront. Cyber risks, backups and data recovery, network segmentation, key management, and operational SLAs with wallet providers are a topic to which VARA applies particularly strict standards. At COREDO we conduct a gap analysis of Technology & Information requirements and address it through SIEM, PAM, and regular Red/Blue Team exercises.

Disclosure and investor protection

Operational transparency and detailed disclosure: key elements of effective investor protection in the digital assets space. In the following subsections we will examine MiCA’s disclosure requirements, the organization of the token register and the content of the whitepaper that help implement these principles in practice.

MiCA disclosure: registry and whitepaper

MiCA’s disclosure and transparency requirements include a whitepaper for public token offerings, a token register and classification under MiCA, as well as clear risk disclosures. Public transaction registries and the transparency requirement strengthen oversight by investors and regulators. At COREDO we establish a process for updating the whitepaper when tokenomics or functionality change.

Stablecoin regulation and reserves

MiCA vs VARA stablecoin regulation converges on one point: the priority of resilience and reserve policy. Assessing stablecoin stability and reserve policy involves checking asset quality, reporting frequency and the transparency of guarantees. In the EU additional requirements are imposed on issuers; in Dubai the emphasis is on disclosures and counterparty risk management.

Protection of token marketplace consumers

MiCA’s impact on the licensing of token marketplaces concerns placement, listing and delisting rules, as well as consumer protection. Ensuring investors’ rights and consumer protection means clear pricing rules, prevention of manipulation and clear complaint procedures. We integrate market conduct controls and independent oversight of listings.

Compliance and operational integrations

Tools for compliance and support of operational integrations combine automated risk monitoring, blockchain activity analysis and ML models to fight fraud. Below we will examine the key elements in detail: KYT and on‑chain monitoring, anti‑fraud ML and graph analytics.

KYT and on-chain monitoring

Technological compliance solutions (KYT, blockchain analytics) are the foundation for AML compliance for crypto exchanges. On‑chain monitoring and KYT tools, anti‑fraud algorithms and machine learning for AML, AML algorithms using graph analytics and tools for monitoring suspicious patterns provide speed and accuracy. We configure risk‑based rules and playbooks for analysts to reduce false positives and accelerate investigations.

ROI assessment: automation, BPM, KPI/KRIs

Compliance automation and BPM tools save time and maintain quality. Compliance performance metrics (KPIs, KRIs): onboarding time, share of EDD cases, number of STR/CTR, average investigation time. ROI assessment from automating AML processes includes OpEx reduction and fewer regulatory incidents thanks to a controlled process.

Integration with banks: PSD2 and KYC

Integration of banking gateways and banks’ KYC requirements remain a barrier for crypto exchanges. Integration with payment providers and PSD2 compliance require reliable identification, transaction monitoring and preventive sanctions measures. The COREDO team pre‑agrees compliance packages with banks, reducing time‑to‑yes.

Blockchain interoperability and oracles

Blockchain interoperability and oracle risk: new sources of operational and market risks. Smart‑contract audits and technical risk management: independent audits, bug bounties and deployment policies. We include these elements in the regulatory dossier to demonstrate mature risk management.

Regulatory supervision and sanctions

Attention to supervision and potential sanctions has become a key factor for market participants: non-compliance with rules often entails operational and reputational risks. Below we examine regulatory practice at the ESMA and national regulator levels, including reporting requirements and the frequency of document submissions.

Reports to ESMA and national regulators: frequency

The supervisory practice of ESMA and national authorities in the EU establishes consistent approaches to disclosures and reporting. Regulatory reports and filing frequency depend on the type of services and the scale of the business: operational incidents, transaction volumes, complaints and disciplinary measures. At COREDO we formalize a reporting calendar and responsibilities for each area.

VARA regulatory sandboxes: appeals

Regulatory sandboxes and VARA pilot projects are a quick way to test innovations under supervision. The right to appeal regulatory decisions exists in both systems, but it is important to properly document the process and maintain an open dialogue. We prepare position letters and arguments in the regulator’s language.

Supervisory sanctions and fines

Supervisory sanctions and fines under MiCA and VARA are a reality for companies with immature compliance. We reduce legal risks for crypto exchanges under MiCA and VARA through early gap assessments, staff training and independent reviews. COREDO conducts pre-audit to fix vulnerabilities before a supervisory visit.

COREDO Case Studies: launching exchanges in the EU and Dubai

COREDO case studies demonstrate how we bring exchanges to the EU and Dubai markets through a phased regulatory compliance strategy. Next, we will break down the MiCA compliance plan — from onboarding counterparties and setting up internal processes to scaling operations and maintaining compliance.

Exchange compliance plan under MiCA

Recently the COREDO team completed a CASP licensing project focused on exchange and custody. We built a compliance plan for entering the EU markets: client onboarding under MiCA requirements, token classification, whitepaper procedures, KYT and the Travel Rule. After obtaining the license we enabled passporting in three EEA countries and scaled the business while complying with MiCA requirements without additional licenses.

VARA risks and controls in Dubai

Another case: an exchange with derivatives on virtual assets under VARA. We deployed risk management and internal VARA controls, including liquidity stress testing, a Company & Risk Rulebook, Technology & Information controls, as well as custody models with cold reserves and insurance. The regulator accepted the PoR model with independent attestation and regular public reports.

Migration from Asia to the EU: clients and data

A client from Asia moved its operations center to the EU. We designed the migration of clients and data when changing jurisdiction, arranged contracts with custodians, performed a DPIA under GDPR and conducted an audit of IT controls. Result: successful license migration, smooth transfer of liquidity and continuity of trading without downtime.

Liquidity, M&A and exits

For sustainable business expansion, liquidity, proper M&A planning and well‑thought exit strategies remain key. In the following section we will examine the principles of liquidity management and stress testing that help assess a company’s ability to withstand shocks and prepare for deals and exits.

Liquidity management and stress tests

Counterparty risk management and credit risk require limits on market makers, custodians and stablecoin issuers. We build prudential stress testing taking into account volatility, oracle failure scenarios and network outages. This increases the confidence of banks and institutional partners.

IPO and M&A exit strategy: regulatory framework

Exit strategies: IPO, M&A and the impact of regulatory requirements determine the structure of reporting and internal control. Audit and independent review of financial statements, mature policies and transparent KPI/KRIs increase the company’s valuation. At COREDO we build a data room with an emphasis on compliance tracks and regulatory history.

Impact of geopolitics and sanctions

The influence of geopolitics and sanctions policy on exchange operations: a factor of strategic planning. We update screening rules, test alternative payment channels and set up inter-jurisdictional information exchange. This approach preserves market access and reduces the likelihood of sudden blocks.

Checklist for launching an exchange under MiCA/VARA 2026

  • Legal structure: SPV/branch/subsidiary; beneficial ownership register; tax planning.
  • Licensing: CASP under MiCA with passporting; VARA VASP classes for exchange/custody/broker-dealer.
  • Governance: board, independent directors, risk committee; roles CCO, MLRO, CISO.
  • Capital and reserves: minimum requirements and buffers; liquidity plan and stress tests.
  • AML/KYC: risk‑based KYC/EDD, sanctions (PEP/SDN), STR/CTR, FATF/AMLD5/6, Travel Rule (OpenVASP/Sygna/TRP).
  • Custody: hot/cold wallets, multisig, HSM, insurance; agreements with custodians under MiCA.
  • Proof of Reserves и аудит: methodology, independent attestation, regular public reporting.
  • Technology: KYT, on‑chain analytics, anti‑fraud ML, SIEM/PAM; BPM automation, KPI/KRIs.
  • Transparency: token registry and classification under MiCA; whitepaper and disclosures; market conduct.
  • Operational resilience: BCM, incident management, RTO/RPO, redundant sites and backups.
  • Integrations: banking gateways, PSD2 compatibility, banks’ KYC requirements.
  • Regulation: reports and frequency, VARA sandboxes, right of appeal, engagement with the regulator.
  • Data and GDPR: DPIA, client and data migration, contracts with providers, access control.
  • Smart contracts: audits, bug bounties, deployment management; oracle risks and interoperability.

Why COREDO is a long-term partner

The 2026 MiCA regulation for crypto-assets and the 2026 VARA regulation for virtual assets in Dubai set a high bar for crypto exchanges. For some it’s a barrier, but I see a window of opportunity: passporting under MiCA, equivalence and international recognition of VARA, mature procedures, a foundation for scaling without regulatory surprises. Our experience at COREDO has shown that the right compliance architecture not only grants market access but also saves capital, speeds up deals, and increases company valuation.

If you are planning crypto exchange licensing in the EU under MiCA or an expansion to Dubai, start with a risk map, a licensing roadmap, and pilot AML/KYT integrations. The COREDO team has already built dozens of such programs, from legal entity registration to proof of reserves and regulatory reporting. I’m ready to discuss details: where migration is advisable, which custody models to choose, how to optimize CapEx vs OpEx, and how to build a compliance matrix that will withstand audit and scaling.

Since 2016 I have been building COREDO as a company that removes regulatory uncertainty for entrepreneurs and financial directors. During this time the COREDO team has obtained licenses and set up operating models in the EU, the United Kingdom, the Czech Republic, Slovakia, Cyprus, Estonia, Lithuania, Singapore and Dubai. In this article I have compiled practical recommendations on CASP licensing, with a focus on capital, personnel, AML and technological resilience. I draw on the experience of numerous projects so that you can immediately see where the main value lies and how to avoid costly mistakes.

Why MiCA and global supervision now

Illustration for the section «Why MiCA and global supervision now» in the article «CASP licensing – capital and personnel»

The European MiCA regulation introduces common requirements for CASPs regarding capital, organizational structure and client protection, and also provides passporting mechanisms in the EU. COREDO’s practice confirms: the new regime raises the entry threshold, but with proper preparation accelerates scaling across regions and reduces fragmentation of requirements. We take into account that MiCA and the capital requirements for CASPs tie own funds to the set of services and fixed overhead costs.

Outside the EU, important benchmarks are set by the FCA (United Kingdom), BaFin (Germany), FINMA (Switzerland) and MAS (Singapore). These regulators emphasize fit-and-proper requirements for CASP management, verification of funding sources and operational resilience. FATF recommendations to VASPs and on staffing requirements, as well as AMLD5/6 in the EU, have strengthened the focus on ML/TF risks and CASP personnel requirements. In Dubai VARA details the separation of responsibilities custodian vs exchange, which directly affects capital and insurance coverage.

Choosing a jurisdiction and market entry

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Decisions on choosing a jurisdiction and forming a market entry model define the legal, tax and commercial framework of expansion. Below we will examine step by step how these factors manifest in the EU context: from regulatory harmonization to requirements for economic substance.

EU regulatory harmonization

MiCA creates uniform rules, but in practice each state retains particularities in supervision and expectations regarding local presence. Economic substance and local presence of a CASP are not a formality: real resident directors, an office, a full-time MLRO, and management functions within the country strengthen the position at the application stage. At COREDO we design the organizational structure of the CASP in advance for licensing and prepare a passporting strategy to later use cross-border CASP services without duplicating licenses.

Estonia, Malta, Lithuania offer different entry barriers. In Estonia the minimum share capital for a VASP depends on the services and usually ranges from €100,000 to €250,000; personnel and control requirements have been strengthened since 2022. In Malta the VFA classification raises the bar for capital and governance: for advanced classes this means hundreds of thousands of euros and enhanced internal controls. Lithuania actively welcomes crypto business: VASP registration is possible, but banks and payment providers expect confirmed substance and a mature AML framework.

Depth and supervisory models in four countries

The FCA conducts strict registration of crypto companies: there is no formal minimum capital, but a CASP’s own funds must cover risks and fixed expenses, and personnel must demonstrate competencies and independence of compliance functions. FINMA and the Swiss cantonal regulators apply a high level of scrutiny to custody solutions and directors’ responsibilities. In Singapore under MAS’ PSA for DPT providers the minimum capital and security deposit depend on the volume of operations; mature processes for cybersecurity and key management are expected. In Dubai, VARA imposes clear requirements for product documentation, outsourcing of critical functions, and SLAs with providers.

CIS: a bridge to the EU and Asia

Applicants from the CIS are successfully licensed when they build a transparent ownership structure, confirm the sources of capital for the CASP and document the business reputation of founders and investors. The COREDO team has implemented multi-level structures with an EU holding and operating companies in Asia to balance tax burden and personnel requirements. This approach facilitates banking relationships, KYC/KYB and demonstrates sanctions compliance to regulators.

Capital for CASP: terms and calculations

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For proper capital management within CASP it is important to first build a clear understanding of key terms before moving on to practical calculations. In the first section we will go through the basic terminology and regulatory logic to lay the foundation for further capital assessment methods and concrete computations.

Terminology and regulatory logic

Own funds (own funds): this is a regulatory metric of resilience. Distinguish paid-up capital vs authorized capital: the regulator considers paid-in capital and other elements of own funds, not just the authorized share capital ceiling. MiCA prescribes minimum capital for CASP in the range of €50–150k depending on services and/or 25% of annual fixed overheads: the higher figure is chosen.

Capital versus liquidity: the regulator for CASP requires both. Capital is a buffer against losses; liquidity is the ability to meet obligations and withstand outflows. Some jurisdictions apply elements of ICAAP: internal capital assessment and stress-testing, and risk-weighted assets (RWA) are adapted to the nature of crypto exposures and operational risks.

Risks, stress tests and capitalization

risk assessment and capital testing for CASP include scenarios: technology failure, abrupt outflows of client funds, increased market/credit risk exposures to liquidity providers. Liquidity reserves and stress tests for a crypto operator show how quickly you cover margin requirements, withdrawals and operating expenses. The COREDO team implemented ICAAP logics taking into account RWA methodologies and operational risk, as well as an analysis of “capitalizable and non-capitalizable liabilities” for correct calculation of own funds.

How to calculate capital requirements for a crypto exchange? We take the minimum CASP share capital, add a buffer to FOE (fixed overheads) for 12–18 months, account for CASP reserve capital requirements for custody and cyber risk coverage. Capitalization strategies when scaling a CASP include additional issuances, subordinated debt as a source of regulatory capital within limits, and cyber insurance, which indirectly reduces net losses in stress scenarios.

Funding and corporate actions

Sources of funding for a CASP license must be transparent: equity, convertible notes, subordinated debt, subject to conditions recognized by the regulator. Evidence of capital sources for CASP relies on bank statements, SPAs, corporate resolutions, auditor reports and investors’ tax returns. Procedures for increasing capital and additional issuances require regulatory approvals for changes to capital structure and updates to corporate documentation, as well as timely notifications to the regulator.

Personnel: fit and proper and organizational design

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A company’s effectiveness largely depends on its personnel, adherence to the fit and proper principles, and thoughtful organizational design. In the following points we will examine staffing requirements and leadership roles in detail to understand how to build competencies, responsibilities, and managerial interactions within the organization.

Requirements and leadership roles

CASP personnel requirements are based on the fit and proper principle: honesty, experience, qualifications, time on the market, and the ability to devote real time to management. Minimum qualifications for CASP CTO, CFO, CCO include proven experience in the financial sector, risk and security management, and for the MLRO, competencies in ML/TF assessment, skills in developing AML policies and interacting with the FIU. What is considered sufficient qualification for an MLRO? Practical experience in AML/CTF, relevant certifications (for example, ICA/ACAMS), knowledge of AMLD5/6 and FATF, investigation cases and SARs.

The roles of MLRO, CCO, CTO, CFO, CIO in a CASP allocate responsibilities: MLRO: management of AML and SARs, CCO – overall compliance framework and reporting, CTO/CIO – security, keys, infrastructure, CFO: capital, liquidity, reporting. The responsibility of CASP directors and staff is personal: the regulator assesses their decisions, the management of conflicts of interest in CASP leadership, and the independence of control.

Hiring and screening effectiveness

Recruitment and personnel screening procedures for a CASP include background checks, biography checks, criminal record and sanctions screening of the director, verification of education and actual achievements. Preparing CVs and proof of experience for CASP applicants should be substantive: projects, KPIs, implemented rollouts, certifications. The composition of the compliance and AML department in a CASP is built from an MLRO, KYC/KYB analysts, a sanctions officer, a reporting officer, and an independent internal auditor.

Ongoing operating expenses for CASP personnel should be planned for 12–18 months ahead. Performance indicators for the compliance function (KRI, KPI) include SLA for KYC, alert processing time, escalation rate, SAR quality, as well as ROI metrics from investments in compliance personnel. The assessment of the economic efficiency of hiring vs outsourcing shows: some functions are cost-effective to keep in-house, while others should be given to an external provider. Compliance function: in-house vs centralized for a CASP group: often a hybrid model with coordination at the holding level.

Succession, motivation and retention

A leadership succession plan and regulator requirements demand ready candidates for key roles, documented procedures for transferring access to assets and signing authorities. Compensation models and risk-oriented bonuses are agreed with the remuneration committee to avoid incentivizing excessive risk. Workforce planning when entering new markets helps avoid overloading the MLRO and deterioration of control.

Technologies, security and resilience

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Reliable technologies, the indispensable foundation for ensuring the security and operational resilience of services. Below we will examine in detail custody, segregation and key management practices that are critically important for protecting assets and maintaining operations during incidents.

Custody and key management

Capital and the safeguarding of client funds in a CASP depend on the chosen model: custody, exchange, brokerage. Product documentation requirements (custody, exchange, brokerage) include a description of client fund segregation and client accounting, SLAs with custodians, management of conflicts of duties and storage conditions. Cold and hot wallets, KMS, HSM, multisig: the standard for secure storage; key management and crypto-custody are documented in policy, with recovery procedures.

Asset insurance and client loss coverage reduce operational risks; cyber insurance and capital requirements are linked: having adequate coverage can affect the assessment of residual risk in ICAAP. Agreements with liquidity and leverage providers should limit counterparty risks, and outsourcing exchange engines and SLAs for critical functions are required with transparent RTO/RPO.

Compliance and privacy

KYC/KYB and beneficiary verification are reinforced by sanctions screening: sanctions controls and SDN/OFAC/UN/EU lists, a daily routine. For KYT and transaction monitoring we use Chainalysis, Elliptic, TRM as KYT tools, configure AML alert levels and detection rules based on a risk-based approach. The travel rule and technical provider integration are mandatory elements for cross-border transfers between VASPs.

Technical requirements: SOC2, ISO27001, regular pentest, vulnerability management and access control. Business continuity and backup policies support operational resilience, while incident reporting and engagement with the regulator reduce regulatory risks during outages. Practices to prevent personal data leaks (GDPR/PDPA) and integration of HR and compliance for access control to assets close significant security gaps.

Independence of quality control

internal audit and the quality control of CASP personnel assess the effectiveness of the first and second lines of defence. Critical functions can be outsourced, but responsibility remains with the directors; we define vendor control KPIs and independent monitoring. Engagement with external auditors and capitalization reviews helps demonstrate the maturity of risk management.

License application: documents and process

Properly assembled documents and a structured submission process are the key to a successful application, and checkpoints help track readiness at each stage. We’ll start with organizational matters, then go over substance requirements and finish with the practical part – a business plan that confirms the project’s economic justification.

Substance of the organization and business plan

The set of documents for a CASP license includes an organizational chart and a description of functions in the application, roles and authorities, as well as local presence and economic substance for the license. How to prepare a business plan for a CASP license? We describe products, revenue models, stress scenarios, growth strategies, risk maps and control measures. The financial forecast template for a CASP license includes P&L, cash flow, capital and liquidity, FOE, and “what-if” scenarios.

Product documentation details custody chains, exchange procedures, brokerage, limits on client transactions and margin risks. Segregation of client funds is codified in contracts and operating instructions, taking into account regulatory guidance on custodian vs exchange liabilities. The organizational structure of a CASP for licensing demonstrates the independence of compliance and risk functions.

Deal structure: timing and cost

Timing and cost of obtaining a CASP license depend on the jurisdiction and the readiness of the materials. In the EU, with a quality package, review takes from 3 to 9 months; in Singapore and Dubai: longer for complex models. We assess in advance the ongoing operating expenses for CASP personnel and funding sources for the CASP license to avoid cash shortfalls at the finish.

We plan passporting in the EU and cross-border CASP services from the start: this affects IT architecture, contracts with custodians and the choice of travel rule provider. We consider the transition from a subsidiary to a branch and its licensing implications from the standpoint of taxation, capital and substance requirements, as well as CASP reserve capital requirements.

Reporting and control in the operational phase

In the operational phase, reliable reporting and continuous internal control become key to minimizing risks and ensuring compliance with standards. Regulatory reporting and AML are especially important – they require clear coordination of procedures, data transparency and prompt incident response.

AML and regulatory reporting

Internal reporting procedures and regulatory reports record compliance with capital and liquidity requirements, security incidents and governance changes. Capital and liquidity reporting rules vary, but in all cases a transparent accounting of own funds for CASP and FOE is required. AML reporting and Suspicious Activity Reports (SAR) require a qualified MLRO and precision in escalation procedures.

Liquidity management in cases of laundering and rapid outflows relies on pre-approved limits and stress plans. Setting limits on client transactions and margin risks reduces the likelihood of sudden breaks and market cascades. Regulatory fines and license refusals typically occur due to undercapitalization, weak AML and unverified sources of capital; the COREDO team remedied such situations through recapitalization and redesign of the KYC/KYB framework.

Structure audit, modification and closure

Regulatory approvals for changes to capital structure and corporate rights: a standard practice when scaling. External auditors check capitalization, IT controls and compliance with GDPR/PDPA. Business closure procedures and protection of clients’ interests include an asset return plan, regulator notifications and an independent audit of segregation.

COREDO case studies: where details matter

In Lithuania, the COREDO team implemented a project for an exchange CASP oriented toward a MiCA passport. The key was the strategy: the minimum capital for the CASP was covered with equity, and the CASP’s own funds were strengthened with subordinated debt within the limits. We implemented an ICAAP approach and outflow stress tests, recalculated FOE for 18 months and achieved a comfortable assessment by the regulator.

In Singapore, a solution developed at COREDO helped a DPT provider obtain a status compliant with PSA requirements. We built a SOC2-compliant architecture, implemented KMS/HSM and multisig, conducted a pentest and set up incident reporting. MAS positively assessed the competencies of the MLRO and the independence of internal audit.

In Estonia, our experience at COREDO showed how critical staffing requirements are for crypto companies. We supplemented the team with a strong MLRO, separated the CCO and MLRO roles, strengthened Travel Rule integration, and updated AML policies in light of AMLD6 and FATF. The result: a successful license review, reduced risk of enforcement actions, and stable relationships with banks.

In Dubai, the COREDO team established outsourcing of exchange engines with strict SLAs, formalized agreements with custodians and custody terms, and provided for asset and cyber risk insurance. This allowed for reduced capital add-ons for operational risks and sped up VARA approval. We also implemented KPI/KRI for compliance to transparently demonstrate ROI at the board level.

Checklists for CASP license

  • Capital and liquidity:
    • Own funds (own funds): minimum and FOE ≥ 25% of annual expenses.
    • Proof of sources of capital: bank statements, SPA, audit.
    • Recapitalization plan: additional share issuance, subordinated debt, cyber risk insurance.
    • Liquidity reserves and stress tests: outflows, margin calls, provider outages.
  • Personnel and governance:
    • Fit and proper for CASP management; independent CCO, qualified MLRO.
    • Procedure for checking the director’s background, criminal record and sanctions clearance.
    • Management succession plan; Risk, Audit, RemCo committees; conflict of interest.
    • Compensation models and risk-oriented bonuses; compliance KPI/KRI.
  • Technology and security:
    • Segregation of client funds; cold/hot wallets, KMS, HSM, multisig.
    • KYT: Chainalysis/Elliptic/TRM; Travel rule provider; sanctions lists.
    • SOC2/ISO27001; pentest; BCP/DR; incident reporting and contact with the regulator.
    • SLA with outsourcers; agreements with custodians and liquidity providers.
  • Documentation and process:
    • Organizational chart and job/function descriptions; local substance.
    • Business plan: products, revenue models, stress scenarios, financial forecasts.
    • AML/CTF policies, sanctions, KYC/KYB, SAR reports; internal reporting.
    • Passporting plan to the EU; assessment of tax and licensing consequences.

Cost planning and return on investment

Assessing the economic efficiency of hiring vs outsourcing requires comparing TCO: salaries, training and certification of AML/CTF staff, software licenses, external auditors. Metrics for return on investment in compliance and security are measured by reductions in losses from incidents, refusals in banking relationships, fines and licensing timelines. Techniques for optimizing personnel and compliance costs include a centralized center of expertise for the group, policy harmonization and shared services.

Staff planning when entering new markets builds in increased workloads for the MLRO and IT security, as well as stronger Travel Rule compliance and reporting. Economic efficiency assessment that takes into account capital threshold requirements by jurisdiction (EU/Asia/CIS) helps choose the optimal scaling route. comparison of jurisdictions by entry barrier and personnel cost we record in the financial model to support the board of directors’ decision.

Trends and Recommendations

Regulatory trends: tightening capital requirements after incidents and clarifying regulatory guidance on custodian vs exchange liabilities. Benchmarking of capital requirements between the EU and Asia shows an increased emphasis on FOE and operational risk. The impact of crypto insurance on capital requirements is becoming noticeable: regulators view real coverage with minimal exclusions positively.

Managing liquidity and sudden increases in outflows is becoming a key competency. Management of conflicts of interest, the role of the board of directors and committees, measures to reduce operational and reputational risk: all of this affects the assessment of an organisation’s “fit and proper” status. Taxation and reporting requirements for CASP require constant calibration as product lines and geography change.

Lessons from COREDO’s practice

In one project, the regulator initiated license revocation due to a capital shortfall after market fluctuations and an increase in FOE. The COREDO team quickly prepared a recapitalization plan, arranged subordinated debt, and updated the ICAAP and stress scenarios. The regulator accepted the adjustments, and the client avoided a business shutdown and strengthened liquidity reserves.

Another case concerned the travel rule: the provider was failing to meet SLAs and AML alerts were piling up. The solution developed at COREDO included replacing the provider, rebuilding the alert logic, setting KPIs for the team, and improving the MLRO’s competencies. Within two months processing time decreased threefold, and SARs became more accurate in structure and content.

I also highlight a project on the transition from a subsidiary to a branch in the EU. We assessed licensing implications in advance, adjusted capital and internal reporting, and agreed on governance changes. As a result the client retained passporting and optimized their tax position without regulatory delays.

How to gain time and reduce risks

Licensing CASP is a managed project where the outcome is determined by the quality of preparation and the discipline of execution. I recommend starting with an honest readiness assessment: capital and liquidity for 12–18 months, fit and proper for management, maturity of AML and technology security. The COREDO team will support you at every stage – from designing the organizational structure and economic substance to configuring ICAAP, implementing KYT and preparing for interviews with the regulator.

The sooner you turn regulatory requirements into a concrete plan, the easier it is to scale the business and protect clients’ interests. Regulators in the EU, the UK, Switzerland, Singapore and Dubai expect from CASPs the same as from mature financial participants: sufficient capital, responsible management, transparency and operational resilience. COREDO’s experience confirms: it is these principles that make crypto business sustainable and predictable over the long term.

I have led COREDO since 2016 and every day I see the same thing: companies lack structured, pragmatic compliance that works as a business asset rather than a bureaucratic overlay. Over years of working in the EU, the Czech Republic, Slovakia, Cyprus, Estonia, the United Kingdom, Singapore and Dubai, the COREDO team has delivered hundreds of projects – from company incorporations and obtaining financial licenses to building AML/CFT systems and regulatory reporting. This text is not a review of ‘best practices’, but a distillation from real cases, mistakes and solutions that turn a compliance strategy into a real driver of business growth and investor confidence.

Compliance as a competitive advantage

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The compliance strategy as a competitive advantage begins with a clear thesis: compliance reduces the cost of capital and speeds up access to banking services. When a bank sees mature corporate compliance and risk management, it opens accounts faster, expands limits and reduces reserve requirements. COREDO’s practice confirms that effective compliance and access to banking services are directly linked: better KYC/CDD, fewer refusals and delays.
Compliance as a factor in investor trust is even more pronounced. Funds and strategic investors evaluate compliance for startups and scaling as carefully as product metrics. Publicly documented policies, ISO 37301 (compliance management system) and ISO 37001 (anti-bribery system), risk appetite, sanctions compliance and export control — these are no longer ‘checkboxes’, but parameters of the company’s valuation model. Our experience at COREDO has shown: when we implement the risk-based approach and proportionality in controls, M&A deal speed increases and the risk discount decreases.
Return on investment in compliance (ROI) is easy to calculate if you acknowledge direct and indirect benefits. On one hand, a reduction in fines and the cost of compliance breaches; on the other — acceleration of client time-to-onboard, higher transaction throughput due to a lower level of false positives. In several projects we showed boards of directors the compliance ROI calculation formula and scenario modeling: ROI = (avoided losses + margin increase from accelerated processes + savings on manual operations) / investments in processes, people and RegTech.

Compliance for international business

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When I design a compliance framework for an international group, I start with governance. The board of directors defines the risk appetite, approves the roles of the CCO and the functions of internal control and compliance. Next, compliance policies and procedures for international groups, including KYC and CDD in the compliance strategy, third‑party management, conflicts of interest and fit & proper for key executives. Such allocation of responsibilities allows the business to scale without a “manual brake”.
Customer and partner screening components cover PEP screening and risk levels of politically exposed persons, sanctions lists: OFAC, EU, UN and screening practices, as well as beneficial ownership registers, the EU beneficial owners register and national registers. Compliance and requirements for beneficial owners often become a blocking factor when opening accounts and registering companies. The solution developed at COREDO includes automation of UBO identification, document management and an audit trail, which removes regulator and bank questions at the start.
Integrating GDPR and data protection into a compliance strategy is mandatory for any company that operates in the EU or interacts with European clients. We conduct a data protection impact assessment (DPIA) in compliance, apply privacy-by-design and data minimization, and plan international data transfers via SCC and other transfer mechanisms taking Schrems II implications into account. For identification, it is useful to use eIDAS and an electronic signature, as well as biometric verification and identity checks; we always assess model risk and explainability when implementing biometric algorithms.
Sanctions compliance and export control are becoming mandatory not only for defense or high-tech sectors. Compliance for export and international business: it is control of the end user, geographic restrictions and dual‑use items. At COREDO we implement screening and approval processes with segregation of duties and recording of decisions in the document management system to ensure demonstrability and readiness for inspections.

Compliance program: stages and KPIs

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Внедрение комплаенс-программы в компании я делю на четыре этапа: risk assessment and compliance maturity model: assessment framework; проектирование контролей по принципу best practices: risk-based approach и proportionality; автоматизация и обучение персонала; мониторинг, регуляторная отчетность и улучшения. Индекс зрелости комплаенса (compliance maturity) помогает быстро объяснить совету директоров, на каком уровне находится организация и какие инвестиции наиболее окупаемы.
Мы закрепляем комплаенс KPI и метрики эффективности, включая time-to-onboard, SAR rate (доля и качество suspicious activity report), false positive rate в транзакционном мониторинге, время закрытия инцидентов, процент third-party Due Diligence с повышенным риском и долю закрытых «alarms» в SLA. Антифрод и комплаенс для платежных операций измеряются через fraud loss rate, chargeback ratio и результаты антивозвратного аудита и контроля транзакций. Такие метрики дают прозрачность и позволяют корректировать ресурсное обеспечение.
Технологии транзакционного мониторинга на базе ML и антифрод-аналитика и поведенческая аналитика снижают число ложных срабатываний, но требуют governance. В COREDO мы внедряем ML/AI: governance, explainability и модельный риск с периодической валидацией моделей, калибровкой порогов risk scoring и обучением аналитиков. Регуляторы развивают suptech решения, и проверяющие все чаще ожидают отчетность с понятными «feature attributions» и логикой эскалаций.

Registration and licenses – Europe/Asia/CIS

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Compliance when registering a legal entity in the EU today includes checking beneficiaries, sources of funds and the business model already at the stage of submitting documents to the register and when opening accounts. The regulatory architecture in the EU and national regulators – from the EBA and ESMA to local FIUs – have synchronized approaches, and AMLD5/AMLD6 set the framework for identification, monitoring and SARs. COREDO’s practice confirms: a correct group structure, a transparent UBO and readiness for the bank’s KYC questions shorten the process by weeks.
Compliance when registering companies in Asia and Africa requires taking different rules into account. In Singapore, MAS and in Dubai (DFSA/FSRA) impose strict AML requirements/KYC, independence of the compliance function and regulatory reporting deadlines. In Asia, AML/KYC regulatory requirements provide for local CDD specifics, address verification and more detailed profiles of transaction activity. The COREDO team builds benchmarking of compliance practices across jurisdictions to avoid transferring European templates without adaptation.
Separate section: financial licenses. Compliance for financial institutions and payment providers covers licenses for payment institutions, electronic money, forex dealers, crypto providers and banking authorizations. We support the preparation of AML policies, CDD/EDD procedures, monitoring scenarios, business continuity plans, independent audit tests and «fit & proper» for management. In some cases COREDO implemented a «pre-audit» approach, when the regulator saw readiness for FIU procedures and SAR processes before issuing the license.

COREDO cases: from idea to operations

First case, Licensing of a payment company in the EU. The client had delays in opening accounts due to a non-transparent UBO and the absence of a sanctions policy. We redesigned the ownership structure, included beneficial ownership registers and chain-of-control checks, implemented sanctions screening (OFAC/EU/UN) and PEP screening, set up SAR scenarios and regulatory reporting. Time-to-onboard decreased from 21 to 9 days, the false positive rate fell by 37%, and the bank increased limits. The client demonstrated compliance as a competitive advantage in M&A a year later and closed the deal without a discount.
Second case, a crypto company in Estonia. The organization required AML/CFT updates under the new FIU rules, configuration of centralized KYC and KYC re-routing between ecosystem products, as well as integration of eIDAS signatures. We implemented transaction monitoring based on ML, explainable rules, anti-fraud analytics and behavioral models. Result – onboarding speed increased by 50%, increased approval of correspondent accounts by banks and a 22% reduction in chargeback ratio.
Third case: a trading company’s expansion to Singapore with exports to several Asian countries. Key elements were sanctions compliance and export control, supply chain due diligence and responsibility for subcontractors. We implemented third-party management and third-party due diligence, end-user controls, a gifts and conflicts of interest policy, a whistleblowing channel and internal investigations. The business gained access to a key customer for whom ISO 37001 certification was a mandatory requirement for supply.

Third parties in international supply chains

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Compliance when working with third parties and contractors requires a layered control model. We conduct third-party due diligence, assess beneficial ownership, sanctions risks and ESG factors, review compliance practices and perform supply chain due diligence for critical suppliers. Agreed SLAs, clauses on audit rights and periodic re-assessments provide manageability of the chain.
Managing conflicts of interest and fit & proper policies prevent gray areas. A gifts policy, interaction restrictions, transparent escalation and accounting for “connected persons” support corporate ethics. At COREDO we set up corporate investigations and privileged communications so the organization remains protected and ready for inspections without leaks or breaches of attorney–client privilege.
DPA (deferred prosecution agreement) and arrangements with regulators become relevant when a business quickly discloses incidents, conducts internal investigations and remedies violations. Such openness reduces sanctions and returns the company to operational mode. Our lawyers prepare remediation roadmaps, documents for the FIU and adjust regulatory reporting: formats and deadlines must match supervisory expectations.

RegTech and compliance automation

Automation of compliance processes (RegTech) turns manual checks into a controlled factory. Identity verification goes through eIDAS, biometrics, PEP/sanctions databases, and centralized KYC and KYC re-boarding allow reuse of verification results within the group. RegTech platforms and solution providers offer modularity: screening, transaction monitoring, case management, audit trail and regulatory reporting.
Methods to reduce false positives in transaction monitoring include a combination of rules and ML, training on high-quality labeled data, adaptive thresholds, customer segmentation and explainability with “reason codes”. Justifying investment in RegTech to the board of directors is based on comparing the cost of non-compliance with a cost-benefit analysis of implementation, including FTE savings, reduced time-to-onboard and a lower SAR rate due to better upfront filtering.
Implementing ML/AI requires governance: models undergo validation, versions are recorded, and decisions and exceptions are logged. We use document management tools and an audit trail so that every step is reproducible. Control of regulatory changes and horizon scanning are embedded into processes: regulators change SAR guidance, FIUs update formats, and banks refine KYC terminology and documents; the system must pick up updates without failures.

Compliance in investments and M&A

Compliance as a competitive advantage in M&A manifests through a reduction of “regulatory debt”. A buyer assesses compliance due diligence, the presence of ISO 37301/37001, the completeness of SAR processes, the quality of data protection, the maturity of AML/CFT and readiness for regulatory inspections. Compliance and corporate reputation management directly affect deal value, and ESG factors amplify reputational risks and insurer interest (D&O, professional liability).
The impact of compliance on the cost of capital and credit rating is linked to transparency and stability. Banks and agencies trust companies with clear risk governance, proactive internal investigations and modular automation. When a business demonstrates compliance budgeting, KPIs and models for evaluating the effectiveness of compliance programs, borrowing costs decrease.
The legal consequences of non-compliance — fines, bans, criminal prosecution — do not by themselves stop a company’s growth, but they erode flexibility. Analysis of the cost of non-compliance (cost of non-compliance) always shows that proper compliance assessment and independent audits pay off faster than they appear. At COREDO we present scenarios: “no change”, “minimal measures”, “transformation” — and forecast how multiples and bank contracts evolve.

Budget and ROI for the Board of Directors

Compliance budgeting and cost-benefit analysis start with a risk map and “critical gaps”. I use the formula: Compliance ROI = (avoided fines and losses + revenue uplift from faster onboarding + savings from manual operations + reduction in cost of capital) / (costs for people, systems, audits and training). Scenario modeling adds ranges and sensitivity to changes in the regulatory environment.
The Board of Directors cares about simple metrics: time-to-onboard, SAR rate and its conversion into confirmed cases, false positive rate, cost to process a single case, share of “high risk” clients, time to respond to regulatory changes, percentage of completed trainings and test results. The COREDO team prepares packages for audit and risk committees where each KPI is tied to a business outcome and a budget line.
The compliance team should remain lean and proactive. Building the compliance team and the role of the CCO assume a combination of in-house specialists and outsourcing compliance and services of external consultants. Question: what are the risks when outsourcing the compliance function to another jurisdiction? Answer: loss of local context and control deadlines; we mitigate this through SLAs, local officers and a unified case management system.

Culture of learning and continuous improvement

Staff training and a compliance culture are not a one-off mailing but a cycle. I document topical modules: AML/CFT, sanctions regime, GDPR, fraud patterns, conflicts of interest, export control. Corporate ethics and whistleblowing systems provide early signals, and internal control and compliance receive data for improvements.
Cross-jurisdictional compliance for cross-border business requires alignment of policies and procedures so that differences between jurisdictions do not lead to “risk migration”. We carry out corporate group structuring with compliance in mind, adapt regulatory reporting, and build mechanisms for centralized KYC and portable effective checks. Interaction with banks, as well as KYC terminology and documents, is simplified through standard packages: incorporation documents, proof of address, UBO diagrams, descriptions of sources of funds, and the business model.
COREDO regularly prepares clients for regulatory reviews and inspections. Internal investigations and audit preparation for the regulator include test SARs, sample checks, walkthrough processes and interviews. We work transparently, acknowledge difficulties, and develop an improvement plan that the regulator views as constructive cooperation.

Frequently Asked Questions from Clients

Question: How to justify investments in compliance to the board of directors?
Answer: Link investments to business metrics: time-to-onboard, reduction in false positives, increase in conversion, reduction in cost of capital, scenario analysis of fines. Show the ROI formula and the ‘critical gaps’, embedding CAPEX/OPEX into a 12–24 month roadmap.
Question: Which metrics to use to assess compliance ROI?
Answer: time-to-onboard, SAR rate and share of confirmed cases, false positive rate and cost to process a single case, fraud loss rate and chargeback ratio, percentage of tasks closed within SLA, response time to regulatory changes, proportion of employees who completed training, and results of an independent audit.
Question: How to integrate AML and GDPR without conflicts?
Answer: Conduct a DPIA, document the legal basis for processing (legitimate interest/legal obligation), use privacy-by-design and data minimization, restrict access by role, apply SCCs for cross-border transfers, and maintain an audit trail for demonstrability.
Question: What risks arise when outsourcing the compliance function to another jurisdiction?
Answer: Loss of local regulatory context, SLA gaps and mismatched reporting formats. Establish quality control, a local representative and unified policies, and regularly conduct benchmarking and independent audit tests.
Question: How to adapt a compliance strategy when entering a new market in Asia?
Answer: Take into account local regulator requirements (e.g., MAS/DFSA/FSRA), configure local CDD/EDD, rebuild sanctions lists, adapt SAR formats to the FIU, check export controls and local personal data rules. Use local RegTech integrations and certification.
Question: How does compliance affect deal value in M&A?
Answer: A mature program reduces regulatory discount, speeds up due diligence and lowers the amount of warranties and indemnities. Having ISO 37301/37001, clear SAR processes and an ESG framework increases buyer and lender confidence.
Question: Which RegTech solutions reduce time-to-onboard by 50%?
Answer: A combination of remote eIDAS/biometric verification, centralized KYC, preconfigured sanctions screening with PEP risk tiers, behavioral scoring and case management with automated playbooks. The COREDO team implemented such stacks and achieved a twofold reduction in TTO.

What leaders should remember

Compliance and anti-money laundering efforts (AML/CFT) are not a brake on business, but a quality control system. Financial intelligence units (FIU) and SARs: part of day-to-day operations, not a “force majeure”. Sanctions control, export rules, GDPR and beneficial owner requirements: elements of a single architecture, where each policy is supported by a process, a role and metrics.
Scaling issues of compliance systems as a company grows should be solved in advance: modular automation, clear SLAs, a review of risk appetite and regular recalibration of models. Third-party management, supply chain due diligence and responsibility for subcontractors require discipline and a complete audit trail. And most importantly – a compliance strategy for the business should enable access to new markets, not become a barrier.

Conclusions

Compliance as a factor of competitive access to new markets: it is already a fact, not a prospect. When I speak with founders and chief financial officers, I ask them to view compliance through the lens of ROI, deal speed, and the trust of banks and investors. COREDO builds solutions that connect strategy, regulatory requirements and technology: from compliance for the registration of a legal entity in the EU to licensing and daily AML‑operations in Europe, Asia and the CIS.
If you need a partner who understands regulatory logic, knows how to calculate profitability and turns requirements into clear processes, the COREDO team is ready to help. We will turn complex standards FATF, AMLD5/AMLD6, ISO 37301/37001, GDPR and sanctions regimes into a system that accelerates scaling, strengthens corporate governance and increases the company’s market value.

Since 2016 I have been leading COREDO through a shifting regulatory landscape, helping entrepreneurs from Europe, Asia and the CIS launch and scale fintech businesses. Over that time regulators have learned to speak the language of technology, and technology — the language of regulators. I see how the fintech director has evolved from a visionary product specialist into an architect of corporate governance for fintech, a proponent of the risk-based approach and a leader of change. And every time the COREDO team takes on a project, I start with a simple question: how to turn regulatory expectations of fintech directors into a competitive advantage?

In this article I have gathered practical approaches, hands-on tools and proven frameworks that at COREDO consistently lead to licenses, a sustainable operating model and flawless inspections. I deliberately use plain language but employ precise terminology — this way our clients build a shared vocabulary with regulators and increase trust at every stage.

Company registration and jurisdiction selection

Illustration for the section «Company registration and jurisdiction selection» in the article «Regulatory expectations for fintech directors»

jurisdiction selection – not about the speed of opening an account and not about “where it’s cheaper to register an LTD”. This decision is about regulatory risk appetite, market access, compliance costs and reporting requirements. COREDO’s practice confirms: early calibration of objectives (payments, e‑money, crypto, brokerage, lending, neobank) saves months and tens of thousands on restructuring.

We most often compare the EU (Lithuania, Cyprus, Estonia), the United Kingdom, Singapore and Dubai. In Europe the PSD2 linkage and open banking matter, in the United Kingdom: FCA expectations for senior managers (SM&CR) and mature financial crime practice, in Singapore – MAS sandbox and an approach to risk‑based licensing, in Dubai: a focus on virtual assets and structuring client funds. The COREDO team carefully assesses local specifics: regulatory supervision for neobanks, requirements for e‑money providers, safeguarding and escrow options.

License vs local registration

In conversations with clients I rarely recommend a “one‑size‑fits‑all license” without a clear go‑to‑market model. An international license opens doors, but only where it is recognized. Local registration for a pilot market sometimes provides a faster product‑market fit and manageable compliance. The solution developed at COREDO typically includes a map of passporting opportunities, post‑Brexit constraints, requirements for agents/distributors and a plan for subsequent harmonization in the EU or Asia.

EU passporting after Brexit

Service passporting is a real advantage for payment institutions and EMIs, but only with a robust model of three lines of defense (three lines of defense) and readiness for cross‑border supervision. After Brexit a UK license does not provide automatic access to the EU, and “reverse” passporting is impossible. Our experience at COREDO has shown: a hybrid architecture with EU‑EMI and UK‑AEMI can cover both zones with a reasonable compliance TCO.

Beneficial owner (BO) checks

In the EU and in several Asian jurisdictions the beneficial owners register (BO) is part of basic hygiene. We build in advance the evidentiary base of source of funds, the ownership structure and the chain of control to withstand enhanced Due Diligence. This sharply reduces friction when opening accounts and speeds up onboarding with partner banks.

PSD2, crypto and brokerage licenses

Illustration for the section “PSD2, crypto and brokerage licenses” in the article “Regulatory expectations for fintech directors”

When it comes to licensing, the main thing is not the list of documents but the alignment of the operating model with the regulator’s intent. I think in terms of governance, risk, compliance and reporting. This helps design processes so the regulator sees risk control embedded in the fabric of the business, not in detached policies.

Licensing of payment institutions

A payment institution in the EU requires evidence of control over operational and financial risks. We rely on EBA guidance on managing payment risks: risk segmentation, incident management, outsourcing, IT and security. For PSD2 compliance we prepare:

  • a map of products and data flows, including eIDAS and electronic signing schemes;
  • regulatory reporting for fintech: formats, deadlines, SLAs, process owner roles;
  • GDPR and fintech requirements: privacy by design, DPIA and data pseudonymization;
  • procedures for client money rules, safeguarding and reconciliation.

Requirements for e-money providers

For EMI we always model capital adequacy requirements taking into account growth rate, seasonality and stress scenarios. Safeguarding client funds is the core of trust: segregated accounts, escrow structures and daily reconciliations. At COREDO we implement checkpoints for custody vs safeguarding so that no custodial storage function is disguised as protection of client money.

Regulation: AMLD5/AMLD6 and the Travel Rule

We divide crypto regulation for companies into three layers: Licensing of VASPs, AML/CFT and data requirements. Directives AMLD5 and AMLD6 and VASP requirements demand a risk‑based approach, EDD for PEPs, and KYC/KYB processes adapted to on‑chain risks. The Travel Rule sets standards for data transfer in inter-exchange transfers of crypto assets; here we design secure channels and data-sharing agreements. At the same time we take into account sanctions compliance for fintech (OFAC/UN/EU) and restriction registers.

Neobank and regulatory sandboxes

Regulatory sandboxes: a tool, not a goal. I design a sandbox procedure for fintech as a managed experiment with clear hypotheses, metrics and a sandbox exit strategy. In the UK we focus on FCA SM&CR and the role of senior managers; in Singapore – MAS sandbox and Singapore’s requirements on risk disclosure; in Hong Kong, regulatory practice of the HKMA and SFC. We agree in advance on regulatory forbearance, checkpoint mechanisms and a commercialization plan after exit.

Corporate governance of fintech

Illustration for the section «Corporate governance of fintech» in the article «Regulatory expectations for fintech directors»

The right architecture of governance determines the “health” of a license for years to come. The fintech director today: an integrator of product, risk and compliance, owner of culture and performance benchmarks.

Regulatory expectations for fintech directors

Regulatory expectations for fintech directors include transparency of decisions, a managed risk appetite, demonstrable competencies and process resilience. The fintech leader’s responsibility extends to strategy, product economics, fintech compliance and supplier‑chain resilience. The role of the fintech director in the corporate governance system is to ensure a balance between growth and control, to define tolerance statements and to monitor their operationalization.

Compliance director KPIs

What do regulators expect from the compliance director? Clear board reporting, independence of the second line of defense and measurability of controls. We implement KPIs and KRIs: false positive rate and triage speed, SAR rate, detection rate for key scenarios, the closure rate of audit findings and the maturity of continuous monitoring. We complement this with reverse stress testing and scenario analysis so the board can see the boundaries of resilience.

Product cybersecurity: the leader’s role

How does the fintech director ensure product cybersecurity? Through the cloud shared responsibility model, contractual guarantees and regular checks. I build in penetration testing and red team exercises, API vulnerability controls, SIEM/SOAR processes and incident response with pre‑defined communication to the regulator. This reduces operational risk and readies the evidentiary base for inspection.

AML for fintech: detections

Illustration for the section 'AML for fintech: detections' in the article 'Regulatory expectations for fintech directors'

Compliance does not live in documents but in data and case‑level decisions. We configure processes so they are fast for the customer and persuasive for the regulator.

How to build an AML program in a neobank

The roadmap always starts with RBA: segmentation of customers, products, channels and geographies. Next — KYC/KYB, identity verification (IDV) and biometric verification with KYC orchestration to reduce friction and increase conversion. We incorporate PEP screening, Enhanced Due Diligence for high‑risk profiles, counter‑terrorism financing controls (CFT) and anti‑money laundering reporting requirements for payment services.

Transaction monitoring and algorithmic risk

Transaction monitoring systems require careful tuning of scenarios. We combine expert rules and machine learning for fraud detection with explainable AI to ensure algorithmic transparency. Model risk management is a mandatory layer: model governance, model backtesting, drift monitoring, model risk management in scoring and anti‑fraud systems. For complex schemes we use graph analytics and network analysis to improve signal quality.

Sanctions compliance

The sanctions program begins with a risk taxonomy and covers sanctions screening, OFAC/UN/EU lists and local registries. I recommend taking into account the impact of sanctions on supply chains and payments, supplementing vendor due diligence and continuous vendor monitoring. For complex jurisdictions we build a “dual‑track” counterparty screening and near‑real‑time monitoring of sanctions updates.

Regulatory reporting/SAR/audit trail

Suspicious Activity Report (SAR) and interaction with the FIU or FinCEN: an area where speed, completeness and security matter. We prepare regulatory reporting with clear SLAs, requirements for log retention and auditing (audit trail) and continuous monitoring procedures. This ensures reliability and readiness for sudden supervisory requests.

GDPR and data governance

Illustration for the section «GDPR and data governance» in the article «Regulatory expectations for fintech directors»

Data is the lifeblood of fintech, and GDPR is the anatomy. I always start with a map of data flows, legal bases, and transfer boundaries.

Schrems II: SCC/BCR and privacy by design

GDPR: the legal aspects of transferring customer data require consideration of Schrems II and international data transfer mechanisms — SCC and BCR. At the same time, we implement privacy by design, DPIA and requirements for pseudonymization and protection of customer data. eIDAS facilitates cross-border payments and identification, but does not eliminate the need for thoughtful cryptography and access controls.

Outsourcing and third-party risks

Outsourcing is not a way to “shift responsibility”, but an area of increased regulatory scrutiny. I design controlled boundaries with clear metrics and accountable parties.

Outsourcing governance: evidence

We establish outsourcing governance, SLAs with suppliers, contractual frameworks and compliance warranties. In inspections regulators often ask: how to demonstrate risk management of suppliers and integrators? I use a package: vendor due diligence, continuous vendor monitoring, change control, failover tests and a plan to replace a critical provider.

Shared responsibility and cyber risks

Approaches to risk management when outsourcing cloud providers include the shared responsibility model, encryption, segmentation, least privilege and monitoring. Contractual guarantees are complemented by technical measures: logging, anomaly detection, periodic red team exercises and independent audit.

Cross-border supervision and coordination

Interagency coordination and cross-border supervision mean that queries may come from several regulators at once. I proactively arrange communication channels, mapping of regulatory requirements and allocation of roles within the team to ensure a coordinated position.

Regulatory transformations, automation

Regtech today is not a fashionable option, but a way to keep pace with change. I evaluate not only functionality, but also TCO (total cost of ownership) and ROI from investments in AML and regulatory automation.

AML roadmap and change management

The roadmap for implementing an AML project at COREDO consists of discovery, design, build, validate, run. We create regulatory intelligence and mapping of regulatory requirements, configure continuous controls monitoring and prepare the team through targeted training. Change management mitigates the risks of service disruption and loss of knowledge.

Regtech platforms: performance metrics

We select regtech platforms for compliance automation, focusing on integration with core systems and scalability. Metrics: KPIs and KRIs include false positive rate, average investigation time, SAR quality, share of detected cases by key patterns, as well as case management system metrics. These metrics feed into board reporting and show how compliance supports growth.

Regulatory inspections: preparation

Inspections are part of a license’s lifecycle. The more transparent the processes, the smoother the inspection.

Checklist for AML inspection readiness

The regulatory checklist for launching a payment product includes confirmation of capitalization, governance, IT and security, AML/CFT and data protection. How to prepare a company for an AML regulator inspection? We build an audit trail, pre-assign communication owners and compile an “evidence package”: policies, triage procedure, logs, case examples and SAR. internal audit helps to capture an objective picture before the inspectors arrive.

Reputational risk and dealing with findings

After an inspection, a constructive follow-up is important. I use a matrix of findings’ severity, owners and deadlines, and regular reports to the board. This strengthens regulator trust and reduces reputational risk during inspections.

COREDO case studies: what worked

Examples are the best way to show how approaches come to life in real projects. Below: several case studies where the COREDO team delivered on complex objectives on time.

EMI in Cyprus: capital, safeguarding

For a B2B‑fintech we launched an e‑money license in Cyprus. We developed a capital adequacy model with reverse stress testing, set up safeguarding and an escrow model, and established client money rules. For PSD2 compliance we connected open banking modules with eIDAS certificates and carried out a DPIA. The regulator accepted the operating model without additional rounds of questions, a sign of maturity in the documentation and processes.

VASP in Estonia: Travel Rule

A crypto service in Estonia required a VASP license and a full AML/CFT framework. We implemented KYC/KYB with biometrics, configured the Travel Rule, integrated sanctions screening against OFAC/UN/EU lists and network analysis to identify high‑risk wallets. The regulator noted strong explainability in the detection models and transparency of case management.

Neobank in the UK: SM&CR and sandbox exit

For a European startup we designed participation in the UK sandbox and built an SM&CR matrix for senior managers. We defined sandbox metrics, continuous monitoring and a commercialization plan. The sandbox exit strategy included scaling compliance and an international data architecture taking Schrems II and SCC into account.

EU institute: cross-border outsourcing

In a payment institution project in the EU we established outsourcing governance with the cloud provider, defined SLAs and control points, conducted vendor due diligence and continuous vendor monitoring. The regulator requested evidence of supplier risk management, and the prepared package demonstrated process maturity, including contractual guarantees and resilience tests.

Roadmap for the fintech leader

To translate regulatory requirements into growth, I propose a simple framework. It helps the fintech director maintain a balance between product and supervision across different regions.

Steps for scaling compliance

  1. Formulate the regulatory risk appetite and tolerance statements, align them with the board, and operationalize them into metrics.
  2. Build the three lines of defense, define critical KPIs for the fintech director on risk and compliance, and integrate them into the OKR cycle.
  3. Deploy regulatory intelligence, account for fintech regulation in Europe, MAS and HKMA/SFC in Asia, and evolving expectations in Africa.
  4. Plan compliance scaling when entering international markets: passporting where possible and localization where required.
  5. Prepare incident response and communication with the regulator, including inter-agency coordination and cross-border supervision.

Resilience – discipline, not an accident

Over the years I have learned: a reliable fintech company grows from discipline in the details, from choosing a jurisdiction to configuring transaction monitoring systems and board reporting. Yes, regulation changes and becomes more complex. But with a sound governance architecture, a clear RBA and thoughtful automation, regulatory requirements become an ecosystem where it is easier for a business to grow and earn trust.

The COREDO team has delivered dozens of projects in the EU, the UK, Singapore, Estonia, Cyprus and Dubai: and each time our approach has remained the same: transparency, measurability, risk manageability and respect for the logic of supervision. If you are building a payment service, an e-money provider, a crypto service or a neobank, I have a simple recommendation. Start with a requirements map and an honest assessment of operational maturity, then step by step build processes that will withstand inspection in any jurisdiction. This is how a business that is trusted by customers, banks and regulators is created, and how it scales steadily without unexpected regulatory “brakes”.

Since 2016 the COREDO team has implemented dozens of projects for registering companies in the EU, Asia and CIS countries, obtaining financial licenses, setting up AML and launching operational processes for fintech. In this article I have compiled the experience that helps clients move from the idea of a payment service to an international scalable model with passporting, a transparent compliance function and a sustainable economic model.

The purpose of this text is to provide a clear roadmap: how to approach licensing payment institutions in the EU, where the pitfalls of PSD2 payment regulation in the EU lie, and how to turn regulation from a cost into a competitive advantage. COREDO’s practice confirms: sound planning, careful engagement with regulators and discipline in operational risk shorten timelines, reduce compliance costs and accelerate growth.

PI or EMI: license or partnership

Illustration for the section «PI or EMI: license or partnership» in the article «Payment institutions in the EU – differences in regulators' requirements»
The first fork: EMI license vs PI license. Licensing of an EMI and a payment institution differs in essence: an EMI may issue electronic money and hold customer balances in wallets, while a PI provides payment services without issuing e-money. These are different business risks, capital requirements and safeguarding procedures for customer funds in the EU, so the choice should be driven by the product roadmap.

I regularly see situations where a young fintech aims for an EMI, even though monetization is based on card acquiring and PIS/AIS within the open banking logic. In such cases an EU payment institution license is sufficient and scales faster through passporting of the payment institution in the EU. The solution developed at COREDO usually includes modeling revenue, liquidity management and capital requirements for 24–36 months, so as not to overload regulatory and operational perimeters prematurely.

The second fork — license vs partnership with a bank. A partnership model (sponsored BIN, white-label, agency agreements) speeds up an MVP launch and reduces CAPEX, but adds dependence on another party’s compliance policy and limits international scalability. Registering your own payment institution in the EU requires time and resources, but provides control, pricing flexibility and direct access to schemes and correspondent banks. Our team often builds a hybrid: a quick start through a bank partner, followed by opening a payment institution in the EU for key markets.

The legal structure is also important. Legal models — branch vs subsidiary — for entering the EU market offer different levels of substance and risk manageability. A subsidiary simplifies passporting and interaction with regulators, whereas a branch is suitable for testing hypotheses or limited presence. For non‑EU groups you need to consider passporting limitations and the lack of full equivalence: often the right move is to create EU substance with independent management and local compliance.

EU regulators: PSD2, EBA and discretions

Illustration for the section 'EU regulators: PSD2, EBA and discretions' in the article 'Payment institutions in the EU – differences in regulator requirements'
PSD2 regulation of payments in the EU and the EBA’s guidance on payment services have formed the basic layer of requirements. But within this framework national PSD2 discretionary rules and differences in EU regulators’ requirements for payment institutions apply. Our experience at COREDO has shown that properly aligning national approaches saves months and reduces the amount of correspondence in the licensing process.

  • regulatory requirements of BaFin for payment institutions place greater emphasis on IT security and outsourcing (MaRisk, BAIT), thorough management checks and clear segregation of duties. This is a market with intensive supervision and a high quality of dialogue, but expectations regarding substance and operational maturity are above average.
  • ACPR’s regulatory requirements for payment institutions focus on consumer protection, safeguarding and incident management. In an application, clarity of governance, third‑party contracts and a measurable staff training programme are valued.
  • DNB’s regulatory requirements for payment institutions have traditionally been strong on integrity risk and the management of outsourcing chains. In the Netherlands they pay close attention to control models, the independence of the compliance function and the realism of financial plans.
  • Banco de España’s regulatory requirements for payment institutions add an emphasis on local presence and reporting. The regulator expects a well‑thought‑out implementation of transaction monitoring requirements and scenario‑based risk analysis.
  • The Central Bank of Ireland’s (CBI) regulatory requirements are known for the strict “fitness and probity” threshold, the structure of PCF roles and the requirement for detailed operational resilience plans. It is one of the most consistent review practices in the EU.
  • CSSF and Banca d’Italia demonstrate high expectations for capital, IT controls and AML. In Italy it is important to carefully describe ring‑fencing and liquidity buffers, whereas in Luxembourg — to demonstrate the maturity of risk management when outsourcing actively.

The ECB’s roles and supervision in payment infrastructure concern the oversight of clearing/settlement systems and systemically important operators. For PI/EMI the main contact is the national regulator, but ECB standards form the backdrop of expectations regarding resilience and incident reporting. Ongoing supervision versus preferential procedures across EU countries vary in inspection intensity, but the general trend is greater focus on operational risks and cyber resilience.

Capital, safeguarding and liquidity

Illustration for the section «Capital, safeguarding and liquidity» in the article «Payment institutions in the EU – differences in regulators' requirements»
Capital requirements for payment institutions in the EU depend on the range of services and are calculated under PSD2 methodologies (Methods A/B/C), and the minimum initial capital for PI is usually in the range of €20–125 thousand. For EMI it is higher, typically from €350 thousand, taking into account electronic money issuance and the specific risks of holding balances. Capital requirements: minimum amounts and buffers are combined with capital reserve requirements and capital adequacy based on stress‑tests and growth plans.

Safeguarding via segregated accounts vs trust accounts: a key choice of operational model. In some jurisdictions insurance/guarantee alternatives apply, but segregation of funds in accounts at credit institutions predominates. Differences in reserve and ring‑fencing requirements appear in the details: the timeframe for daily segregation, permissible custodian banks, reconciliation mechanics and independent audit checks.

Liquidity management and regulatory requirements boil down to maintaining sufficient own funds, covering peak loads and planning a «survival horizon» under stress scenarios. Liquidity and stress‑test reporting requirements in the EU are converging, but formats and frequency differ between BaFin, ACPR, DNB and CBI. COREDO’s practice confirms: early automation of ALM metrics and independent limit controls prevent regulatory issues at later stages.

AML/KYC: policy and metrics

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AML requirements for payment institutions are built on the AML Directives (AMLD5, AMLD6) and the recommendations of FATF. They require assessing risks, applying KYC/KYB, beneficial owner (BO) verification procedures for PI, monitoring transactions and establishing reporting on suspicious operations. The solution developed at COREDO often includes risk matrices by jurisdictions, products and channels, as well as the design of an escalation “ladder” and exception handling.

KYC automation, eIDAS and remote identification speed up onboarding but require calibration taking into account national rules and the risk level. Biometric identification and regulatory compliance are possible with strong liveness‑check procedures, template protection and independent testing. In correspondent banking relationships it is important to consider interaction with correspondent banks and KYC requirements, since banks impose additional customer verification standards for PI/EMI.
Sanctions screening and sanctions compliance for payment companies imply matching customers and counterparties against OFAC/EU lists and local lists. PEP screening and management of elevated risk should be combined with flexible segmentation so as not to “strangle” conversion. Thresholds for suspicious transaction reports (STR) are interpreted differently, but the general EU logic – STRs are filed on the basis of suspicion, not monetary thresholds, while thresholds are more often applied to other types of reporting.
Transaction monitoring systems and machine learning strengthen anomaly detection when models are supported by correct scenarios, a quality training sample and periodic validation. Managing false positives in AML and the impact on business‑processes is a separate discipline: our experience shows that rules optimization, alert prioritization and feedback from investigations reduce false positives by 30–50% without degrading the detection rate. AML program performance metrics (SAR rate, detection rate) should be recorded in the compliance function’s KPIs and regularly discussed at the board of directors level.

SCA/RTS, GDPR and resilience

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SCA and RTS requirements for payment providers have set standards for strong authentication and transaction risk management. Exemptions based on TRA and low amounts improve UX if risk models are properly calibrated and agreed with the regulator and processing partners. Integration of Open Banking and API requirements for TPPs imply resilient APIs, SLAs, version control and secure token management mechanisms.
Information security requirements and the GDPR for payment services in the EU set a high bar for data protection, processing transparency and data subject rights. Outsourcing to cloud providers and regulatory requirements on data localization require attention to storage location, access from third countries, encryption and audit rights. Contractual obligations when outsourcing critical functions must cover subcontractor control, inspection rights, RTO/RPO and exit plans.
Operational resilience management and BCP for payment providers are strengthened by DORA (Digital Operational Resilience Act) in the EU. Incident reporting and regulator notification rules require reporting significant operational or security events within specified deadlines and formats. Requirements for penetration testing and application security are complemented by vulnerability management, secure development and change control over the business model and notifying regulators if services or geography change.

Outsourcing and fraud prevention

Outsourcing and third-party management in payment institutions are an area of increased inspection scrutiny. Management of business partners and Due Diligence of vendors should include assessment of financial stability, security controls and the compliance of their subcontractors. Requirements for third-party risk management and SLAs imply metrics for availability, response times, quality of investigations and a documented escalation procedure.

Differences in national regulators’ approaches to combating fraud affect the set of minimum measures, but the overall trend is a combination of behavioral analytics, device‑fingerprinting and channel monitoring. Regulatory measures against fraud and chargebacks require close cooperation with scheme providers and acquirer banks. Integration of fraud prevention with UX and conversion is achieved through adaptive application of SCA, whitelists of trusted beneficiaries and thoughtful user communication.

Regulatory frameworks affect both permitted and prohibited business models for payment institutions, including restrictions on holding funds outside safeguarding and mixing client and own funds. Regulatory restrictions on FX and cross-border payments vary by country, especially regarding correspondent chains and exotic currencies. Regulation of interbank settlements and clearing (SEPA) sets standards for formats and timelines, and connection to schemes requires mature processes and a reliable IT architecture.

Documents, timelines, and the economics of compliance

The documents and the package for applying for a payment institution license include a business plan, financial models, policies and procedures, a description of the IT architecture, outsourcing agreements, safeguarding mechanics, a BCP/DR plan, compliance matrices, and management questionnaires. The COREDO team carefully synchronizes the operational and legal parts so that no “gaps” arise between the business and compliance vocabularies in correspondence with the regulator. This reduces the number of request rounds and speeds up the process.

The times to obtain a payment institution license in different EU jurisdictions range from 6–9 months up to 12–18 months, depending on team readiness and the complexity of the business model. Licensing time lag: average timelines across jurisdictions shorten if the pre-licensing dialogue is built on a clear picture of risks and realistic KPIs. The regulatory sandbox for fintech in the EU helps to test hypotheses and engage with regulators, but it has limitations in scale, types of operations and does not replace a full license.
The cost of PSD2 compliance for a business consists of CAPEX for preparation and IT, and OPEX for maintaining compliance, audit and reporting functions. Comparing compliance expenses: CAPEX vs OPEX shows that investments in automating KYC versus manual review pay off at a scale of tens of thousands of onboardings per year. ROI metrics when implementing compliance requirements include reduction in false positives, account opening time, the proportion of blocked fraudulent transactions, and a decrease in regulatory inquiries.

Scalability, M&A and reputation

International scalability and passporting after local requirements: the main dividend of an EU license. The impact of national discretions of EU member states on the single payments market remains, so a go‑to‑market strategy for priority countries must take into account differences in reporting, local substance and consumer interaction. The concept of passporting and restrictions for non‑EU companies remain relevant: for groups from third countries, having substance in the EU with independent governance is the practical standard.

Requirements for internal control and the compliance function should be strengthened as growth occurs: independence, direct access to the board of directors, regular reports and improvement plans. Requirements for audit and external reporting and regulatory reviews and inspections: preparation and response are organized through a pre-approved “playbook” and a set of KPIs/evidence. Managing reputational risks in case of non-compliance includes transparent communication, a corrective action plan and documenting progress.

Due diligence practices in M&A of payment platforms require verification of licenses, compliance with safeguarding, the quality of AML frameworks, contracts with third parties and any open regulatory issues. Exit scenarios in the event of license revocation and customer protection must be predefined in BCP plans and in safeguarding agreements. Assessment of scalability: the impact of regulatory barriers on user growth and the pricing model of payment services and the impact of regulatory requirements should be considered when planning unit economics and choosing markets.

MiCA and tokenized assets

Crypto payments regulation and the intersection with MiCA is becoming a new reality for payment companies that want to accept or convert digital assets. Rules for e-money and the issuance of tokenized assets differ, and custodial vs non-custodial models in payments carry different risks and expectations regarding controls. At COREDO we help separate the flows: payment services under PSD2, e-money under EMI, and crypto services under national and pan-European MiCA regimes, so as not to “mix” risks and licences.

Outsourcing of critical functions in the crypto part requires special attention to the chain of subcontractors and key storage. Regulators expect clear answers on sanctions screening, the origin of funds and monitoring of blockchain transactions. International cooperation on AML and FATF recommendations for VASPs impose additional checks, which are important to consider when integrating the crypto pathway into the overall risk appetite of a PI/EMI.

COREDO case studies – from application to growth

One of the projects: a payment institution license in Ireland. The client came with an ambition for instant‑payments in the B2B market and a plan for fast cross‑border transfers. The COREDO team built governance to meet CBI requirements, described TRA models for SCA/RTS, prepared outsourcing agreements and a BCP plan taking DORA into account. As a result the application passed with a minimal number of queries, and after obtaining the license the client successfully implemented passporting to several EEA countries.

Another example – a fintech company’s entry into the German market targeting open banking services. We mapped BaFin’s IT and outsourcing requirements against the existing cloud architecture, strengthened change control and implemented an independent pen‑testing process. At the same time an approach to safeguarding via segregated accounts at a tier‑one bank was agreed and transaction monitoring scenarios were configured, which reduced operational risks and sped up integration with partners.

The third case – scaling a Spanish PI with added FX functionality. COREDO’s practice confirmed that Banco de España pays close attention to cross‑border chains and liquidity. We implemented stress tests on currency positions, negotiated additional limits with correspondents and updated the AML policy with a focus on exotic corridors. As a result the company maintained its growth pace without supervisory objections.

Payment institution launch checklist

  • Licensing strategy and geography. Determine where local substance is critical and how quickly passporting is required, and build a PI vs EMI and bank‑partnership vs own‑license model over a 24‑month horizon. This approach reduces regulatory duplication and unnecessary costs of rebuilding the architecture.
  • financial resilience and safeguarding. Calculate capital and buffers, choose a segregated vs trust account model, prepare agreements with custodian banks and descriptions of reconciliations. Ensure that ALM metrics and stress scenarios are available “at the push of a button”.
  • Compliance and AML. Set up KYC/KYB, BO checks, OFAC/EU sanctions screening, PEP procedures and transaction monitoring with ML scenarios. Implement SAR/detection metrics and a false‑positives reduction program with feedback from investigations.
  • Technology and security. Implement SCA/RTS, an API policy for open banking TPPs, GDPR controls and a data processing register. Conduct an independent pen test and document BCP/DR plans under DORA with incident reporting procedures.
  • Outsourcing and third parties. Conduct supplier due diligence, agree SLAs, audit rights, exit plans and control subcontractors. Verify that the cloud architecture complies with local regulator requirements.
  • Reporting and inspections. Prepare a regulatory calendar, report templates, a playbook for inspections and a change‑notification process for business‑model changes. Regularly train staff and maintain a culture of compliance.

COREDO’s scalable regulatory growth

Registrations, licences and AML are not “paperwork”, but a risk-management system that underpins the international payments business. When the foundation is strong – capital requirements are met, safeguarding is transparent, SCA/RTS are implemented, the AML framework is measurable and technological, growth happens faster, and the dialogue with regulators becomes constructive. At COREDO I insist on sequence: first strategy and architecture, then documentation and evidence, and only then the submission.

Our experience at COREDO has shown that the right jurisdiction, a well-prepared licensing package and a mature operating model reduce time‑to‑market and the cost of compliance. The COREDO team speaks the same language as BaFin, ACPR, DNB, Banco de España, Banca d’Italia, CBI and CSSF, taking into account national discretions while the logic of PSD2 remains unchanged. We support clients from company incorporation to licensing as an EMI and a payment institution, from AML concept to incident reporting and DORA, helping build reliable, scalable and profitable payment businesses.

If your plan is to enter the EU and use passporting while keeping processes transparent and saving time, start with a well-considered roadmap. COREDO’s practice confirms: a strategy backed by measurable controls and attention to detail turns regulatory requirements into the foundation of long-term partnership with the market and regulators.

Company registration in the EU, Asia and the CIS, obtaining financial licenses and building a reliable AML framework are not separate projects, but interconnected elements of a resilient strategy. When an entrepreneur gains the ambition to operate simultaneously in the Czech Republic, Slovakia, Cyprus, Estonia, the United Kingdom, Singapore and Dubai, complexity grows exponentially. My task as a leader is to propose a path that preserves control, speed and transparency, and at critical points relies on technology, including artificial intelligence in AML.

In recent years the team COREDO has implemented dozens of projects where legal design, licensing and AML monitoring reinforce each other. Our experience at COREDO has shown: the earlier you account for AML and AI regulatory requirements and design KYC/KYB processes, the easier it is to scale the business, open accounts, integrate payment gateways and pass audits. In this article I have compiled a practical guide that connects strategy, procedure and technology, and also answers common questions of owners and chief financial officers.

Choosing jurisdiction and structure

Illustration for the section “Choosing jurisdiction and structure” in the article “Impact of AI tools on AML monitoring”
The right jurisdiction: it’s not about “the fastest register”, but about alignment with the business model, the license and traffic sources. In the EU this is primarily compliance with the EU AML Directives (AMLD5/AMLD6), GDPR requirements and local supervisory authorities. In Asia and the Middle East we take into account the MAS in Singapore and UAE regulators, including DFSA/VARA in Dubai, as well as the recommendations of FATF. COREDO’s practice confirms: investing time in a preliminary AML gap analysis reduces risks when opening accounts and interacting with banks.

Companies working with payments, forex or digital assets feel the difference in levels of evidential basis. For example, in the United Kingdom the regulator expects a mature risk model and transparent case management, whereas in Cyprus the emphasis is more on governance and an independent AML audit. The solution developed at COREDO,, is country regulatory map templates that show requirements for capital, key functions (MLRO, compliance), reporting and SLAs with KYC providers.

When choosing a structure, I recommend the compliance-by-design principle. This means that the ownership chain, substance, local directors and operational flows are pre-aligned with the future license and AML model.

Such an approach facilitates PEP screening, sanctions checks (OFAC, EU, UN) and subsequent regulatory reporting (SAR/STR). It also reduces the likelihood of “untenable” conditions from banks when opening accounts.

Differences and priorities of EU countries

In the Czech Republic and Slovakia we see a stable legal environment and clear substance requirements. Cyprus remains popular for payment services and forex companies, with a focus on CySEC and detailed AML policies. Estonia is useful for digital companies, including virtual asset operators, while the regulator is demanding regarding real presence and AML systems.

United Kingdom: it’s about mature practices and close scrutiny of governance, as well as the need to demonstrate the explainability of models if AI is used in AML. The COREDO team often moderates dialogue with banks, explaining hybrid rule+ML AML solutions and false positive control.

Singapore and Dubai – Asia and the Middle East

Singapore via MAS sets a high bar for risk management, data quality and independent model validation. In Dubai, including DIFC and virtual assets in VARA, clear boundaries between the front office, the AML function and independent audit are important. Our experience at COREDO has shown that local adaptation of KYC/KYB and sanctions screening speeds up onboarding of partners and clients in these markets.

Compliance by-design: AML and licenses

I proceed from the assumption that each license is a set of procedures and metrics that must be embedded into the architecture from day one. Automation of client verification (KYC/KYB), real-time sanctions screening, adverse media screening using NLP and NER, as well as a documented data ownership line (data lineage), are not “optional” but a basic outline.

When this logic is built into the charter documents, contracts with providers and the operational regulations, Licensing proceeds faster and more predictably.

Financial licenses: forex, crypto

Illustration for the section «Financial licenses: forex, crypto» in the article «The impact of AI tools on AML monitoring»
Licenses for payment services, forex activity, crypto services and even limited banking operations require varying depths of capitalization, internal policies and staffing roles. We use COREDO checklists for the document package, including the business plan, risk appetite, description of AML processes, training plans and disaster recovery. We separately document AML monitoring, alert criteria and their triage process.

Regulatory requirements and FATF

FATF recommendations and local laws require a risk‑based approach (RBA), clear customer categorization and adaptive monitoring thresholds.

EU AMLD5/6 insist on beneficial owner transparency and sanctions screening; FinCEN is strengthening requirements for SARs and quality assurance. COREDO’s practice confirms that explainable AI for AML (XAI) is becoming an expectation of regulators, not just a technological trend.

Documentation and timelines: common bottlenecks

The main bottlenecks are unclear sources of funds (SoF/SoW), weak data governance and inconsistent KYC profiles. We offer structured templates for SoF, external data enrichment sources and entity resolution procedures for complex corporate structures.

This reduces investigation time and lowers cost per investigation.

COREDO licensing cases

Recently a solution developed at COREDO helped a Europe‑focused payment provider structure an EMI licensing package taking into account a hybrid AML architecture. We implemented graph-based transaction analysis to detect circular patterns and symmetric peers and prepared XAI reports for the regulator using SHAP. The result: an accelerated dialogue with the regulator and a smooth launch of real‑time AML monitoring.

AI and AML in real practice

Illustration for the section «AI and AML in real practice» in the article «The impact of AI tools on AML monitoring»
AML for international business is often perceived as an obligation. I prefer to talk about a competitive advantage: reduced operating costs, faster onboarding and increased payment conversion. artificial intelligence in AML allows shifting the focus from manual review of “noisy” alerts to investigating truly risky scenarios.

The COREDO team implemented projects where AML automation reduced false positives by 30–60%, while increasing recall on known patterns. ML-based transaction monitoring combined with a rule engine provides stability in known areas and flexibility for new anomalies. Importantly, we always preserve human-in-the-loop and transparent decision traceability.

Why businesses need AI in AML

  • Reducing false positives in AML: targeted feature engineering and graph embeddings allow filtering out “white noise” without increasing false negatives.
  • Optimizing AML alert triage: prioritization by risk score and cost per alert speeds up the response to genuinely dangerous events.
  • Reducing the cost of AML investigations with AI: automatic context gathering, entity resolution and linkage reduce MTTI.
  • Speeding up onboarding: KYC and artificial intelligence help complete checks in minutes while maintaining the quality of PEP and sanctions controls.

Hybrid rule-based and machine-learning AML solutions

The hybrid approach combines rule playbooks for known scenarios and anomaly detection models for “grey areas”. Real-time AML monitoring relies on streaming buses (Kafka/Kinesis/Pub/Sub), online scoring and low-latency stores (for example, Key-Value + an analytics lake like Snowflake/Databricks). Our architectures support API-first integration with core systems and case management, allowing flexible scaling during peak loads.

KYC/KYB, transactions and data quality

Data is the foundation. For international companies these are KYC/KYB profiles, transaction logs, device footprint, geolocation and external sources (sanction lists, PEP, adverse media). Improving data quality for AML models includes record linkage, fuzzy matching, data lineage and controls at the ETL/ELT stage. COREDO’s practice confirms: investments in data quality pay off first because they directly affect precision/recall and the number of alerts.

AML system models using machine learning

We use a combination of tree-based models (XGBoost), autoencoders for anomalies, isolation forest and clustering (DBSCAN/HDBSCAN). For graph scenarios, Neo4j/TigerGraph, graph embeddings (node2vec, DeepWalk) and, where appropriate, GNNs for complex network motifs.

Graph analysis in AML is especially useful when analyzing large transaction graphs and detecting complex structures where simple rules are powerless.

AI/AML Roadmap

Illustration for the «AI/AML Roadmap» section in the article «The impact of AI tools on AML monitoring»
We start with the business case: where the losses are, which KPIs matter, what TCO is acceptable. Then we document regulatory requirements for AML and AI, and define the architecture and change management plan. I personally insist on a phased rollout: pilot, limited production, scaling, with a ModelOps loop and risk controls.

KPI and metrics: precision, recall, PR-AUC

We measure not only model quality but also operational metrics. Precision/recall and PR‑AUC for key scenarios; precision@k for priority alerts; alerts per 1000 customers; mean time to detect (MTTD) and mean time to investigate (MTTI).

At the economic level – cost per alert, cost per investigation, OPEX for onboarding and the share of automated decision-making agreed with regulators.

ModelOps and XAI: model governance and drift

Explainability is mandatory: SHAP/LIME, counterfactual explanations and XAI reports for regulators. Managing model drift in AML requires continuous evaluation, backtesting and versioning models in a registry, with audit trails. The COREDO team implements model validation procedures and independent controls to eliminate the ‘black box’ in critical steps.

on-premises vs cloud: core banking, SIEM

Integration must be seamless. We connect AML scoring with core banking, payment gateways and orchestration systems, as well as with SIEM and event logging for a complete trace. The choice of on‑premise vs cloud vs hybrid depends on data localization requirements, latency and costs; often hybrid wins thanks to the balance of control and scalability.

Data privacy and GDPR

Legal aspects are a separate layer. For the EU this is GDPR and local personal data laws; in Asia and the CIS there are their own rules for cross-border data transfer. In some cases we used privacy‑preserving ML: federated learning, differential privacy and MPC, to train models without moving sensitive data across borders.

This reduces regulatory risks and preserves confidentiality.

COREDO cases and results

Illustration for the 'COREDO cases and results' section in the article 'Impact of AI tools on AML monitoring'
I prefer to speak with facts. Below are three examples where AI and AML methods turned from a project into operational value with clear economics and compliance.

Reducing false positives at an EU provider

The client was a mid-sized international payments provider with offices in the Czech Republic and Slovakia, a growing merchant base, and fines for payout delays. The problem was a high level of false positives and an overloaded investigations team. The COREDO team implemented a hybrid rule+ML solution, including graph embeddings and adaptive thresholds; they introduced alert prioritization and automatic context collection.

Result: about a 45% reduction in AML false positives, a 35% reduction in MTTI and transparent XAI reports for internal control. After six months TCO decreased due to reduced manual workload, and the payout SLA improved without compromising security. A regulatory review confirmed sufficient explainability and governance.

XAI and crypto-provider checks

A virtual assets operator licensed in Estonia and Cyprus faced a requirement to increase the explainability of AML models. The solution developed at COREDO included SHAP reporting at the individual alert level, a backtesting and stress-testing framework on “synthetic laundering patterns”. At the same time we enhanced adverse media screening, applying BERT/transformer for NLP and entity resolution.

As a result the client passed an unscheduled audit, confirmed the correctness of procedures, and maintained onboarding pace. Additionally, we modified the sanctions pipeline to real-time Sanctions screening with thresholds based on risk score and geocontext. The risk profile became more predictable, which eased dialogue with correspondent banks.

Scaling fintech in Singapore and Dubai

A fintech company from Singapore was entering Dubai with a new payments product line. The key challenge was scaling the AML-ML system and managing cross-border data within MAS and local UAE regulations. COREDO’s practice confirms the effectiveness of a hybrid architecture: data localization with federated learning, a centralized model registry and unified KPIs.

We implemented continuous training with model drift monitoring and auto-alerts for compliance officers. Operational metrics throughput/latency met the SLA, and precision@k for alerts at the top priority levels reached target values.

The business entered the new market without “manual slowdowns” from AML processes.

Frequently asked questions from clients

Frequently asked questions from clients about applying AI to combat money laundering reflect growing uncertainty: should a small international payments provider invest in such solutions and how to assess their effectiveness? Below we’ll review the key concerns, potential benefits and practical steps to make a well‑informed decision.

Is it worth investing in AI for AML?

Yes, if there is a clear business case: a high percentage of false positives, rising investigation costs, SLA pressure and plans to scale into new markets. For small providers we recommend a modular approach: start with automating KYC/KYB, sanctions screening and alert prioritization. The COREDO team has implemented lightweight pilots that pay back in 6–12 months through OPEX savings and improved onboarding conversion.

KPIs and metrics after deploying AI in AML

Minimum set: precision/recall for key scenarios, PR‑AUC, precision@k for top alerts, alerts per 1000 customers. Operationally: MTTD, MTTI/MTTR, cost per alert and cost per investigation, share of auto‑classification and escalation rate. Financially – TCO and ROI, expressed in reduced OPEX and losses from delays/penalties.

When will an AI project in AML pay off?

Typically 9–18 months, but much depends on the initial level of automation, data quality and regulatory constraints. Projects focused on reducing false positives and automating triage pay back faster. Longer payback occurs with complex graph analytics and strict data localization requirements; a phased rollout helps here.

Compliance risks of the machine-learning black box in anti-money laundering

The risk of decision opacity and the inability to defend them before a regulator. Mitigated by XAI: SHAP/LIME, counterfactual explanations, model cards, audit trails. We also apply human‑in‑the‑loop in the final decision, separating model assistance from the officer’s responsibility; this aligns with regulator expectations in the EU and Asia.

Human-in-the-loop for alert triage

Optimal is a three‑level scheme: auto‑closing low‑risk alerts, semi‑automatic triage for the mid‑range and manual investigation for high‑risk cases. Active learning helps direct labeling to where the model “is uncertain”, speeding up training. COREDO’s practice shows that such a scheme reduces MTTR and improves SAR quality.

AI regulators for AML in the EU, Asia, and the CIS

In the EU: AMLD5/6, EBA Guidelines, GDPR; in the UK: local guidelines on model explainability; in Singapore: MAS and AI governance guidelines; in the UAE: DFSA/VARA.

We treat FATF recommendations and FinCEN requirements as a benchmark, especially for cross‑border scenarios. We record this in the project’s regulatory map and take it into account when designing governance.

Data for cross-border ML in AML

The key is localization, minimizing transfers and pseudonymization. We use federated learning and differential privacy to train models on local data, transmitting only aggregates and gradients. Data lineage and data provenance are documented for audit and compliance demonstration.

On-premise vs cloud vs hybrid for AML AI

Hybrid most often wins: sensitive data and online scoring locally, training and analytics in the cloud. This balances security requirements, latency and cost. In critical markets we build an on‑premise stack with containerization (Kubernetes, Docker) and microservices, maintaining compatibility with cloud MLOps.

Reducing false positives for ROI

  • Hybrid rule+ML AML solutions where ML enriches signals and refines context.
  • Graph methods: graph embeddings and GNNs to reveal “hidden” connections.
  • Adaptive thresholds and alert prioritization, supported by precision@k.
  • Improving data quality, including entity resolution and external enrichment.

How to choose an AI vendor for AML

We look at explainability, experience in your industry, completeness of integrations (case management, SIEM, core), SLA for latency/throughput and model governance.

It’s important to have backtesting capabilities, a model registry, audit trails and a transparent total cost of ownership. The COREDO team supports clients at the RFP and vendor Due Diligence stage, helping to evaluate not the “demo” but the solution’s viability.

How COREDO works: approach, stages, SLA

I value process predictability. That’s why at COREDO we split the project into clear stages, define success criteria and support the client’s team at every step.

This reduces operational uncertainty and strengthens trust with regulators and banks.

Diagnostics and design project

We start with legal and operational diagnostics: company structure, licenses, AML policies, data and IT landscape. We form a target architecture that includes AML monitoring, KYC/KYB flows, sanctions screening and integrations. We prepare a roadmap with KPIs, a TCO assessment and a change management plan.

Implementation and integration

We implement customer verification automation, connect external lists and adverse media with NLP, configure streaming scoring and case management. We introduce MLOps/ModelOps: model registry, continuous training/evaluation, backtesting and drift monitoring. At the same time we prepare XAI reports and a model governance framework for regulatory dialogues.

Support, audit and team training

We train analysts and MLROs, set up human-in-the-loop and active learning. We conduct regular AML audits, stress tests, regulatory simulations and playbook updates. We maintain a KPI dashboard: precision/recall, PR‑AUC, MTTD/MTTI, cost per alert and operational SLAs.

Key takeaways

International growth: it’s a combination of the right jurisdiction, timely licensing, and mature AML. Artificial intelligence in AML strengthens each element of this triad: it reduces operational costs, accelerates onboarding, and makes risk management predictable.

At the same time, the key to resilience is explainability, ModelOps and a strict discipline in data handling.

The COREDO team has implemented solutions that operate in the EU, the UK, Singapore and Dubai, and shows how integrating AI into existing AML processes leads to measurable results. If you are seeing an increased compliance burden, planning new markets, or preparing for licensing, it makes sense to turn AML into a source of advantage, not a compromise.

My team and I are ready to help build this path transparently, step by step, and based on regulators’ requirements and real-world business practice.

Limitations of traditional AML monitoring

Classic AML monitoring relies on rule-based systems, sanctions screening and threshold rules that raise alerts when fixed values are exceeded. This approach is supplemented by manual triage and investigations, where analysts gather context on the customer, transactions and external sources, including OFAC/EU sanctions lists and local registers. It is understandable, reproducible and familiar to regulators, but does not scale well as volumes grow and laundering patterns become more complex.

Key weaknesses: high false positive rates, poor resilience to changing schemes and difficulties with record linkage and fuzzy matching. Entity resolution often breaks on name variations, typos, transliteration and the «splitting» of entities across systems. As a result SARs are initiated late, MTTD/MTTI increase, and the costs of investigations and escalations rise.

Metric Manual/rules (typical) AI/automated (target)
Alerts per 1000 customers 40–120 15–50
False Positive Rate 85–95% 50–80%
Cost per alert €18–€45 €8–€20
MTTD (detection) hours–days minutes–hours
MTTI (investigation) 1–3 days 4–12 hours
SAR conversion rate 1–3% 3–7%

Even a small reduction in alerts per 1000 customers and the false positive rate quickly converts into a lower cost per alert. These shifts also reduce the team’s workload, improving the quality of investigations and the proportion of truly relevant SARs.

AI in AML: when and how to apply

Supervised‑approaches use labeled cases (suspicious/not suspicious) to build scoring models that prioritize alerts and reduce noise.

They are appropriate with mature labeling and stable investigation processes, especially in transaction monitoring and when assessing clients’ risk profiles. The key condition: a sufficient volume of quality labels and stable business processes.

Unsupervised‑methods detect anomalies and new patterns without labels, which is useful for “gray areas” and the emergence of new schemes.

Semi‑supervised and active learning combine limited labeling and iterative label collection through human‑in‑the‑loop. Hybrid rule+ML solutions provide the greatest controllability: rules capture known patterns, and ML surfaces “non-trivial” signals and refines context.

The choice of approach depends on data maturity, tasks and regulatory constraints. For PEP/sanctions screening, improvements in fuzzy matching, NER and match prioritization are effective, whereas for adverse media NLP/transformer models with vector search work better. In any scenario, data quality, clear definition of business cases and model drift monitoring are critical.

Anti-money laundering systems using machine learning

For an AML system with machine learning, a well-thought-out architecture that ensures scalability, reliability and rapid model integration is critical. In the following sections we will examine architectural patterns and key algorithms that determine the accuracy and speed of risk detection.

Architectural patterns

The production architecture is built around stream processing of transactions and batch analytics for training. Online scoring via API/webhook provides low-latency decisioning, and the feature store synchronizes features between online and offline. The MLOps loop includes a registry, automated tests, backtesting and canary deployments to safely roll out updates.

Algorithms: applicability

  • Tree‑based (XGBoost, Random Forest): interpretable scoring of transactions and customers, strong on tabular data and ‘medical’ features.
  • Neural networks: useful for complex nonlinearities and multimodal data, but require XAI pipelines.
  • Autoencoder and Isolation Forest: unsupervised anomaly detection where there are no labels or patterns drift rapidly.
  • Clustering (DBSCAN/HDBSCAN, k‑means): segmentation of customer risks, identification of atypical behavioral clusters and outlier groups.

Combining multiple methods increases robustness, and stacked models (ensembles) help balance precision/recall. Probability calibration and threshold tuning tied to KPIs and regulatory escalation policies are important.

Reducing false positives through GNN

Graph analysis combined with GNN helps reduce false positives by explicitly accounting for relationships between entities and transactions. In the following subsections we’ll examine what advantages graphs provide in AML and how these connections become informative features.

Graphs in AML: what do they offer?

Graph analysis in AML reveals hidden links between counterparties, devices, addresses, and beneficiaries.

These models detect ring schemes, layered transits, and ‘smurfing’, where simple threshold rules are ineffective.

Entity resolution on the graph merges duplicates and partial matches, reducing noise and improving accuracy.

Methods and technologies

Graph databases (Neo4j, TigerGraph) provide fast queries for motifs and subgraphs, and graph embeddings (node2vec, DeepWalk) translate topology into vectors for ML scoring. GNN (GraphSAGE, GAT) learn from the structure of connections and node/edge features, reducing false positives by contextualizing behavior.

Important addition: explainability at the subgraph level: highlighting the paths and motifs that influenced the decision.

Integrating graph features into the overall scoring improves precision@k and speeds up triage. This is especially useful in international networks where links span multiple jurisdictions and currencies, and sanctions matches require additional context.

NLP/transformers for KYC and adverse media

Using NLP and transformers enables automating and scaling checks in KYC, adverse media analysis and processing of transaction descriptions, increasing the accuracy of matching and risk detection. In the following subsections we will examine key use cases, from monitoring negative publications and identifying connections to normalizing and classifying transaction descriptions.

Use cases

NLP‑models increase the accuracy of adverse media screening, extract entities (NER) from documentary KYC/KYB flows and classify transaction descriptions.

Multilingual transformers help process local media, court registers and open sources in the EU, Asia and the CIS. Vector search with embeddings facilitates uncovering hidden links and “similar” cases.

Technology stack

The BERT/transformer family and specialized multilingual models work in tandem with OCR and data normalization. Relevance ranking, news deduplication and sentiment/stance analytics reduce manual work and improve the quality of signals.

For explainability, key phrases, attention maps and classification rationale are used, which is important for regulatory inquiries.

Metrics and KPIs after AI implementation

Key model metrics – precision, recall, F1, PR‑AUC, precision@k and false positive rate – are linked to operational ones: alerts per 1000 customers, MTTD, MTTI, cost per alert and throughput/latency. For executives it is important to tie these metrics to economics, including TCO and ROI. Proper visualization of metrics in dashboards increases transparency and manageability.

Basic ROI formula: ROI = (OPEX savings + avoided losses/penalties + additional margin from accelerated onboarding − TCO) / TCO. Sensitivity is assessed by three parameters: reduction in false positives, reduction in MTTI and the share of automated solutions in the low‑risk zone. We recommend performing sensitivity analysis over ranges rather than points to account for regulatory and seasonal fluctuations.

Scenario template for assessment:
– Conservative: −20% false positives, −15% MTTI, +10% auto‑close low‑risk; payback period 15–18 months.
– Realistic: −40% false positives, −30% MTTI, +25% auto‑close; payback period 9–12 months.
– Aggressive: −60% false positives, −45% MTTI, +40% auto‑close; payback period 6–9 months.

Integration of AI into AML processes and the IT landscape

A practical integration plan begins with building reliable data pipelines (ETL/ELT) and a DataOps discipline. Streaming buses (Kafka/Kinesis) provide real‑time ingestion, and the feature store synchronizes online/offline features. API‑first integration and webhooks enable online scoring and automatic triage without heavy rework of core systems.

On‑premise is appropriate when strict localization and low tolerance for external dependencies are required, cloud – when rapid elasticity and accelerated R&D are needed, hybrid – for a balance of control and scalability. Integration with core banking, payment gateways, case management and SIEM creates a unified audit trail and accelerates investigations.

Process orchestration (for example, via BPM/ESB) enforces escalation rules and human‑in‑the‑loop.

Model governance and explainability

Model governance relies on versioning, model registry, reproducible training and audit trails. Backtesting and independent validation check robustness, bias and stabilize thresholds relative to risk appetite. We recommend a three-line defense model: development, independent validation and internal audit.

Explainable AI (XAI) is implemented through SHAP/LIME, counterfactual explanations and “model cards” describing purpose, limitations and data. Regulatory XAI reports include feature attribution, sensitivity to parameters and examples of cases that have undergone human review. Drift management is built on monitoring distributions, PSI/KS metrics and retraining schedules.

Legal and ethical aspects of AI in AML

In the EU, AMLD5/6, EBA Guidelines and the GDPR are important; in the US, FinCEN requirements; in Asia, MAS and local regulators; in the CIS — national personal data and AML laws. Regulators expect explainability, a clear human role in final decision-making and full auditability. Documentation should include model objectives, test cases, limitations and escalation procedures.

Legal risks concern the ‘black box’, cross-border data transfers and localization. They are mitigated by transparent models, pseudonymization, privacy-by-design and local training environments. Vendor due diligence is mandatory: we look at the hosting jurisdiction, subprocessors, incident policy and security SLAs.

privacy-preserving ML for AML

Federated learning, differential privacy, MPC and partially homomorphic encryption help train models without transferring raw data.

In AML, their applicability is tied to cross‑border restrictions, but an assessment of computational costs and quality trade-offs is required.

Synthetic data helps expand datasets and test “rare” patterns without disclosing personal data.

Model threats include data poisoning, adversarial examples and model stealing. Protection is built on validation of data sources, robust tests, rate‑limits and monitoring of anomalous API requests. Regular “red teaming” of models reduces the risk of vulnerability exploitation.

Checklist: vendor selection, pilot, implementation

Vendor selection criteria: model transparency and XAI, experience in your industry, completeness of integrations (case management, sanctions, adverse media), SLA for latency/throughput and support for on‑prem/cloud/hybrid. Backtesting capabilities, model registry, audit trails and a clear total cost of ownership are important. Legally, check licensing terms, subprocessors and compliance with GDPR/local laws.

PoC must have clear objectives, a baseline (rule‑based), a set of success metrics and a limited but representative dataset. A 6–12 week timeline is realistic with ready data and integrations; the outcome is a go/no‑go decision and a TCO/ROI plan. The project team includes an MLRO, compliance, data scientists, integration engineers and a product owner, and human‑in‑the‑loop is documented in playbooks.

Mini checklist for PoC:

  • Data: sources, volume, quality, anonymization/localization.
  • Metrics: precision/recall, PR‑AUC, precision@k, MTTD/MTTI, cost per alert.
  • Integrations: API, webhooks, case management, sanctions provider.
  • XAI: methods, report format, case examples.
  • Governance: registry, versioning, backtesting, decision log.

Scaling AML-ML in Europe and Asia

Regulatory requirements and data formats vary from country to country, as do local PEP/sanctions lists. Localization processes are needed: separate pipelines, dictionaries, thresholds and language models for adverse media. Multi‑currency and time‑zone differences require careful normalization of features and time-series.

Technically, scaling relies on horizontally scalable queues, stateless services and sharding of the feature store. Streaming scoring must withstand peaks, and replication and geo‑routing reduce latency. Practical recipe – local PoCs, adaptation of thresholds and retraining of models on local data with federated/transfer learning.

Implementing AI in AML for Executives

Step 1 – Readiness assessment: conduct a data audit, inventory sources and pain points, align KPIs (precision@k, cost per alert, MTTD/MTTI). Define regulatory boundaries (GDPR, localization, explainability expectations) and target business cases. Document TCO constraints and a risk checklist.

Step 2: PoC: choose 1–2 priority scenarios (e.g., reducing false positives in transaction monitoring), prepare a baseline and dataset. Establish success criteria and an integration plan, ensure XAI reporting and a human-in-the-loop protocol. Make a go/no-go decision based on metrics and stress tests.

Step 3, Integration and governance: deploy MLOps, a model registry, backtesting and drift monitoring. Set up API/webhooks, integrate case management, SIEM and sanctions providers, and agree SLAs. Prepare regulatory documentation: model cards, XAI reports, escalation procedures and a decision log.

Step 4, Scaling and monitoring: start continuous training and regular threshold reviews, optimize triage and load distribution. Expand coverage to new products/countries with local adaptations and transfer learning. Conduct quarterly audit sessions with ROI/TCO analysis and playbook updates.

Conclusions for the business owner and C-level executives

  • AI and AML deliver the greatest effect in reducing false positives and accelerating investigations, but require high-quality data and clear KPIs.
  • Hybrid rule+ML solutions are the optimal start: they quickly improve metrics while preserving manageability and explainability.
  • Graph analysis and NLP for adverse media: two ‘multipliers’ of ROI in international networks and multilingual environments.
  • Model governance and XAI are not options but prerequisites for regulatory resilience and the trust of banks/partners.
  • Privacy-preserving ML helps overcome localization barriers and cross-border restrictions without sacrificing quality.
  • A realistic payback period is 9–12 months when focusing on triage and noise reduction, given mature DataOps.
  • Start with a PoC and a clear baseline; otherwise it’s impossible to prove the effect and protect the investment.
  • Team and processes are more important than the tool: human-in-the-loop, regular audits and metric discipline determine the outcome.

A recommended table for evaluating vendors and PoC includes columns: functional coverage, explainability/XAI, integrations, SLA, security/localization, TCO, pilot results by metrics. Such a matrix speeds up decision-making and makes dialogue with regulators more substantive.

How to write a conclusion and CTA

Artificial intelligence enhances AML-monitoring, turning it from a cost center into a manageable framework for reducing risk and accelerating the business. Success depends on data quality, well-thought-out governance, XAI reporting and careful integration into existing processes.

If you are planning international expansion or see an increasing compliance workload, start with a readiness audit and a PoC checklist. Upon request we will provide templates: an RFP for vendor selection, a supplier comparison matrix, a PoC metrics matrix, and an ROI/TCO calculator.

Contact our COREDO team to plan a phased implementation and turn AML-automation into a strategic advantage.

Real-time banking transaction checks have ceased to be a “regulator’s last-mile requirement” and have become an element of business strategy. When a system promptly detects anomalies, stops a fraud attempt, and automatically generates reports, a company not only complies with regulations — it saves time, retains customers, and reduces operating expenses.

The COREDO team has carried out dozens of projects in the EU, the UK, Singapore and Dubai, from company incorporations and licensing to launching real AML processes and integrating transaction monitoring into payment infrastructure. In this article I examine in detail how real-time transaction monitoring works, which regulatory expectations currently dominate, and which solutions work in practice. I will show case studies, performance metrics, approaches to reducing false positives, and highlight the questions you should ask technology providers.

Why businesses need transaction monitoring

Illustration for the section «Why businesses need transaction monitoring» in the article «Real-time bank transaction checks - what's monitored»
transaction monitoring in real time, it’s not just about AML. Real-time fraud detection protects revenue, and compliance monitoring of payments reduces the risk of fines and blocking by correspondent banks. Under PSD2 and open banking the customer expects instant transaction approval, and the bank expects explainability and auditability of decisions. Without real-time AML systems a company loses speed and flexibility, and the risk of undetected schemes increases.

Our experience at COREDO has shown that launching transaction monitoring for business pays off faster if you combine AML, fraud detection and sanctions screening of payments into a single streaming architecture. This simplifies maintenance of the rules and triggers for transaction monitoring, enables sharing scoring features between teams and consistently assessing ROI.

What is monitored when checking transactions?

Illustration for the section «What is monitored when checking transactions» in the article «Real-time bank transaction checks - what is monitored»

What is monitored when checking transactions is not abstract bureaucracy, but a set of concrete indicators that bank specialists pay attention to. In the following subsections we will examine in detail the parameters banks monitor when analyzing operations: from client profiles to atypical payment patterns.

Which parameters do banks monitor?

When it comes to what is monitored during transaction screening, banks assess the amount, currency, direction, instrument type, channels and devices. Parameters include the customer’s behavioral profile, transaction history, frequency and counterparty, as well as the presence of anomalies in the volume, frequency and direction of transfers.

Temporal payment patterns

Time windows and event deduplication make it possible to find spikes of activity related to smurfing and payment structuring, as well as detect attempts to bypass limits. Payment geography reflects country risks and triggers for areas of increased attention (including offshore destinations and high-risk jurisdictions).

Sanctions screening of payments and PEPs

Sanctions screening of payments is based on matching against the sanctions lists of OFAC, the UN and the EU, as well as local regulators’ lists. SWIFT screening and sanctions checks of correspondent banks are important for international transfers, especially when operating through the correspondent account network.

Monitoring transaction chains and TBML

Analysis of transaction chains and graph analysis reveal complex schemes, including trade-based money laundering (TBML). Clustering transactions to identify schemes and graph analysis of transfer chains help reveal “bridges” between groups of companies and shadow counterparties.

Requirements in the EU, the UK and Asia

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In different jurisdictions — the EU, the UK and Asia — regulatory requirements set the compliance framework for financial and crypto-asset services. Below we examine in detail the key international standards and European rules, including the recommendations of FATF, the AMLD5/AMLD6 directives and EBA guidance.

FATF and EBA recommendations on AMLD5/AMLD6

The FATF legal standard sets the foundation: a risk-based approach, continuous monitoring, data governance and independent assessment. In the EU, the AMLD5 and AMLD6 directives have strengthened requirements for UBO identification, internal controls and liability for facilitating money laundering.

PSD2 and open banking: monitoring

The impact of PSD2 and open banking on monitoring is expressed in expanded access to transaction data and the requirement for secure authentication. Payment service providers (PSPs) build integrations with open APIs and are simultaneously obliged to ensure control over chains of related transactions.

GDPR, privacy-preserving analytics and eIDAS

Data privacy and the GDPR in transactions require a lawful basis for processing, data minimization and pseudonymization. Privacy-preserving analytics and pseudonymization allow working with behavioral patterns without revealing unnecessary personal data.

FCA and sanctions lists

The FCA and regulatory expectations on AML in the UK emphasize the importance of model explainability and the reliability of sanctions screening. Banks and PSPs are required to match sanctions lists and PEPs in real time, taking into account fuzzy matching and the counterparty’s context.

How to build a real-time AML system

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The architecture of real-time AML requires measured approaches to data processing if you want to actually build a system without headaches and ensure stable operation as volumes grow. The choice between batch and stream comes down to a trade-off between latency and throughput.

Batch vs Stream: latency and throughput

The batch approach is suitable for retrospective analytics and periodic analysis, but it does not catch instantaneous risks. The stream approach provides minimal latency and high throughput, which is critical for merchant flows, payroll, and instant payments.

Stream processing: Kafka, Flink, Storm

Tools for real-time transaction monitoring typically include Apache Kafka as an event bus and Flink or Storm for computations. Such a stack supports complex time windows, aggregates, deduplication, and stateful processing for transaction scoring.

Integration of Core Banking and PSP Enrichment

API integration with Core Banking and PSP allows pulling transactions, sessions, KYC/CDD data, and authorization context. Data enrichment — geolocation, BIN, AML watchlists, corporate directories, sanctions lists — improves scoring quality.

Scaling for peak loads

Scaling for peak loads, for example during holiday payrolls or sales, requires elasticity and prioritization. Flow control in multi-currency and cross-border payments takes into account FX volatility and correspondent account limits.

On-prem vs cloud: SIEM log storage

On-prem solutions increase control and are suitable for banks with strict regulations on log retention in the EU and Asia. Cloud speeds up deployment and reduces CAPEX, but requires clear data boundaries and encryption.

Monitoring triggers: database and context

Illustration for the section “Monitoring triggers: database and context” in the article “Bank real-time transaction checks - what is monitored”
Effective monitoring begins with clear rules and properly configured triggers that translate raw data from the database into actionable insights. Next, we’ll examine how rule-based scenarios and contextual rules use information from the database.

Rule-based scenarios and contextual rules

Scenarios for AML automation (rule-based) include threshold amounts, frequency, country-risk lists and merchant blacklists. Contextual rules for AML add a “healthy” behavioral baseline and customer links: usual IP addresses, devices, counterparty types and time windows.

Bank limits and limit checks

Bank limits and limit checks cover monitoring of large transfers, daily and monthly volumes, and group limits across related accounts. How do banks identify transaction anomalies? They combine limits with behavioral profiling and build score functions and threshold tuning to reduce false positives without losing sensitivity.

Onboarding and KYC/CIP/EDD

KYC and transaction monitoring are closely linked: quality onboarding and EDD for high risk set the correct “baseline”. Creating a profile of a customer’s normal activity reduces false positives and speeds up investigations.

How to manage false positives and KPIs

Practices for reducing false positives include customer segmentation, contextual features, adaptive windows and feedback from analysts. Performance metrics for AML systems — precision, recall and false positive rate — help balance sensitivity and accuracy.

Hybrid machine learning approaches

Machine learning helps reveal hidden patterns in large volumes of data, and hybrid approaches allow combining expert rules with models for greater robustness and explainability. Below we consider how these methods are used for anomaly detection and behavioral monitoring.

Machine learning for anomaly detection and monitoring

Machine learning for transaction anomaly detection adds depth on top of rules. Behavioral monitoring of customers’ transactions uses clustering, graph features and gradient boosting for complex patterns.

Explainability and regulatory requirements

Explainability of ML models in AML and regulatory requirements prescribe understandable reasons for each alert and auditing and traceability of ML decisions. Case management systems for investigations should store the model version, the feature set and escalation steps.

Privacy and risks of third-party models

What are the risks when using third-party ML models for AML? Loss of control over data, inattention to local regulatory nuances and difficulty validating quality. Privacy-preserving analytics and pseudonymization, as well as a clear GDPR lawful basis for transaction monitoring, reduce these risks and simplify certification.

COREDO Case Studies: the Path to AML Monitoring

COREDO case studies demonstrate the path from obtaining a license to real implementations of an operational AML monitoring system in financial market products. Using the example of a PSP in the EU, we show how the licensing stage smoothly evolves into building a real-time platform and an operating system for AML.

PSP in the EU: from licensing to real-time

In Estonia, the COREDO team assisted a PSP in obtaining a license and implementing real-time AML. We integrated Kafka and Flink, configured SWIFT screening, the OFAC/UN/EU sanctions lists, and contextual rules for the merchant flow.

Fintech and Open Banking in the UK

In a project supervised by the FCA, we helped agree on model explainability, built API integration with open banking, and added monitoring of chains of related transactions. Chain and graph analysis uncovered a scheme to extract funds through a series of low-volume transfers to new wallets.

Payment Company in Singapore and Dubai

In Singapore and Dubai, COREDO built payment compliance monitoring with a focus on cross-border and multi-currency flows. We applied hybrid scoring, enriched data with geolocation, and implemented TBML controls based on documentary inconsistencies.

Mass Merchant Transactions

For a large merchant in the EU, the COREDO team implemented rules for checking international transfers and screening of PEPs and corporate beneficiaries. We set up transaction graph visualization tools, which allowed the detection of fake counterparties and shell companies in the supply chain.

Performance metrics: cost and ROI

Assessment of implementation cost, projected ROI and a set of key performance metrics — essential elements when planning digital projects in a bank. Below we will examine in detail what makes up the budget for an average bank.

Implementation cost for an average bank

How much does it cost to implement a real-time transaction monitoring system for an average bank? In our experience, TCO over 12–18 months ranges from 0.9 to 2.5 million euros, including licenses, implementation, integrations and team training.

Accuracy and speed metrics

Which metrics demonstrate ROI from real-time monitoring? Reduction in false positive rate, increase in precision/recall, average time to investigate (MTTR), share of automated SARs, proportion of fraud losses prevented and cost per case.

ROI: where the business value comes from

The ROI of transaction monitoring systems consists of reduced fines for non-compliance, prevented fraud and lower investigation costs. Data license costs are recouped when the practice of reducing false positives cuts manual work and increases analyst productivity.

Questions for vendors regarding the SLA

SLA templates for real-time monitoring include latency to decision, platform availability, recovery time, RPO/RTO, guarantee of logging and log retention. Questions for AML solution vendors during selection: explainability, rule version control, retro-simulations, training data and others.

Preparing your business for bank monitoring

Businesses should prepare in advance: bank monitoring implies transparent reporting, proof of sources of funds and tidy registration documentation. Below are practical steps for opening an account and registering in the EU.

How to open an account in the EU and register

Monitoring for the registration of legal entities in the EU is not a formality but a real criterion for bank onboarding. How to prepare a company for banks’ AML checks before opening an account?

Policies, playbooks and reporting

Incident management and playbooks for AML operations should describe escalations, priorities, actions for mass payments and payroll, as well as rules for operating on weekends and holidays.

Validation and log storage

End-to-end data validation and reconciliation eliminate discrepancies between transactions and balances and increase confidence in alerts. Log retention policies in the EU and Asia specify retention periods and requirements for protection and access.

What do banks expect from licenses?

When obtaining financial licenses (crypto, forex, payment services) regulators evaluate not only policy but also operating processes: KYC/CIP/EDD, sanctions screening, international transfer controls and false positive management.

International transfers

Rules for reviewing international transfers require controls over correspondent banks, SWIFT screening and assessment of chains of related transactions. Monitoring cash flows between related companies prevents artificial fragmentation of volumes and circumvention of limits.

How to choose a provider and tooling

The right tooling when selecting a provider defines what analytical and operational tasks can be solved quickly and reliably. This is especially important for graph visualization capabilities.

Graph visualization and AML-as-a-Service

Transactional graph visualization tools speed up the analysis of suspicious transactions and explain scenarios to the regulator. Using external AML-as-a-Service providers helps you get started quickly, but it’s important to assess explainability and quality control.

Questions for providers on SLA and GDPR

Check how the provider ensures GDPR: lawful basis, minimization, pseudonymization, and storage in the EU. Ask about the scalability of real-time monitoring, especially as international flows grow, and about SLA patterns for peak loads.

Reducing investigation costs

How to reduce operational costs for AML investigations? Adopt lean investigation and triage models, automate enrichment, use prioritization by risk score, implement case templates and active feedback training.

Strategic partnership with COREDO

When a business prepares for international expansion, company registration and Licensing: only the first chapter. Real transaction monitoring becomes the operational backbone that supports risk management, the trust of partner banks, and stable unit economics. If you combine rules and ML, build a transparent data architecture and explainable models, the system not only meets AML standards – it helps the business grow.

COREDO combines legal and financial expertise with strong engineering practice. We support registration in the EU, the United Kingdom, the Czech Republic, Slovakia, Cyprus, Estonia, Singapore, and Dubai, help obtain licenses and launch compliance processes that withstand scrutiny from regulators and banks. If you are building an international payments business or scaling corporate payments, the COREDO team prepares a roadmap, implements real-time monitoring and configures metrics that show real ROI.

I often hear the question: how to build a legal model that truly works across different jurisdictions, rather than just existing on paper?
Over the years at COREDO I am convinced, that a strong legal model for a company is not a static set of policies and regulations, but a living corporate governance mechanism that links strategy, Licensing, AML processes, data governance and operational cycles. It reduces regulatory burden and cost of compliance, provides regulatory risk management and increases business predictability when scaling in Europe, Asia, the Middle East and the CIS.

The COREDO team has implemented dozens of projects to register legal entities in the EU, the Czech Republic, Slovakia, Cyprus, Estonia, the United Kingdom, Singapore and Dubai, and obtained financial licenses for crypto platforms, forex brokers and payment companies. Our experience at COREDO has shown that results are achieved not when another checklist is closed, but when the legal model and corporate governance are built as a single system of control and decision-making, supported by transparent ROI and TCO metrics and a methodology for evaluating control effectiveness.

What is a company’s legal model?

Illustration for the section 'What is a company's legal model?' in the article 'Legal model as a tool for managing regulatory risks'

By legal model I mean an integrated architecture of rules and processes that sets the logic of the corporate structure, allocation of roles and powers, the mechanism for managing beneficial ownership and UBO-transparency, as well as KYC/EDD, AML transaction monitoring and sanctions screening.

The legal model of corporate governance must take into account GDPR requirements, features of cross-border data transfers, local regulations, as well as regulatory expectations for reporting and transparency.

When the legal model and internal controls work in sync, the company obtains licenses faster and better withstands regulatory inspections.

For financial organizations I recommend considering the legal model and compliance management as part of GRC (governance, risk, compliance). This approach links the company’s risk appetite, key risk indicators (KRI), compliance key performance indicators (KPI) and testing & sampling procedures, so as not only to declare rules but also to prove their control effectiveness. COREDO’s practice confirms: where the legal model and regulatory risk management are integrated into the operational cycle, the likelihood of legal consequences of non-compliance with regulations and regulatory fines is reduced.

How to build a legal model

Illustration for the section 'How to build a legal model' in the article 'The legal model as a tool for managing regulatory risks'
We start every project with an analysis of the regulatory and legal environment and by creating a regulatory map of jurisdictions. At this stage a regulatory Due Diligence is carried out on licensing requirements and permitting documentation, criteria of international standards are compared (FATF recommendations on AML/CTF, EBA and EU regulatory requirements, Basel Committee recommendations for financial companies), sanctions regimes and rules of international cooperation are assessed. For companies with cross‑border operations this is the basis of an inter‑jurisdictional legal model.

At COREDO we use scenario-based stress testing of regulatory impact that takes into account changes in rules, shifts in law enforcement, and increased intensity of inspections during scaling.

At this stage it is important to define the risk appetite, carry out an analysis of residual risk after implementing controls and agree on monitoring metrics: KRI, KPI and alert handling indicators for transaction monitoring systems (TMS). The solution developed at COREDO allows to transparently link KYC procedures/EDD, sanctions screening of counterparties and beneficial owner (UBO) checks with the client profile and product type.

Once the concept is approved, we design built-in compliance (compliance by design).

This includes privacy by design, preparation of a protection impact assessment (DPIA) for significant data flows, settings for data governance, management of privacy policy and data localization requirements, as well as contract lifecycle management to minimize risks (CLM). Through CLM we record legally significant obligations, SLA for suppliers, mechanisms for managing contract risk and vendors, and a system of controlled documents and versions.

Implementation of the legal model: risks

Implementation always follows a roadmap. First we agree on the target corporate structure and ring‑fencing for company groups, to limit the transfer of risks between legal entities, determine centralization vs decentralization of legal functions, and the allocation of licenses and permits across the perimeter. Then we configure AML/KYC processes, TMS and CASE systems for investigations, RMS for risk metrics, register regulatory reporting and the SAR/STR report for suspicious transactions. I separately set out an incident response plan with escalation triggers, as well as a business continuity plan and regulatory compliance for critical services.

The main risks during implementation are underestimating data governance, outdated policies without regulatory monitoring, and weak change management (regulatory change management).

To mitigate them, the COREDO team establishes a process of continuous updating of regulatory maps, conducts staff training and develops a culture of compliance. This approach simplifies interaction with regulators and prepares the company for regulatory inspections without emergencies.

Metrics of ROI and TCO for the legal model

The key to management is measurability. I assess the total cost of ownership of the legal model through direct costs for licensing and maintenance, the cost of automation (CLM, RMS, CASE, TMS), and the cost of people and external advisers. ROI for compliance initiatives is calculated from reduced probability/regulatory expected loss (the probability of an incident multiplied by the expected damage), time savings on KYC/AML and reduction of cost leakage in accounts payable and suppliers thanks to CLM.

We use metrics: average KYC/EDD time per client, share of false-positive alerts in TMS, level of control effectiveness by testing & sampling, share of regulatory findings closed on time, frequency of updating controlled documents and versioning systems.

This method of calculating the economic effect of the legal model makes it possible to manage regulatory burden and make investment decisions about automation.

Regional Accents: Europe, Asia, CIS

Illustration for the section «Regional Accents: Europe, Asia, CIS» in the article «The legal model as a tool for managing regulatory risks»

Regional emphases in legal regulation vary significantly: Europe, Asia, the Middle East and the CIS countries apply different approaches to corporate law, taxation and data protection.

In the following sections we will examine practical legal models and requirements for businesses in each of these regions, starting with Europe.

The legal model of business in Europe

European projects often rely on the GDPR, EBA requirements and local regulators. For payment organizations we build the legal model when registering legal entities in the EU taking into account PSD2 rules, access to payment infrastructure and risk management requirements. In Cyprus I recommend aligning the corporate structure with CIF licensing for forex brokers, and in Estonia: considering the updated rules for virtual asset providers and the upcoming harmonization with the MiCA framework. COREDO’s practice confirms: when the legal model and Financial services licensing are designed simultaneously, time to market is noticeably reduced.

The legal model and GDPR requirements are a separate block. We work out the legal bases for processing, DPIAs for high-risk processes, mechanisms for cross-border data transfer and localization, and also model interaction with subprocessors.

This reduces the risk of penalties for privacy breaches and simplifies regulatory inspections.

Legal model for entering Asian markets

In Singapore we take into account MAS expectations regarding AML/CTF and governance for fintech players, as well as requirements for managing technology risks. The legal model for a startup in the Asian market is built as a flexible legal model for a fast-growing business: emphasis on scalable KYC/EDD, outsourcing part of legal ops and regulatory sandboxes (regulatory sandbox) for testing new products. In Dubai we align the framework with VARA practice and free zone rules, plan sanctions screening of counterparties and beneficial ownership transparency. Such a design facilitates cross-border operations and preparation for international compliance audits.

Cross-jurisdictional legal model

Cross-border schemes require a legal model for transnational activity taking into account dual licensing requirements, tax and regulatory efficiency, as well as reporting requirements in different jurisdictions.

At COREDO we design the corporate structure and ring-fencing to separate risky assets, manage reputational risks and build scenarios for scaling business in Africa through partnership models. The legal model and protection against sanctions risks include UBO transparency, sanctions filters, contract adaptation and regulatory resilience stress tests.

Licensing and built-in compliance

Illustration for the section «Licensing and built-in compliance» in the article «The legal model as an instrument for managing regulatory risks»
Licensing is not a checklist, but a test of the viability of the legal model and internal control. We have supported licenses for crypto services, payment companies, forex providers and specialized financial firms in several jurisdictions. The solution developed at COREDO links licensing and permit documentation with AML processes, transaction monitoring systems (TMS) and the SAR protocol to meet regulators’ expectations and operational realities.

I rely on international standards: recommendations FATF for AML/CTF, EBA for risk management in the EU and Basel Committee recommendations for financial firms on capital and operational risks.

This creates a common language with the regulator and facilitates compliance audit support. For innovative models we use a regulatory sandbox and a phased rollout, where the legal model and automation of legal processes (CLM, RMS, CASE) are tested on a limited volume of operations.

AML in the legal model

Illustration for the section «AML in the legal model» in the article «The legal model as a tool for managing regulatory risks»
AML‑services are not only KYC/EDD, but a blend of risk assessment, monitoring and culture. We build KYC processes on a risk‑oriented principle, configure EDD for countries/segments of elevated risk, implement sanctions screening of counterparties and UBO checks. AML transaction monitoring should be proportionate to risk and support effective alert handling. At COREDO we apply automation and AI tools to manage regulatory risks: behavioral analytics, alert prioritization, case management and quality control of investigations.

It is important to maintain anti‑corruption policies and procedures, integrating them into staff training and compliance culture. We carry out testing & sampling methodologies, assess the effectiveness of controls, form KRI at the process and team levels, and also build the process for managing regulatory changes. This reduces residual risk and strengthens trust from partner banks and investors.

Data governance and GDPR by design

The legal model and the GDPR converge at the point of privacy by design.

I view data governance as a system: a registry of processing activities, data owner roles, sensitivity classification, retention rules, cross-border transfers and DPIA. For the EU and the United Kingdom, mechanisms for international data exchange are critical, taking into account local requirements and contractual safeguards. We document regulatory requirements for reporting and transparency to easily pass audits and respond to supervisory authority requests.

In projects with an Asian and Middle Eastern perimeter we take localization requirements and the specifics of consent into account, and build contract lifecycle management to ensure supplier and contractor compliance. This approach makes the legal model a tool of corporate control rather than a formality.

Legal operations and automation

Automating the legal function is not an end in itself but a way to reduce TCO and increase the scalability of the legal model. I use CLM to manage the contract lifecycle and obligations, RMS for risk assessment and KRI/KPI, CASE for investigations and regulatory requests, and TMS for transactions. Legaltech solutions for regulatory monitoring fill the gap in regulatory change management and prevent policies from falling behind reality.

An important element is centralization vs decentralization of legal functions.

In corporate groups we often choose a hybrid: a centralized methodological framework, unified document standards and a versioning system, while local legal entities are responsible for regulatory practice. COREDO helps establish outsourcing of legal functions (legal ops outsourcing) where it accelerates launch and preserves control.

Company structure and reputational risks

The legal model for a group of companies must take into account the management of beneficial ownership, UBO transparency, delegation of authority and independence of control. We design ring‑fencing so that a high‑risk element does not “infect” the entire group, and we establish rules for information barriers. The legal model and reputational risk management include a matrix of crisis scenarios and a response plan, a mechanism for reporting via SAR in suspicious situations, as well as procedures for interaction with auditors and regulators.

The role of the legal model in compliance with regulations manifests through regular self‑assessment, testing & sampling, independent verification of control effectiveness and updating the regulatory map.

This regime maintains the trust of banks, payment partners and clients.

Inspections and interaction with regulators

I always operate under the principle of “no surprises”. Engagement with regulators begins long before a request: we transparently maintain records and manage licenses and permits, prepare reports, keep change logs for policies and procedures, and also training logs. When preparing for an inspection we assemble an evidence package: from KYC/EDD records and CASE investigations to TMS logs and DPIA registries. The COREDO team supports communications, helps disclose information correctly, and close findings on time.

We use scenario stress-testing of regulatory resilience to identify weaknesses in advance.

This reduces the likelihood of escalation and maintains predictability in dialogue with regulators.

M&A: Migration and Integration of the Legal Model

M&A deals pose a complex challenge: migrating the legal model during M&A and integrating the legal model after the deal. I recommend starting with mapping GRC frameworks and licenses, reviewing contracts in CLM, aligning AML/CTF policies and data governance. Often it is necessary to transfer licenses, agree on new UBO structures and update TMS/CASE settings. COREDO’s experience shows that early planning reduces the risk of operational stoppages and accelerates synergies.

Implementation Plan

I build an implementation roadmap for a legal model using a clear logic. First, regulatory due diligence and an analysis of the legal and regulatory environment are carried out, a regulatory map of jurisdictions is compiled, and a target legal model for business in Europe, Asia and the CIS is developed.
Then regulatory risk modeling and residual risk assessment follow, KRI/KPI are set up and automation tools are selected: CLM for contracts, RMS for risks, CASE for investigations, TMS for transactions.

At the same time, privacy by design and a DPIA are developed, and data governance is configured.

Next, we move the model into the operational environment: we document internal controls, standard policies, a document versioning system, an incident response plan and a business continuity plan. At the launch stage we organize staff training and foster a compliance culture, implement regulatory monitoring and change management, and prepare for interaction with regulators and compliance audits. This approach reduces the total cost of ownership of the legal model and ensures its scalability.

COREDO case studies: legal model

First case – a group of payment companies headquartered in Cyprus with operations in the EU and the UK. The COREDO team built the legal model and financial services licensing as part of a CIF and European authorisations, designed ring‑fencing between processing and marketing, implemented CLM and RMS, and also a TMS with alert prioritisation. Performance assessment showed a 37% reduction in false positives and a 28% reduction in KYC time, which directly increased the ROI of compliance initiatives.

Second case, a crypto provider registered in Estonia and expanding to Dubai. The solution developed by COREDO combined the legal model and AML services: revision of EDD procedures, sanctions filters, CASE for investigations and regulatory sandboxes for testing a new product. We synchronised VARA requirements with the European framework and prepared the company for future MiCA regulations. As a result, the business safely expanded cross‑border operations and accelerated listing with payment partners.

Third case – a fintech from Singapore planning to scale in Africa through partnerships. We built an interjurisdictional legal model taking into account local KYC practices, requirements for data governance and cross-border data transfer, added privacy by design and DPIA, as well as regulatory change management. COREDO’s practice confirmed that a flexible legal model for a fast-growing business reduces legal and reputational risks and accelerates entry into new markets.

Innovation in the legal model

I actively use legaltech for monitoring regulations and automating processes.

Contract lifecycle management reduces the likelihood of missing obligations, RMS manages the risk portfolio and metrics, CASE ensures manageability of investigations and interaction with regulators, and TMS, adaptive AML monitoring. We use blockchain and smart contracts in the legal model where it increases transparency, and we are testing the use of AI for managing regulatory risks — from alert classification to contract analysis.

An important requirement is manageability of changes. Regulatory monitoring and change management (regulatory change management) are integrated into daily work: controlled documents and versioning system, revision schedule, allocation of responsibilities and staff training. This reduces ‘regulatory debt’ and helps avoid accumulation of vulnerabilities.

Legal model: an instrument of control

The legal model as a tool of corporate control provides manageability and predictability.

It simplifies licensing, reduces the cost of compliance through automation and proper allocation of functions, enables building regulatory scenarios and making decisions faster. At COREDO I strive to ensure that the legal model and the use of legaltech are not a barrier, but a foundation for growth: from cross‑border operations to post‑M&A integration.

A strong model is built on honesty and realism. I openly discuss difficult areas: sanctions risks, reporting requirements, SAR‑obligations and regulatory inspections: and I propose practical measures: ring‑fencing, DPIA, KRI/KPI, testing & sampling and transparent communication with the regulator.

This approach builds trust and confirms the authority of our team in the eyes of regulators and partners.

Conclusions

Over ten years I have become convinced: the legal model is a strategic asset that determines the pace and scale of companies’ growth in the international environment.

When the legal model and regulatory risk management are built as a single compliance framework, business obtains licenses faster, complies with requirements more cheaply, and scales more confidently in Europe, Asia, the Middle East and the CIS.

At COREDO we turn complexity into clarity: we design cross-jurisdictional models, implement automation, set up AML/CTF, data governance and change management so that every control point adds value.

If you are planning the registration of legal entities in the EU, expansion into Asian markets, financial services licensing or post-deal integration, rely on the legal model as the architecture of growth. The COREDO team is ready to discuss your project and offer a practical plan: from a regulatory map to the launch of processes and performance metrics. I believe in remote partnership, where expertise, experience and reliability will turn regulators’ requirements into your competitive advantage.

I have been building COREDO since 2016 and have seen how international acquiring has transformed from an auxiliary function into a strategic asset. Properly structured payments drive higher conversion, reduce total cost of ownership, lower fraud risks and accelerate expansion into new markets. The COREDO team has implemented dozens of projects in the EU, the UK, Singapore, Dubai, the Czech Republic, Slovakia, Estonia and Cyprus; COREDO’s experience confirms: successful international projects rely on precise legal architecture, a mature AML/KYC process and an engineering approach to payment routing.

In this article I have compiled practical strategies that we regularly implement. The text is intended as a practical map: from choosing a provider and a legal model to improving approval rate and managing chargebacks. I draw on industry standards (PSD2, SCA, EMV 3‑D Secure, PCI DSS, GDPR), as well as on the comprehensive support experience COREDO has provided to companies across industries: from subscriptions and digital to marketplaces and fintech.

Architecture of International Acquiring

Illustration for the section «Architecture of International Acquiring» in the article «Acquiring for International Projects - How to Reduce the Risk of Declines»
First, about the foundation. International acquiring is not a single contract, but a bundle of legal, technical and financial solutions. I suggest looking at the architecture through four layers: the merchant role, the connection model, transaction economics and routing.

  • Merchant role. Options are merchant of record (MoR) and an in-house merchant model. MoR takes on billing, taxes and risk, accelerating launch but increasing MDR and reducing flexibility. An in-house model gives control over pricing, settlement and data, but requires mature AML/KYC and PCI DSS compliance.
  • Connection model. Comparing PSP and bank acquiring shows: PSP is faster to integrate, provides payment orchestration, smart routing and fallback providers, as well as a payment gateway in one window. Bank acquiring offers direct rates and tight underwriting ties, but will require additional integration and self-orchestration.
  • Roles and scaling. PayFac (payment facilitator) speeds up onboarding of sub-merchants and suits marketplaces; an ISO aggregator builds a portfolio on relationships with acquirers. BIN sponsoring and multi-BIN strategies open the way to local schemes and increase approval rates of international payments through local-present routes.
  • Transaction economics. Merchant discount rate (MDR) consists of interchange, scheme fees and the provider’s margin. Interchange-plus vs blended pricing is an important choice: interchange-plus is transparent for optimization, blended is convenient at the start. Interchange optimization and managing MCC and business categorization reduce fees. MCC downgrades increase costs; I recommend keeping an up-to-date MCC profile and monitoring downgrades.
The cost of acquiring in international projects depends on on-us vs off-us logic, acquirer’s locality, vertical risk, rolling reserves and settlement timing. The COREDO team deployed a model with net settlement and batch processing, and then migrated to real-time settlement for a high-turnover marketplace — we aligned authorization and finance through smart routing and settlement optimization.

PSD2, SCA, PCI DSS and GDPR: compliance

Illustration for the section «PSD2, SCA, PCI DSS and GDPR: compliance» in the article «Acquiring for international projects - how to reduce the risk of decline»

The impact of PSD2 on international acquiring is most noticeable through SCA and ecommerce exemptions. 3-D Secure 2.0 and decline reduction go hand in hand with the liability shift under EMV 3-D Secure, while a frictionless flow is more important for conversion. I apply dynamic 3DS: low-risk transactions proceed without friction, while high-risk ones require a challenge. Trusted beneficiary, transaction risk analysis (TRA), low-value, corporate and recurring exemptions, when configured correctly, provide a steady increase in the approval rate.
Compliance and regulatory requirements GDPR and PCI DSS determine data processing and the level of integration. PCI SAQ and SDK integration requirements depend on the type of checkout: gateway hosted page vs embedded checkout. A hosted page simplifies PCI obligations, while embedded requires enhanced measures (token vault, encryption, segregated environments). GDPR’s impact on the processing of payment data requires justification of all data flows and transparency of consent.

AML and KYC when connecting acquiring services abroad are the point where projects most often lose momentum. Best practice for merchant onboarding for international clients includes a KYB checklist, emphasis on UBO, source of funds, turnover benchmarking, merchant risk scoring and portfolio segmentation. Sanctions screening and PEP checks during onboarding are supplemented by managed escalation on sanctions hits, and enhanced Due Diligence (EDD) for high-risk merchants structures elevated checks.

Reducing Declines and Increasing Approval Rates

Illustration for the section ‚Reducing Declines and Increasing Approval Rate‘ in the article ‚Acquiring for International Projects - How to Reduce Decline Risk‘
I set acquiring KPIs – approval rate, decline rate, chargeback ratio – at the P&L level. Improving the approval rate of international payments begins with correctly interpreting issuer response codes. We separate soft-decline codes and retry authorization tactics from hard-decline reasons and escalation methods: the former are handled via retry logic for soft declines with a backoff strategy and soft-decline retry windows, the latter are sent to an alternative rail or we request a different payment method.

Payment routing optimization (smart routing) provides the fastest uplift. We apply:

  • bin-based routing and fallback algorithms tailored to specific issuers;
  • time-of-day and geo-based routing rules for regional peaks;
  • split routing and fallback providers to maintain uptime;
  • working with local acquirers in Asia and Europe for local presentment and to reduce cross-border frictions.
Payment orchestration platforms and their role here cannot be overstated: they speed up A/B testing of the checkout flow and measurement of lift, provide flexible decision trees and real-time decisioning. Our experience at COREDO has shown that authorization rate uplift and measurement methods via controlled experiments, plus issuer-specific logic, deliver a stable 2–4 percentage points of growth without compromising security.

DS 2.0: tokenization and security

Illustration for the section «DS 2.0: tokenization and security» in the article «Acquiring for international projects - how to reduce the risk of decline»

Tokenization and payment security are the foundation of CNP. Token vault and management of stored credentials are important for subscriptions and repeat payments. Stored credential compliance and card scheme rules require an initial CIT with SCA and subsequent MITs with correct indicators. Using tokens and stored credentials for subscriptions increases conversion and reduces the risk of leaks.
3-D Secure 2.0 and reduction of declines are achieved through dynamic 3DS and frictionless flow. Liability shift protects the merchant in disputed transactions. At the same time it is important to configure SCA and exemptions for ecommerce and to consider the trusted beneficiary. Device fingerprinting and behavioral biometrics together with the device trust score set individual risk thresholds; at the same time device fingerprint persistence and privacy restrictions in the EU require a delicate implementation within the framework of GDPR.

I am not a supporter of excessive friction. Bot mitigation techniques and the CAPTCHA trade-off should be applied selectively, relying on behavioral analytics and velocity checks. The right balance reduces false declines without loss of security, and fraud rules and white/black lists for merchants speed up decision-making for legitimate customers.

Fraud, chargebacks, and dispute representment

Illustration for the section “Fraud, chargeback and dispute representment” in the article “Acquiring for international projects - how to reduce the risk of declines”

Tools for reducing fraud risks in international payments are built on rule-based and ML approaches. Fraud scoring models: rule-based vs ML complement each other. Ensemble models combined with real-time transaction monitoring rules provide consistent filtering and speed. Velocity profile analysis and anomalous activity help catch BIN attacks and card scanning before they translate into chargebacks.

Managing chargebacks and dispute representment is a discipline with clear SLAs. I highlight:

  • chargeback threshold monitoring and SLAs for incidents;
  • representment process and documentation (invoices, T&Cs, proof of delivery, 3DS data, customer communications);
  • representment win rate and optimization of cases by reason (fraud, not as described, processing errors);
  • chargeback prevention services and third-party vendors with integration into orchestration.
Authorization hold and capture windows affect cash flow gaps and disputes. Rolling reserve and funds retention terms should be agreed taking into account the vertical and historical metrics. An incident response playbook for mass failures (incident response): isolation of the problematic provider, forced fallback, communication with issuer relations, and targeted changes to risk rules — I recommend keeping such a plan up to date.

From KPIs to cash in the account

Consolidation of reconciliations and settlement optimization save time and money. Reconciliation automation and webhook integrations close gaps between authorization, capture, refund, and chargeback. Reconciliation exceptions and matching rules are needed for non-standard scenarios, including partial refunds and multi-capture.

Settlement timing and net settlement models determine liquidity; batch processing vs real-time settlement – a choice between predictability and speed. Currency issues and FX margin in cross-border acquiring require transparency: FX markup and dynamic pricing are better fixed in the SLA; cross-border tax and VAT implications should be addressed in the legal framework. Managing reconciliation of multi-currency settlements and authorization rate uplift should be done from a single panel, to calculate ROI metrics in decline-reduction projects and to see acquirer fees breakdown and optimization opportunities.

Approval rate benchmarking by industry helps set realistic targets, while portfolio management and merchant risk segmentation show where to expect quick wins. The COREDO team developed reporting templates in which acquiring KPIs: approval rate, decline rate, chargeback ratio, representment win rate, and dispute SLAs are collected automatically. This reduces manual errors and speeds up decision-making.

Merchant acquiring for legal entities: onboarding

The best practice for merchant onboarding for international clients is speed without compromises in AML/KYC. Merchant onboarding KYC/KYB checklist includes corporate documents, beneficial owners, business model rationale, sources of funds, sanctions policy, user geography and turnover forecasts. Acquirer underwriting and turnover requirements matter up front: I recommend preparing the sales pipeline and approval rate data from pilot markets.

Sanctions screening and managed escalation on hits reduce delays. EDD for high-risk merchants structures additional requests, and merchant risk scoring and portfolio segmentation help explain internal control to the regulator and the bank. Legal entity structuring for cross-border sales sets up MoR/own-merchant roles, taxation (including VAT in the EU) and allocation of risks between legal entities.

BIN sponsoring and multi-bin strategies are useful when a local footprint is needed for specific countries. Managing MCC and business categorization is critical at the application stage: the correct MCC reduces interchange and lowers the risk of downgrades. The COREDO team structured such setups in the EU and Asia, building ISO aggregator relationships with acquirers when a direct contract was economically suboptimal at launch.

How to evaluate a provider and an architecture

How to choose a payment provider for an international project? I look at seven parameters:

  1. Approval rate for target BINs/markets and analysis of issuer response codes.
  2. Capabilities: smart routing, split routing, bin-based routing and fallback providers.
  3. Roles: PSP vs bank acquiring; presence of PayFac, ISO aggregator, BIN sponsoring.
  4. Settlement modes: batch vs real-time, net settlement, payout speed.
  5. Compliance: PCI DSS level, PCI SAQ options, GDPR compliance, sanctions screening.
  6. Acquiring costs and MDR calculation: interchange plus vs blended, acquirer fees breakdown, FX markup, rolling reserve.
  7. Roadmap: payment orchestration platforms, open banking and alternatives to card payments (for example, SEPA Instant in Europe).
The role of payment gateways in reducing declines lies in stable integration (ISO 8583 and modern messaging formats), advanced routing and analytics. Gateway hosted page vs embedded checkout affects UX and PCI. Assessment of the acquiring bank’s reliability for international settlements includes uptime, quality of connectivity with issuers, time-to-approve changes in risk rules and support for merchant support SLA and dispute timelines.

COREDO Cases: what works

Case 1. Subscription service in the EU with stored credentials. Initial approval rate: 78%. The solution developed at COREDO included dynamic 3DS, stored credential compliance, bin-based routing and retry logic for soft declines. Authorization rate uplift was 6.2 percentage points, we kept the chargeback ratio below 0.5%, and the representment win rate rose to 72% thanks to standardized document templates and improved customer communication.
Case 2. Digital content marketplace in Asia. Problem — fraud spikes and BIN attacks. We implemented ensemble models with real-time decisioning, velocity checks, behavioral analytics, device fingerprinting and geo-based routing. The fraud-mitigation tools for international payments reduced the false positive vs false negative imbalance, the approval rate increased by 3.5 percentage points, and hard-decline reasons shifted toward alternative payment paths (including local methods and open banking).

Case 3. B2B SaaS with multi-currency billing in the UK and Singapore. Pain points — reconciliation and FX. We set up reconciliation automation and webhook integrations, consolidation, settlement optimization and matching rules for partial refunds. Currency issues and FX margin in cross-border acquiring became transparent, and we implemented a hybrid of batch processing vs real-time settlement: instant settlement for key clients and batches for the long tail. This sped up cash visibility and increased ROI in projects to reduce declines.

Launch and scaling plan

I propose a step-by-step plan of action:

  • Diagnosis. Analysis of issuer response codes, segmentation by BIN/countries, benchmarking, acquiring KPIs and portfolio risk profile.
  • Architecture. Selection of PSP and/or bank acquiring, payment orchestration platforms, fallback providers, BIN sponsoring. Structuring MoR/own-merchant, MCC, VAT and AML/KYC.
  • Integration and security. PCI SAQ, SDK requirements, token vault, stored credential compliance, 3DS 2.0 with dynamic 3DS. Setting up real-time transaction monitoring rules, fraud rules and whitelists/blacklists.
  • Routing and retries. Smart routing, bin-based routing, time-of-day/geo-based rules, split routing. Retry logic mechanics for soft decline, backoff strategies, soft decline codes and re-authorization tactics.
  • UX and A/B. Personalization of the payment flow to increase conversion, UX optimizations for mobile checkout, gateway hosted page vs embedded checkout, A/B tests of payment scenarios and lift measurement.
  • Operations and finance. Reconciliation automation, settlement timing and net settlement models, batch vs real-time settlement. Managing reconciliation of multi-currency settlements, FX and tax aspects.
  • Fraud and disputes. Bot mitigation, device trust score, velocity profile analysis. Chargeback representment process and documentation, SLA and threshold monitoring, preventions and third-party vendors.
  • Escalations and incidents. Incident response playbook for mass failures: fallback, communications with acquirers/issuers, adjustments to risk rules, post-analytics and authorization rate uplift measurements.
  • Scaling. Payment facilitator (PayFac) models for scaling the portfolio, ISO aggregator and relationship with acquirers, local acquirers in Asia and Europe, open banking and SEPA Instant. Strategies for scaling acquiring as volume grows, taking into account acquirer underwriting and turnover requirements.

COREDO’s practice confirms: discipline at every step yields a synergistic result. Even small improvements in routing, SCA exemptions and retry logic together produce a significant increase in conversion and MDR savings.

Private matters — handled personally

  • How to reduce the risk of payment failures and lower declines in cross-border transactions? Local routing, issuer-specific rules, dynamic 3DS, correct ISO 8583 fields, SMART AVS/CVV policies and precise retry windows.
  • How to reduce false declines without sacrificing security? Calibration of ML model thresholds, adding contextual signals (device fingerprinting, geolocation checks and IP-risk controls), whitelisting trusted customers and trusted beneficiaries.
  • What to consider in pricing? Interchange optimization, MCC, acquirer fees breakdown, interchange-plus vs blended pricing models, FX markup, rolling reserve and conditions for holding funds.
  • How to increase checkout conversion through acquiring optimization? Personalization of the payment flow, dynamic method selection (card/SEPA Instant/open banking), embedded/hosted hybrid, stored tokens and frictionless 3DS 2.0.
  • How to manage incident response? Real-time monitoring of the approval rate, triggers for anomalous decline spikes, automatic fallback and notifications, communication channels with acquirers and issuers, post-mortem with analysis of issuer response codes.

COREDO checklist: international acquiring

  • Legal structure: legal entity structuring, MoR vs own merchant, VAT and cross-border tax.
  • Compliance: PSD2/SCA, PCI DSS/PCI SAQ, GDPR, sanctions screening, PEP, EDD.
  • Integration: provider selection, PSP and bank acquiring, PayFac/ISO aggregator, BIN sponsoring.
  • Economics: MDR structure and components, interchange optimization, FX and settlement timing.
  • Risks: fraud scoring models, ensemble models, real-time monitoring, velocity checks, bot mitigation techniques.
  • Orchestration: smart routing, bin-based/time-of-day/geo-based routing, split routing, fallback providers.
  • UX: mobile-first, hosted vs embedded, stored credentials and card scheme rules, dynamic 3DS.
  • Operations: reconciliation automation, webhook integrations, matching rules, settlement optimization.
  • Disputes: chargeback prevention, representment documentation templates, merchant support SLA and dispute timelines.
  • Metrics: acquiring KPIs, authorization rate uplift, approval rate benchmarking, ROI.

Conclusions

International acquiring is a field where strategy, law, and engineering meet in one place. The right choice of provider, a well-thought-out legal structure, strict AML/KYC, advanced routing, and proper data handling produce an effect that is immediately visible in the P&L. I see businesses in the EU, Asia, and the CIS accelerating growth when they transform payments from infrastructure into a conversion driver.

The solution developed by COREDO always begins with diagnostics and clear KPIs. The COREDO team implements international acquiring as an ecosystem: from licensing and AML consulting to payment orchestration, anti-fraud and reconciliation automation. If you are planning to launch or scale cross-border sales and want to increase the approval rate, optimize MDR and build reliable compliance – let’s discuss the roadmap and design an architecture that will withstand any scale.

Over the years since 2016, together with the team COREDO I have developed a compliance and licensing practice so that entrepreneurs from Europe, Asia and the CIS can enter new markets without unnecessary turbulence. Company formation in the EU, Singapore or Dubai, obtaining payment, forex and crypto licenses, building robust AML processes — these tasks require not only knowledge of the laws but a clear decision‑making logic. Enhanced Due Diligence (EDD) is the core of that logic. When EDD processes operate transparently, businesses gain speed, regulators gain trust, and management gains predictability.

In this article I have systematized our practical approach to EDD. Here: working algorithms, industry standards and our case studies. The goal is simple: to show how to turn EDD from a narrow “compliance‑ritual” into a management tool that protects capital, speeds up onboarding and increases conversion of quality clients.

What is EDD and how does it differ from CDD?

Illustration for the section «What is EDD and how does it differ from CDD» in the article «Client verification Enhanced Due Diligence – process and stages»

Basic customer due diligence (CDD – Customer Due Diligence) answers the question: is there enough information to confidently begin a relationship. Enhanced due diligence (EDD) goes further: it reveals the ownership structure, identifies ultimate beneficial owners (UBO), analyzes the source of funds (source of funds) and the source of wealth (source of wealth), checks reputational and sanctions risks, as well as the quality of corporate governance.

A risk-based approach (RBA) determines the depth: the higher the risk, the deeper the EDD.

The FATF recommendations, EU AML directives (4DG, 5DG, 6DG), and the guidelines of the European Banking Authority (EBA) form the regulatory basis on which EDD is built. At COREDO we additionally rely on KYB (Know Your Business) and KYC (Know Your Customer) practices, as well as on proven methodologies such as OSINT, negative news screening (adverse media), and systematic verification of data through corporate registers and UBO registers.

When to apply EDD

Illustration for the section «When to apply EDD» in the article «Customer Check Enhanced Due Diligence – Process and Stages»
I recommend documenting a set of clear triggers that move a client from CDD to EDD. The most common scenarios:

  • PEPs (Politically Exposed Persons), their close and associated persons.
  • Complex ownership structures, use of nominee shareholders, trusts, offshore jurisdictions.
  • Sanctions risks: inclusion in OFAC/EU/UN lists, alias matches, geographic matches.
  • Crypto assets, VASP providers, transactions subject to the FATF “travel rule”.
  • Adverse media/negative news: from investigations to legal disputes and regulatory sanctions.
  • Unclear source of funds/wealth or a gap between the declared profile and actual turnover.
  • KYT (Know Your Transaction) triggers: atypical activity, layering, trade-based typologies.
  • High-risk geographies and cross-border transactions with complex chains of intermediaries.
COREDO’s practice confirms: formalized high-risk criteria consistently improve selection quality and reduce the share of false positives in subsequent automation.

Step-by-step Enhanced Due Diligence

Illustration for the 'Step-by-step Enhanced Due Diligence' section in the article 'Customer Enhanced Due Diligence check – process and stages'
A step-by-step approach in Enhanced Due Diligence allows systematically identifying and assessing client risks at each stage of engagement, reducing the likelihood of oversights and errors. Below are the key stages of EDD review that form a consistent and verifiable picture of risks.

Stages of EDD review

I structure the EDD process as a sequence of clear steps:

  1. Initial risk assessment and scoring. We record the client’s profile, geography, sector, product risks, expected volumes.
  2. Documentary verification (documentary verification). For individuals, identification, proof of address, eID/biometrics with liveness and forgery detection. For legal entities, incorporation documents, register of directors and shareholders, certified extracts, LEI (if available).
  3. Ownership structure and UBO chain checks. Ownership map, nominee/trust elements, matching with UBO registers and corporate registries (for example, Companies House).
  4. Beneficial owner checks in EDD. Identity verification, sanctions screening, PEP status, reputational checks.
  5. Source of funds and wealth in EDD. We request justification for transactions (source of funds) and the origin of capital (source of wealth), and cross-check with public and private sources. For virtual assets: blockchain analytics and address attribution.
  6. Adverse media and EDD. Negative news screening, OSINT, analysis of court registers, archives of publications with consideration of local specifics.
  7. Interviews and site visits when necessary. In cross-border cases this often reduces uncertainty and speeds up decision-making.
  8. Case prioritization and case management. We record risk hypotheses, verify them, and document conclusions.
  9. Decision and escalation. Compliance prepares a conclusion; for complex cases we involve the internal risk committee.
  10. Audit trail and evidence storage. We ensure reproducibility and further periodic reviews.

Roles and responsibilities of Compliance in EDD

For me, the key is to allocate roles according to the three lines of defense principle. The first line (business/onboarding) collects basic data and initiates the case. The second line (compliance) manages the EDD procedure, sets rules, performs independent verification and prepares the conclusion. The third line (internal audit) assesses the quality, completeness and independence of the procedure.

The solution developed at COREDO records the RACI: who initiates requests, who approves exceptions, who escalates to the committee, who is responsible for SAR/STR. Such clarity simplifies communications with the FIU and regulators and maintains continuous readiness for inspections.

Documents used in EDD

The COREDO team has implemented a list of documents that consistently meets the requirements of international regulators:

  • Individuals: passport/ID, proof of address (utility bill/bank statement), confirmation of source of funds (statements, sale and purchase agreements, dividends, investment reports), confirmation of source of wealth (business history, proceeds from sale of shares, inheritance with supporting documents).
  • Legal entities: incorporation documents, articles of association, certificate of registration, register of directors/shareholders, UBO declaration, certified/apostilled extracts, licenses, audited reports, major contracts, bank confirmations.
  • For crypto clients: compliance policy for the ‘travel rule’, description of KYT systems, blockchain analytics reports, evidence of wallet attribution.
Certified documents and their validation play an important role. I support electronic verification with biometrics to reduce onboarding time and decrease the risk of forgeries.

EDD for legal entities and individuals

Illustration for the section 'EDD for legal entities and individuals' in the article 'Client check Enhanced Due Diligence – process and stages'
EDD helps identify and assess risks related to legal entities and individuals, adapting the depth of the review to the client’s profile. Далее подробно остановимся на EDD для юридических лиц (KYB): процедурах верификации, ключевых документах и индикаторах повышенного риска.

EDD (KYB) for legal entities

В KYB-кейсе мы проверяем правоспособность, экономическую сущность и управленческую структуру. Обязателен анализ UBO: цепочки владения, номинальные держатели, трасты, оффшорные “узлы”. Практика COREDO: использовать пакет OSINT-источников, корпоративные реестры (включая Companies House), UBO registers, а также инструменты entity resolution и анализ графов для сопоставления связей.

При наличии высокого риска я рекомендую дополнительно запросить сертифицированные реестры акционеров, протоколы собраний, доказательства контроля (shareholder agreements). Такой подход снижает вероятность пропусков риска (false negatives).

EDD for individuals

Здесь важно качество KYC и оценка PEP. Мы учитываем родственников и тесно связанных лиц, особое внимание уделяем несоответствию между профилем клиента и декларируемыми источниками средств. В COREDO я ввожу контрольные вопросы для интервью: логика доходов, ключевые транзакции, структура активов, география налогового резидентства. Это повышает explainability и облегчает диалог с регуляторами при последующих проверках.

Sources of funds and UBO chains

Illustration for the section 'Sources of funds and UBO chains' in the article 'Enhanced Due Diligence client screening – process and stages'
Source of funds (SoF): the short-term perspective of a specific transaction, the source of wealth (SoW), the long-term history of capital. We collect evidence, match it against the client’s financial model and public datasets. In cases involving virtual assets I use blockchain analytics to confirm the cleanliness of the funds’ path, identify connected addresses and assess mixer risks.

Reviewing ownership structure and UBO requires flexibility. When a client resorts to trusts, I request trust declarations, letters of intent, information about beneficiaries and protectors. Oversight of nominee shareholders: another mandatory layer. In complex schemes, analysis of transaction and relationship networks helps, as does matching with adverse media.

Working with PEPs, sanctions and adverse media

Enhanced checks when working with PEPs: standard practice. I increase the frequency of periodic reviews, expand the scope of OSINT, re-check sources of wealth and conflicts of interest. Sanctions screening relies on sanctions-screening tools (API, watchlists), relevant OFAC, EU and UN lists, as well as regional lists when necessary.

Adverse media and EDD are carried out according to a verification principle: an initial finding is a hypothesis that requires confirmation from independent sources. This approach reduces false positives and preserves speed.

EDD for VASP and cryptocurrency clients

EDD rules for cryptocurrency clients include KYC/KYB, compliance with the FATF “travel rule”, monitoring systems of transactions (KYT) and blockchain analytics. I always review the control architecture: token listing policy, counterparty risk management, blocking mechanisms and escalation procedures.

In onboarding with EDD for international VASP clients, proof of licensing, the presence of an independent Compliance Officer, descriptions of SAR/STR procedures and interaction with the FIU are important. Additionally, testing “live” cases in the monitoring system to ensure the quality of the configurations.

EDD Integration into AML

Proper integration of EDD into AML processes turns complex customer assessment procedures into a manageable set of rules and events, increasing the accuracy and consistency of decision-making. This creates the foundation for automating routine stages: from data collection and validation to triggers for subsequent checks, and naturally leads to the topic of EDD process automation.

Automating EDD processes

I integrate EDD into the AML system so that data and decisions flow end-to-end: CRM/ERP, sanctions and PEP screening: EDD module – case management – audit log. Tools: APIs for watchlists, scoring models, rules and scenarios, entity resolution, graph analysis, ML models for prioritization. For regulators, explainability of ML models is critical: we use interpretable risk factors and reports with clear metrics.

Backtesting and validation of AML rules are performed regularly. I track KPI/KRI: time-to-onboard, SAR rate, share of returns for rework, share of false positives/false negatives, average manual review time. This approach allows tuning rules without excessive rigidity and preserves conversion.

Configuring KYT triggers for EDD

I link KYT to EDD through entry points: limit breaches, atypical geography, sudden spikes in turnover, signs of layering, trade-based schemes, frequent refunds. Properly configured triggers escalate the case to in-depth review with a clear processing SLA. This provides control and transparency for management.

Audit and quality reporting

Quality control and audit of EDD include a continuous audit trail, peer review of complex cases, and an independent internal audit. Reporting: not only regulatory (FIU, SAR/STR), but also managerial: statuses, overdue items, reasons for escalations, results of investigations. The COREDO team implements report templates that are easier for both the business and compliance officers to digest.

I support regular tabletop exercises in case of a regulatory inspection. Such training keeps the documentation “alive” and preserves staff confidence during inspections.

Access and Data Management

Access control to data during EDD is based on the principle of least privilege. Data storage and data retention policies comply with the GDPR and requirements for cross-border data transfer. We apply data minimization, record the client’s consent, and log every operation in an event log.

Documenting decisions and preserving evidence include screenshots, file hashes, document versions, and the date of receipt. When necessary, we cooperate with law enforcement through formal channels and with legal counsel.

EDD for business: timelines, cost, ROI

How to reduce onboarding time in EDD?

I recommend three steps: a preliminary checklist, electronic document submission with biometrics and eID, and early screening for UBOs and sanctions before the full package is collected. This reduces repeat requests and speeds up approvals.

EDD cost and ROI calculation depend on the risk profile, volume of documents, the need for site visits and the depth of OSINT. Compliance cost assessment includes direct expenses for data providers, licenses, staff time and indirect effects from onboarding delays. Strategies to reduce operating costs for EDD: automation of routine tasks, standardization of templates, case prioritization, staff training and optimization of manual review.

Pricing models for EDD services vary: fixed fee per case, a complexity‑based hybrid, a retainer with KPIs for time‑to‑onboard and SAR/STR quality. I link EDD metrics to business outcomes: impact on customer conversion, product launch speed and resilience to regulatory risks.

Scaling EDD within the company

Scaling EDD requires standardized policies, a living knowledge base, and regular training. I build employee training for effective EDD through case practicums, specialist certification, role-play escalation scenarios, and explainability training for dialogue with auditors. Peer benchmarking of EDD practices helps keep the standard aligned with the market without losing the unique aspects of corporate risk policy.

Compatibility of EDD with corporate risk policy is achieved through clear risk appetites, tolerance matrices, and documented exceptions. Such a framework allows scaling decisions without surprises.

Working with counterparties and suppliers

Counterparty and supplier screening through EDD, part of the ecosystem. I implement vendor due diligence: evaluation of the data provider, legal and technical SLAs, quality obligations, an incident response plan and fallback channels. Third-party and counterparty management reduces dependence on a single source and helps control the risk of gaps.

Vendor due diligence practices include test run checklists, measuring the rate of false positives, assessing coverage of sanctions and PEP lists, as well as audit trails in the tools.

Refusal and termination of relationships

Sometimes EDD leads to refusal of service after EDD or to termination of relationships. I document the legal procedures for refusal and termination of relationships: transparent reasoning, careful communication, compliance with data retention periods, fulfillment of obligations to regulators, proper closure of accounts/relationships.

Escalation procedures and coordination with management prevent impulsive decisions and preserve reputation.

Regulatory sanctions and fines for AML violations are more costly than a timely refusal. Therefore a clear refusal policy: it is business protection and a signal to the market of mature risk management.

How EDD solves challenges at COREDO

The COREDO Case Studies section shows how EDD helps solve complex problems in real projects. Using a cross-border deal as an example, we examine specific approaches, process integration, and practical results. These materials will help understand which tools and steps lead to success when implementing EDD.

EDD in a cross-border deal

A client from the EU planned investments in a technology asset with a multi-jurisdictional structure (EU, United Kingdom, Singapore). The COREDO team deployed an EDD process: verification of ownership structure and UBO chains, matching with UBO registers, analysis of regulatory history through Companies House and Singaporean registers, OSINT and adverse media. At the source-of-wealth stage we requested audited financial statements and confirmations of M&A transactions.

KYT triggers showed atypical transfers to addresses associated with early investors. Blockchain analytics confirmed a clear funds trajectory. The outcome: a lowered risk category, the deal launched on schedule, and an agreed reporting package for the FIU in case of post-monitoring.

Investigation of complex UBO schemes

In a Dubai project the client managed the holding through a trust and nominee directors. The solution developed at COREDO included graph analysis and entity resolution to match indirect links, requests for trust declarations and interviews with key persons. In parallel we used negative news screening across regional sources and conducted a site visit.

The findings made it possible to identify the true UBO and adjust the service terms. The internal committee approved the EDD conclusion, and the periodic monitoring system revised the review frequency. This approach preserved speed and reduced the risk of surprises.

ESG and reputational risks

ESG and EDD are directly connected. Reputational risks are part of a high-risk assessment. I pay attention to environmental and social incidents, corporate conflicts, legal claims, and ethical issues in the supply chain. When a business takes ESG‑factors into account in EDD, it protects its value and reduces the likelihood of adverse media in the future.

Ethical issues are about informed consent, data minimization, and careful handling of personal data. This approach builds trust and supports GDPR compliance.

How to conduct Enhanced Due Diligence

  • Document high-risk criteria and entry points for EDD.
  • Set up scoring and RBA, define roles and escalations.
  • Collect documents: KYC/KYB, SoF/SoW confirmations, UBO, licenses and reports.
  • Conduct sanctions screening, PEP screening, adverse media checks and OSINT.
  • Build an ownership map, identify the UBO, check nominees/trusts.
  • For crypto: travel rule, KYT, blockchain analytics, address attribution.
  • Use automation: API screening, case management, ML prioritization, explainability.
  • Conduct interviews/site visits for elevated risk.
  • Document findings, ensure an audit trail, set up periodic monitoring.
  • If suspicions arise, follow investigation procedures, file SAR/STR and engage with the FIU.

Conclusions

EDD is not a brake on international growth, but a framework that gives businesses confidence and speed. Our experience at COREDO has shown: when risk processes are transparent, documents are audit-ready, and automation supports people, onboarding is faster, Licensing proceeds predictably, and regulatory dialogue becomes constructive.

I build my practice so that entrepreneurs and chief financial officers receive a comprehensive solution: from company registration in the EU, the Czech Republic, Slovakia, Cyprus, Estonia, the United Kingdom, Singapore and Dubai to obtaining financial licenses and setting up EDD in the context of AML and KYC. If your business needs to reduce risk, accelerate onboarding and improve the quality of decisions, the COREDO team is ready to become a long-term partner and a pillar of your international operations.

I founded COREDO in 2016 with a very simple idea: entrepreneurs should have access to a predictable and secure infrastructure for international business. Since then the COREDO team has completed hundreds of projects in the EU, Asia and the CIS and has gone through the whole process with clients: from company registration to obtaining financial licenses and bank onboarding. This experience has shaped a resilient methodology in which legal architecture, taxation and compliance work as a single system.

This article is a concentrated summary of COREDO’s practice on key topics: international company registration, Licensing (crypto, payments, forex, investment services), compliance and legal entity onboarding at a bank. I write in the first person because I am personally responsible for ensuring that the client sees in advance all KYC requirements when opening an account, compliance with AML and tax requirements, and understands how to reduce onboarding time without compromising compliance. My goal is to give you strategic guidelines, concrete checklists and practical solutions that we apply daily.

Choice of jurisdiction and substance

Illustration for the section «Choice of jurisdiction and substance» in the article «Taxes and compliance as part of bank onboarding»
The right jurisdiction, is not a flag on a website but the foundation of bank onboarding, tax resilience and operational speed. Our experience at COREDO has shown: a successful launch is built on three pillars – a transparent ownership structure (UBO), economic substance (substance) and a manageable tax position. If these three elements are aligned, AML compliance and onboarding turn into an operational procedure rather than a long due diligence cycle.

We start with the business model and the value chain. Where profit is generated, where the clients are located and where management is based — the answers determine the risk of a permanent establishment (PE) and the assessment of the company’s tax residency. When designing the structure I keep the impact of BEPS and MLI on bank onboarding in focus, the requirements for master file / local file under transfer pricing and the company’s readiness to justify intragroup pricing.

EU: Czechia, Slovakia, Cyprus, Estonia

In the EU the bank examines substance under a magnifying glass. Office, employees, contracts with key counterparties, on‑site management decisions: all this confirms economic activity and substance during onboarding. In Czechia and Slovakia banks value the predictability of financial reporting and the transparency of beneficial owner registers; in Cyprus and Estonia, the quality of AML policy/CFT, and in the UK, the maturity of corporate governance and PSD2 compliance for payment businesses.

COREDO’s practice confirms: in the EU registration is half the job, the other half: preparing for CRS and FATCA, setting up TP documentation and monitoring related activity. We pre‑agree corporate documentation with the bank (incorporation documents, contracts, bank transactions for the pilot period) and explain the economic rationale of the structure. This reduces the risk of account opening refusals on the grounds of «nominee shareholders» or breaks in the ownership chain.

Singapore and Dubai: Asia and the Middle East

Singapore and Dubai are about speed and technological sophistication, but also about impeccable compliance. In Singapore the regulator MAS expects well‑thought‑out KYC/KYB, and when licensing under the Payment Services Act — advanced AML procedures and fraud monitoring. In Dubai, whether VARA for crypto or DFSA in DIFC for investment services, the emphasis is on governance, risk & compliance and on how the company manages the risk appetite framework.

The COREDO team builds onboarding in Singapore and UAE banks through early dialogue with compliance officers: we show sources of funds (source of funds), transactional logic, sanctions screening and KYT plans. This accelerates international bank onboarding and increases trust in the client even before submitting the application.

Coordinating structures in CIS countries

Companies from the CIS often go to the EU or Asia to access payment infrastructure and investors. To avoid questions on tax Due Diligence and reputational risk, we build corporate transparency from the start, register the UBO in relevant registers and prepare cross‑verification of documents (cross‑check) for bank compliance teams. The solution developed at COREDO is a multi‑jurisdictional scheme where management residency and tax obligations are calculated and demonstrable.

Licenses: crypto and payment institutions

Illustration for the section «Licenses: crypto and payment institutions» in the article «Taxes and compliance as part of bank onboarding»
Licensing, is a check of business maturity. Banks infer from the license and regulatory status the quality of your AML system/KYC and the resilience of the business model. I always synchronize the license project with the future onboarding so that “taxes and compliance” are integrated at the process level, not added afterwards.

Crypto/DLT: licenses and regulations

In the EU crypto services are registered as CASP in Cyprus (CySEC) or under tightened rules in Estonia. In the UK crypto companies register under the MLRs with the FCA, and in Singapore obtain DPT licenses from MAS. In Dubai VARA is responsible for VASPs with a focus on EDD, sanctions screening and PEP risk management. Our cases show: banks accommodate crypto clients when they see a mature AML framework, EDD and CDD procedures in onboarding, and proven control of transaction history.

EMI/PI, banking and forex licenses

EMI/PI in the EU under PSD2 require strong governance and reliable correspondent banking relationships. Forex businesses like CIF in Cyprus or under the FCA in the UK are full MiFID processes, including market abuse controls and records of communications. The COREDO team builds licensing so that AMLD5/6, GDPR and local regulations are embedded into operational SLAs and measurable through compliance KPIs.

PSD2 sandboxes, correspondent relationships

A sandbox for financial innovation, an opportunity to test a model and gather “evidence of viability” for a bank. We use PSD2 integrations to access payment data and for early calibration of fraud monitoring. This reduces cost per onboard (cost‑per‑onboard) and speeds up time‑to‑onboard, because the bank’s compliance has fewer questions about data quality and automation of controls.

Onboarding: AML and Tax Compliance

Illustration for the section 'Onboarding: AML and Tax Compliance' in the article 'Taxes and Compliance as Part of Bank Onboarding'
I treat bank onboarding as a project with defined stages, SLAs and responsible parties. When AML and tax due diligence run in parallel, the risk of “sudden” requests from the bank falls sharply. The solution developed at COREDO is a unified AML+Tax compliance matrix that answers the bank’s key question: what do you know about the client, their tax history and the real economics of the business.

KYC/KYB, CDD/EDD and UBO verification

The bank starts with basic identification and legal cleanliness. We prepare a KYC/KYB package where UBO (beneficial owner) verification relies on public and private registers, notarized confirmations and logical ownership chains. For structures with trusts and nominee arrangements we pre-form a written disclosure, confirm ownership rights and beneficial economic interest, and demonstrate how banks verify ownership chains and nominee shareholders.

Common Reporting Standard/Foreign Account Tax Compliance Act/Base Erosion and Profit Shifting/Multilateral Instrument/Directive on Administrative Cooperation (DAC6)/Permanent Establishment/residency

I have integrated a separate module for CRS and FATCA into the onboarding: self-certification forms, assessment of the tax residency of the company and beneficiaries, and a data exchange policy. We analyze PE risk, the impact of BEPS and MLI on profit allocation, and for cross-border schemes we check whether a transaction falls under DAC6 as potentially reportable. This approach closes the bank’s “taxes and compliance” questions before they arise.

Tax due diligence and transfer pricing

Tax due diligence is about predictability. We check whether there is a master file / local file, whether TP policies correspond to actual flows, and assess transfer pricing risks during the account opening process. Banks increasingly request brief TP reviews, especially for holdings with intra-group loans and royalties, and I prefer to provide these materials proactively to reduce the risk of EDD requests.

AML onboarding: PEP, sanctions screening

Advanced banks check not only individuals and directors but also related activity. We perform sanctions screening, mitigate PEP risks through connection segmentation and product restrictions, and document the verification of source of funds. Built-in KYT helps explain control over transaction history during the initial client check, and also sets the framework for post-onboarding monitoring and filing SAR/STR on suspicious transactions.

Documents and digital ID: eIDAS, GDPR

digital identification and eIDAS save weeks when the bank accepts qualified e-signatures. We use OCR to read documents, biometric verification and liveness checks, and consent for personal data processing and the GDPR policy are written clearly and transparently. File reporting and evidence storage (audit trail) ensure that any compliance question can be closed by referencing the system log and supporting files.

Tax review during bank onboarding

I link CRS/FATCA data with KYC through a unified questionnaire and set of attributes. This allows the bank to see the tax position immediately and, if necessary, request EDD selectively rather than “at random”. As a result, onboarding time (time-to-onboard) decreases and compliance with AML requirements and tax requirements increases without overburdening the client with documents.

Onboarding risks and SLA

Illustration for the section «Onboarding risks and SLA» in the article «Taxes and compliance as part of banking onboarding»
Onboarding is a managed process. I set SLAs for each stage, assign owners and measure results using onboarding KRI/KPI. This approach disciplines both the client and the bank: everyone has a shared understanding of where we are and what has been done.

Risk scoring, risk appetite, KRI/KPI

We assess client risk and risk scoring across several elements: jurisdiction, industry, complexity of structure, sanctions indicators, and tax history. The risk appetite framework defines which combinations of factors are acceptable and which require EDD. I track KRIs (delays, number of escalations) and KPIs (time‑to‑onboard, cost‑per‑onboard) to identify bottlenecks and address them promptly.

API automation, ID vendors, ROI

Automation of KYC/KYB and tax control through API integration with ID verification vendors produces a noticeable effect. We calculate the return on investment (ROI) of implementing automated compliance not by feel but by the reduction of manual checks and decreased bank declines. Support for scaling onboarding processes includes automatic sanctions monitoring, fraud alerts, and an appropriate response to changes in the risk profile during post-onboarding.

Corporate client onboarding case studies

In mass onboarding, standardization and quality control are important. The COREDO team implements a two-step review, where the first line addresses formal non-conformities, and the second performs thematic reviews (for example, on PE or TP risks). This reduces the bank’s reputational risk when accepting a client and limits regulatory risk and compliance issues through documented verification of each step.

International data exchange requirements

Illustration for the section «International data exchange requirements» in the article «Taxes and compliance as part of banking onboarding»
International transparency is the new norm. I design processes so that requests from regulators and tax authorities are not a surprise, but fit into the client’s and the bank’s standard operating procedures.

CRS and EOIR information exchange practices

CRS and automatic exchange are the ongoing norm, while information exchange on request (EOIR) may require extended explanations. We prepare clients for regulatory notifications and interactions with supervisors through careful documentation and supporting materials. This helps avoid escalations and speeds up the resolution of requests.

Beneficial ownership registers, nominees, trusts

The role of corporate transparency and beneficial ownership registers in onboarding cannot be overstated. Banks check beneficiary registers, reconcile data with corporate records and expect disclosure of nominee arrangements. For structures with trusts we provide trust declarations, protector letters and benefit distributions so that no grey areas remain for the bank.

Impact of sanctions lists on geo-risk

Sanctions lists and flag indicators of risky jurisdictions significantly influence the decision to open an account. I prefer to assess geo-risk in advance and potential restrictions on products and payment corridors, including dependence on correspondent banking relationships. An honest conversation about risks saves time and preserves the reputation of all parties.

COREDO case studies: mistakes and solutions

There are many examples, but I chose three that best illustrate COREDO’s approach to the complex challenges of onboarding and licensing.

Accelerating the onboarding of a fintech company in the EU

A fintech client with an EMI license faced an extended review due to an ambiguous TP policy and incomplete CRS/FATCA documentation. We performed an express-AML audit/Tax, built a combined AML and tax compliance matrix for banks, and integrated CRS/FATCA data into the KYC process via API. As a result, the bank reduced the number of additional requests, and time-to-onboard was shortened from eight weeks to three.

Substance of an offshore holding company

An investment structure with a holding in the EU and operating companies in Asia was rejected because of questions about substance and economic justification. The COREDO team developed a plan to strengthen substance: office, management functions, contracts with key suppliers, and an explanatory note on the allocation of functions and risks. After updating the master file/local file and re-submitting, the bank approved the onboarding, and the client passed EDD without delays.

Reasons for rejections due to tax risks

Common reasons for rejections: discrepancies in UBO disclosure, lack of evidence of source of funds, and incomplete TP documentation. I apply preventive measures: stress-testing the client’s tax compliance, simulating bank questions, and a review of the agreement with key counterparties. Such an audit shows what fines the bank and the client may face in the absence of tax compliance and how to adjust processes before submission.

Checklists and action templates

Checklists are not bureaucracy but a way to reduce risk and speed up work. Below are three sets I recommend using before onboarding.

Tax-legal compliance during onboarding

  • Check residency and PE risk. Assess where key management decisions are made and prepare evidence of presence (substance).
  • Prepare CRS/FATCA self-certifications. Ensure that UBO and controller data are consistent with corporate registers.
  • Update TP documentation. Verify that the master file/local file correspond to actual flows and applied pricing methods.
  • Conduct sanctions and PEP screening. Record the results and the response measures to identified risks in the risk register.
  • Set up GDPR processes and consents. Describe how you store KYC data, retention periods and access for the audit trail.

Onboarding document package

  • Incorporation documents, shareholder register, and UBO confirmation. Add notarizations and translations if the bank expects them.
  • Agreements with key counterparties and confirmation of payment logic. Attach invoices and bank remittances for pilot transactions.
  • AML/CFT, KYC/KYB policies and EDD/CDD procedures. Show how you perform supplier and counterparty checks and manage risks.
  • Tax due diligence and TP review. Prepare a short memo with key findings and a risk map.
  • Financial statements and business plan. Justify the economic model, sources of financing and transactional activity forecast.

Shorten onboarding without harming compliance

  • Agree the risk profile with the bank before submission. Discuss the geography of payments, sanctions restrictions and correspondent corridors.
  • Use digital identification and eIDAS. Clarify whether the bank accepts e-signatures and remote verification of directors and UBO.
  • Implement KYC automation and OCR. Prepare data in structured form and ensure recognition accuracy.
  • Split the document package into stages. Give the bank the necessary minimum at the start and prepare answers to EDD questions in advance.
  • Assign responsible parties and SLAs. Record response times, the communication channel and the escalation procedure on the client side and COREDO.

How COREDO organizes support

Complex projects require clear roles and disciplined execution. I design the process so that every participant understands their area of responsibility and the quality criteria for the outcome.

Role of the internal AML/Tax officer

The internal AML/Tax officer is responsible for the client’s compliance architecture and for dialogue with the bank. The COREDO team strengthens this role with methodology, templates and training, and also helps calibrate risk scoring and implement KRI/KPI. Such a tandem speaks to the bank in one language: “compliance and onboarding” become a joint project with shared responsibility.

Aligning the company structure with the bank

Structure alignment is a separate stage. I provide the bank with a brief note on the structure, UBO, substance and tax position, with visual diagrams of ownership chains. This reduces the likelihood of disputed interpretations, helps the bank assess the economic rationale of the company’s structure, and speeds up decision-making.

How to manage scaling and growth

As you grow, new jurisdictions, product lines and investment structures emerge. COREDO’s practice confirms: regular review of the risk appetite, policy updates and support for automated KYC/KYB platforms prevent the accumulation of compliance debt. We support scaling without increasing regulatory risk and while keeping onboarding SLA at an acceptable level.

How to structure the next step

International bank onboarding is not about ‘just passing a check’, but about building a system that the bank, the regulator and your partners trust. I always start with the business model and tax architecture, then add licensing and only after that proceed to submitting an application to the bank. This order reduces risks, speeds up approvals and makes the process predictable.

If you plan to register a company in the EU, Singapore or Dubai, obtaining a license for crypto, payments or forex, or are preparing for a multi-jurisdictional onboarding of a holding, engage expertise in advance. The COREDO team is used to solving tasks comprehensively: from designing the structure to setting up AML/KYC, integrating CRS/FATCA data and preparing for post-onboarding monitoring. I see my role as ensuring your growth goes hand in hand with strong compliance, and that bank onboarding becomes a source of trust rather than a factor of uncertainty.

I have been working with international investment platforms and crowdfunding services for many years, and today I see a unique window of opportunity in Europe. Regulation has become strict and transparent, the infrastructure: mature, and investors demanding and disciplined. In such an environment, those who build compliance by design, plan licensing in advance, and understand how ECSP, MiFID II and MiCA relate to one another win. In this article I will lay out how we, together with the COREDO team, build strategies for platforms operating at the intersection of crowdfunding, P2P lending and crypto-assets, and I will show practical steps, timelines and metrics that really work.

Now for investment platforms in the EU

Illustration for the section «Now for investment platforms in the EU» in the article «Investment platforms and crowdfunding - regulatory differences in the EU»

Regulation of crowdfunding in the EU has finally entered a phase of maturity: European Crowdfunding Service Providers (ECSP) have removed barriers between countries for investment and debt crowdfunding, providing single passporting and clear rules. This means that a well-chosen jurisdiction and properly designed compliance will allow scaling across the Union without duplicating licenses. Our practice confirms: those who adopted ECSP in 2024–2025 gain a noticeable advantage in the cost of raising capital and the speed of launching partner programs.
At the same time, MiCA moves crypto-assets out of the “grey area” into a regulated space: platforms can reasonably plan work with utility tokens, ART/EMT and tokenize equity instruments in combination with traditional crowdfunding models. It is important here to soberly assess where ECSP ends and MiFID II begins, and which part of the model requires a whitepaper and disclosure under MiCA. At COREDO we have learned to assemble these pieces so that the legal architecture does not break the product and growth metrics.

ECSP or CIS: which is more advantageous and when?

Illustration for the section «ECSP or CIS: which is more advantageous and when?» in the article «Investment platforms and crowdfunding - regulatory differences in the EU»

Moving from general logic to practical criteria helps to understand exactly what the key differences between ECSP and CIS are. We’ll examine which model is more advantageous for different business goals and when it makes sense to follow the MiFID II regime and when to prefer the European crowdfunding framework.

Differences between ECSP and CIS under MiFID II

ECSP is a specialized regime for investment crowdfunding and SME lending with a limit of €5 million per project within 12 months and enhanced protection for non‑qualified investors. It provides passporting across the EU, establishes suitability tests, a cooling‑off period and disclosure standards. For most platforms where the core product is equity crowdfunding or business lending, ECSP is the optimal route balancing requirements and flexibility.
CIS under MiFID II is essentially an investment firm providing investment services (for example, reception and transmission of orders, placing without firm commitments). Such a regime is more powerful but more expensive in terms of capital and processes, and may require a prospectus in some structures. It is needed when you exceed €5 million per issuance, work with more complex instruments, or want the full range of MiFID services.

Costs and licensing timelines

In terms of licensing timelines for ECSP, we consistently see 3–6 months from submission to authorization with good preparation and effective communication with the regulator. In some jurisdictions and with a complex structure the period can stretch to 9 months, but disciplined document preparation brings the project back into the target range. For MiFID II‑CIS you should plan 6–12 months, enhanced capital and governance requirements, and a more stringent risk management infrastructure.
The investment cap in ECSP is €5 million per project per year, and this is a key parameter of economic efficiency. At the investor level the EU does not set a single quantitative limit, but for the non‑sophisticated segment the platform must conduct suitability tests and inform about risks. The COREDO team usually recommends internal starting limits in the range of €500–€5,000 per transaction for non‑qualified investors until they pass the test and confirm their experience. This reduces fundraising volatility and the risk of breaches.

Choice of jurisdiction: Estonia, Lithuania

Illustration for the section «Jurisdiction choice: Estonia, Lithuania» in the article «Investment platforms and crowdfunding - regulatory differences in the EU»
jurisdiction choice: between Estonia, Lithuania, Cyprus, Czechia and Poland – sets the key framework for compliance, taxation and the operational business model. Below we will examine practical aspects and advantages of different countries, starting with obtaining an ECSP license in Estonia and e-residency opportunities.

ECSP license in Estonia and e‑residency

Estonia offers a fast speed-to-market thanks to digital company registration, e-residency and clear communication with the regulator. The COREDO team implemented several projects where we combined registration via e-residency, preparation of policies for ECSP and integration of RegTech providers for KYC/AML to reduce time to first listings. The regulator values a transparent ownership structure, real substance and a well-thought-out conflicts of interest management policy.

Licensing of investment platforms

Lithuania is strong in the fintech ecosystem and in its interface with banks and PSPs. We have cases where a platform started with ECSP while simultaneously preparing a pipeline for e-money and payment services at the second scaling stage. The Lithuanian regulator pays close attention to transaction monitoring and origin-of-funds verification, as well as to escrow/custody models. This is convenient for P2P lending with a clear flow of funds.

Legal entity registration for crowdfunding

Cyprus: a good hub for structuring investment services and cross-border flows, but it requires a careful approach to substance requirements: an office, key personnel, local directors and management processes. CySEC closely examines the prospectus for a public offering of securities and the delineation of services under MiFID II. The solution developed by COREDO for one client included a combined model: an ECSP platform in the EU and a Cyprus structure for investment services complying with CySEC requirements for reporting and internal control.

ECSP Czechia (CNB) and differences with Estonia

The Czech central bank (CNB) adheres to a conservative approach in assessing governance and risk management. The regulator requires convincing evidence of management competence and the independence of compliance functions. Compared with Estonia, Czechia may take longer to agree operational models but provides a stable position for entering Central European markets. Our experience at COREDO has shown that thorough preparation of documents on EU P2P lending rules and investor protection speeds up the approval process with the CNB.

PKD codes and Due Diligence for SPI/NPI

Poland, a strategic market for payment infrastructure. SPI/NPI (Small/National Payment Institution) are useful if you are building a marketplace with payment flows. It is important here to correctly determine PKD codes with the registrar and to build due diligence for SPI/NPI models so that they do not conflict with the services of an ECSP platform. The COREDO team configured procedures for clients on an AML risk-based approach, FIU reporting obligations and sanctions screening taking into account local requirements and EBA guidance on cross-border compliance.

Markets in Financial Instruments Directive II (MiFID II), Markets in Crypto‑Assets Regulation (MiCA), Sixth Anti‑Money‑Laundering Directive (AMLD VI), European Securities and Markets Authority / European Banking Authority (ESMA/EBA)

Illustration for the section «MiFID II, MiCA, AMLD VI, ESMA/EBA» in the article «Investment platforms and crowdfunding - regulatory differences in the EU»
MiFID II, MiCA, AMLD VI and ESMA/EBA guidance form a unified regulatory landscape that defines the rules for platforms, from traditional brokers to new models like P2P lending. In the following subsections we will look at how these standards are applied in practice, in particular regarding investor protection and compliance with AML requirements.

MiFID II for P2P: investor protection

MiFID II affects those platforms where the instruments fall into the category of financial instruments. In P2P lending this is more often a matter of structuring: securities or loan agreements, and whether the platform acts as an investment intermediary. COREDO’s practice confirms: with sound legal design ECSP covers 80% of typical models, while MiFID II comes into play for extended functionality, marketing of complex products and a deeper underwriting role for the platform.

MiCA: compliance of platform whitepapers

MiCA classifies tokens as ART (asset‑referenced tokens), EMT (e‑money tokens) and other tokens, setting the regimes for whitepapers and disclosure. For tokenized equity and debt instruments we determine in advance whether the model intersects with MiFID II. For a MiCA whitepaper I recommend the following structure: project and team description; investor rights and risks; token economic model; control and redemption mechanisms; AML/KYC procedures; disclosures on custody and cybersecurity. In some jurisdictions a whitepaper requires notification or approval, which is built into the roadmap.

AMLD VI: KYC/KYB, sanctions, FIU reporting

AMLD VI strengthens personal liability for AML compliance and expands the definition of «involvement» in money laundering. For platforms this means: staged KYC levels (risk‑based), KYB for issuers and borrowers, origin of funds automated verification and continuous transaction monitoring. At COREDO we build full cycles: from risk scoring models to alert tuning rules, as well as FIU reporting procedures and incident escalation.

Compliance by design: building platforms

Illustration for the section «Compliance by design: building platforms» in the article «Investment platforms and crowdfunding - regulatory differences in the EU»
KYC automation and risk scoring models

KYC automation for investment platforms starts with multi-level verification of identity, address and PEP status, and for KYB – with checks of beneficiaries and ownership structure. We implement risk scoring with dynamic raising/lowering of KYC levels depending on activity, jurisdiction and amount. Origin of funds verification is automated through income confirmations, bank statements and integrations with payroll/tax sources where this is legally possible.

Transaction monitoring with AI: alerts

Transaction monitoring systems with AI help catch anomalies, but without correct rules they overwhelm compliance. The COREDO team configures scenarios by transaction types, geography, risk typology and behavioral patterns. We keep the level of false positives down through iterative alerts tuning, maintaining strictness toward sanction risks and signs of layering. This reduces operational costs and speeds up case resolution.

cross-border KYC and clients from Asia

Sanctions compliance screening is not only the EU and UN lists, but also industry, regional and internal watch‑lists. For clients from Asia we build a compliance strategy taking into account local registers, language aspects and MAS Singapore substance requirements for structures operating from Singapore. Practical benefits: fewer bank rejections and fewer “manual” checks when scaling cross-border flows.

Technologies and DeFi under European law

DeFi and smart-contract audits

Hybrid DeFi regulation models are possible when a platform has centralized points of control: onboarding, project listing, custody/escrow, off‑chain management of corporate rights. We integrate smart‑contract audit into the roadmap and link whitepaper sections and cybersecurity procedures to it. Possible DeFi exemptions are limited: if there is an identifiable issuer or operator, the regulator requires the classic set of disclosure and AML obligations.

Custodial vs non-custodial risks

Custodial models provide control over assets and simplicity for FIU reporting, but increase liability and capital/insurance requirements. Non‑custodial reduces the platform’s risk; however, it shifts verification of the origin of funds and monitoring to the deposit and withdrawal stages. We help choose the architecture based on the risk profile, banking relationships and the chosen regime (ECSP, MiFID II, MiCA).

Bank payments infrastructure

Bank account opening for fintechs in the EU

Account opening is a bottleneck. Optimizing bank on‑boarding for platforms starts with a transparent structure, a clear client profile and a well‑designed AML model. Experience shows: a single strategic bank partner and a backup PSP reduce no‑banking risk. At COREDO we set up banking relationships, prepare dossiers and support interviews with the bank to speed up the decision.

Onboarding of payment providers and e‑money

For platforms with intensive payment flows, a setup with e‑money providers and licensed PSPs is useful: it simplifies escrow and provides flexibility in multi‑currency operations. We design the process to avoid duplicating KYC between the platform and the PSP, and we also synchronize the rules for transaction monitoring and sanctions screening.

Taxes and reporting for platforms

IOSS VAT for marketplaces: tax agent

For marketplaces with cross-border sales, IOSS VAT reduces administrative burden but requires correct classification of roles and flows. The tax agent marketplace model allows centralizing settlements and reducing errors. I recommend conducting a tax stress test before scaling across the EU to avoid retroactive surprises.

FIU reporting, ESMA and EBA cross-border

FIU reporting obligations in the EU require a systematic approach: threshold transactions, suspicious activities, record retention and quality control. ESMA oversight sets expectations for investor protection and disclosure for ECSP, and EBA guidance streamlines cross-border compliance. The COREDO team prepares an audit-ready document package, including an escalation policy and a staff training log.

Passporting and scaling in the EU

Passporting and substance tests

Passporting in ECSP gives the right to operate across the EU, but substance tests remain. Regulators assess whether key functions and decisions are actually made within the chosen jurisdiction. We design the allocation of functions in advance to meet substance requirements and ensure sustainable cross-border investment flows without claims of “empty shells”.

MiFID II: governance and tech stack

If the strategy involves moving to a CIS under MiFID II, build in requirements for governance: independent directors, risk/compliance functions, internal audit, strict management of IT risks and cybersecurity. The tech stack should support the investor qualification process, record retention, an end-to-end audit trail and modularity for new jurisdictions.

COREDO practice: cases and figures

e‑residency in Estonia and speed‑to‑market

One of the recent projects included registration via e‑residency, preparation of documents for ECSP and integration of a KYC/KYB provider within 8 weeks. Licensing timelines took 4.5 months, first listings: in the 6th month. Key lesson – early setup of origin of funds verification and a transparent limits logic for non‑sophisticated investors.

Lithuania ECSP license: ROI growth +25%

In Lithuania the platform faced a high number of “false” AML alerts and payment delays. After implementing risk scoring models, alerts tuning and updating policies under AMLD VI the average processing time decreased by 38%, and investor conversion increased. Over a 9‑month horizon ROI grew by 25% due to reduced operational losses and faster funds turnover.

Cyprus: corporate substance and accounts

For a client with a Cyprus structure we built corporate substance: local management, an office, job descriptions and SLAs with providers. This enabled opening accounts at a European bank and PSP without additional requests. As a result the client avoided no‑banking risk and launched cross‑border operations on time.

Financial model and platform metrics

ROI, CAC, LTV, ARR and stress‑testing

I recommend evaluating ROI including the cost of compliance and banking infrastructure. CAC should include identity verification and KYB procedures, and LTV should reflect the depth of investor engagement taking into account limits and tests. A platform’s ARR grows sustainably when compliance doesn’t slow onboarding. Financial modeling and stress‑testing should account for bank outages, spikes in alerts, sanctions updates and anomalous outflows.

Costs, timelines and regulatory roadmap

Realistically plan 3–6 months for ECSP and 6–12 for MiFID II‑CIS. Allocate budget for RegTech integration, smart‑contract audit (if applicable), annual compliance audit and training. The regulatory roadmap should cover whitepaper approval under MiCA 2026, the ESMA audit package and potential expansion into Poland via SPI/NPI if payment flexibility is required.

COREDO Launch Roadmap

Jurisdiction audit: whitepaper approval

We start with a regulatory audit of the jurisdiction: comparing Estonia, Lithuania, the Czech Republic and Cyprus by substance, timelines, banking accessibility and supervisory nuances. Next we form the licensing architecture: ECSP vs CIS, MiCA tracks, EU P2P lending rules and investor protection rules. For tokens we prepare the whitepaper structure and the notification/approval process, assembling an ESMA-compatible disclosure package and policies under AMLD VI.

RegTech integration and compliance audit

Next: integration of RegTech providers for KYC/KYB, sanctions screening, transaction monitoring with AI and automated origin-of-funds verification. We set up FIU reporting, escalation procedures and alert quality control. Finally we approve a schedule of regular audits, including an annual compliance audit, cyber risk tests and updates in line with EBA/ESMA guidance.

Frequently asked client questions and my answers

  • ECSP vs CIS: when which? If you are within €5 million per project and do not sell complex instruments, ECSP is usually more efficient. For an extended product line and underwriting, we look towards MiFID II‑CIS.
  • How long will licensing take? In most of our ECSP projects: 3–6 months, and the general market range is 2–12 months depending on the model and jurisdiction.
  • How to reduce AML risks when scaling? Build KYC tiers, implement risk scoring, automate origin of funds and keep AI monitoring on a short leash with clear rule configuration.
  • How to account for taxes and VAT? For marketplaces the IOSS scheme is useful, and the tax agent model simplifies collection and remittance. Build this into the payments architecture from the start.

Additional aspects often overlooked

  • Registration through e-residency in Estonia speeds up preparation, but substance tests are still required.
  • CySEC requirements for a prospectus can apply even to seemingly “simple” offers: analyze the format and method of placement.
  • The CNB in the Czech Republic scrutinizes governance in detail; prepare independent functions and the role of the board of directors.
  • CIS under MiFID II for investment platforms will require more capital and mature IT security, take this into account when planning.
  • Compatibility of DeFi with centralized control points is key to ensuring the project is regulatorily viable and can pass audits.
  • Passporting and EU cross-border services work better when there are banking relationships and backup PSPs: this reduces operational risk.
  • An origin-of-capital audit before listing the project on a platform saves weeks on subsequent checks and prevents reputational risks.

Conclusions

Launching and scaling an investment platform in the EU: it’s not a race for speed, but discipline in the details. Crowdfunding regulation in the EU via ECSP, its connection to MiFID II and the forthcoming impact of MiCA provide clear rules of the game, but require a compliance, technology and banking infrastructure design planned in advance. I see how a well-structured compliance setup doesn’t slow the business but accelerates it: banks open accounts faster, regulators place more trust, investors return more often.

The COREDO team has gone this route with clients in Estonia, Lithuania, the Czech Republic, Cyprus and Poland. We don’t look for shortcuts: we build robust structures that withstand ESMA audits, EBA requirements and AMLD VI updates. If you are planning a platform based on ECSP, want to understand where and how to connect MiFID II, assess the impact of MiCA 2026 or prepare RegTech integrations for scaling: I’m ready to discuss your case. At the core of a successful project lies an honest risk assessment, a clear strategy and careful implementation. This is what I propose to do together with COREDO.

Multi-level ownership structures in the EU: how I design sustainable holdings that meet compliance requirements and scale

Since 2016 I have run COREDO as a practicum for creating and developing international companies. Each new project confirms: multi-level holding structures in Europe give businesses flexibility, tax predictability and asset protection, but require impeccable compliance discipline. I see entrepreneurs from Europe, Asia and the CIS come for international registration and licenses, and leave with working operating models where UBO transparency, economic substance and risk management are built into the group’s DNA.

Our experience at COREDO has shown that the structure strategy matters more than the choice of jurisdiction. The market is changing under the influence of BEPS and ATAD, AML directives 5AMLD/6AMLD, DAC6 and CRS/FATCA. I embed these frameworks into the ownership architecture from day one, because the legal risks of multi-level ownership manifest not at the moment of registration, but at the stage of bank onboarding, licensing, M&A and profit distribution. Below: a practical system that I use in projects with the Czech Republic, Slovakia, Cyprus, Estonia, EU countries in general, the United Kingdom, as well as Singapore and Dubai as international hubs.

Why businesses need multi-level holding structures

Illustration for the section «Why businesses need multi-level holding structures» in the article «Multi-level ownership structures in the EU – permissible limits»

Multi-level holding structures in Europe serve several purposes: asset protection, tax planning taking into account anti-abuse provisions, access to capital and licensing, risk management and segregation of functions. When I evaluate the economic benefit of a multi-level structure, I look not at theory but at economic effect: reduction of the overall tax burden within the law, lowering regulatory costs per unit of turnover and increased financeability of the business. Such an ROI assessment when creating a holding in Europe is built on value creation drivers: bank and provider fees, audit and reporting costs, speed of approvals, liquidity and distribution of dividends within the holding.

There are limitations on the use of offshore companies in ownership chains, and I accept them as a given: many banks and regulators block access to services when there is an offshore intermediate link. The cost of maintaining multi-level companies in the EU is higher than for single-level ones, so I always carry out a cost‑benefit analysis of creating an additional layer. It is important for me to set scalability metrics and growth criteria for the structure: when a new layer improves manageability, reduces risks and opens markets, and when it only creates costs and the risk of loss of control as ownership layers increase.

Limits of layers and permissible ownership levels in the EU

Illustration for the section «Limits of layers and permissible ownership levels in the EU» in the article «Multi-level ownership structures in the EU – permissible limits»

There is no single formal limit in Europe on the depth of corporate structures, but the limits of ownership layers of legal entities are determined by other regulatory mechanisms. Permissible limits of multi-level ownership in the EU are in practice set by the rules of substance over form, economic substance requirements and economic nexus criteria. The depth of corporate structures in Europe is limited where there is no real substance: an office, staff, independent directors, functions and risks confirmed by service agreements and intercompany agreements.

Place of effective management and the management and control test for holdings remain key factors of tax residency. I design board meetings, signatures, treasury management and document flow so that the place of effective management does not conflict with the declared residency. The EU has a ban on bearer shares, and control over letterbox company and shell company criteria and indicators has been strengthened: registrars and banks detect artificiality by desk presence requirements, the absence of payroll and duplicate nominal functions.

Transparency of UBO, RBO and management of beneficial control

Control of ultimate beneficiaries in complex structures is not a formality but the foundation for access to bank accounts and licenses. UBO transparency and multi-level groups are now tightly linked to the beneficial owners register (RBO) and public registers: beneficial ownership thresholds in the EU usually start at 25%, but banks often require disclosure of the full ownership chain up to the ultimate beneficial owner. I use chain-of-ownership mapping and ownership visualization to eliminate «blind spots» before signing the first banking questionnaire.

The COREDO team implements beneficial ownership verification services, a digital audit trail and blockchain for traceability where it increases counterparties’ confidence. CRS and the automatic exchange of information about owners, as well as CRS/FATCA interaction and disclosure risks, require pre-establishing the UBO position and tax residency. We comply with data protection when exchanging beneficiary data and prepare country-by-country reporting (CbCR) and profit transparency for international groups where applicable.

Tax rules: BEPS, ATAD, CFC, DAC6 and anti-abuse

Illustration for the section «Tax rules: BEPS, ATAD, CFC, DAC6 and anti‑abuse» in the article «Multi‑level ownership structures in the EU – permissible limits»

BEPS and the implications for multi‑level structures manifest through ATAD and the EU anti‑avoidance rules, controlled foreign company (CFC) rules and the impact on residents of different countries. Applying CFC rules to multi‑level structures requires justification of the allocation of functions, risks and assets; I record this in intercompany agreements and transfer pricing documentation. I eliminate hybrid mismatch rules and tax traps at the design stage to avoid double non‑taxation or double taxation.

Double tax treaties and anti‑abuse provisions provide legal opportunities to optimise dividend withholding tax and payment planning, but create treaty shopping risks in multi‑level ownership. I do not permit schemes that look like treaty shopping and prefer transparent economics in agreements. The impact of DAC6 on multi‑level structures and mandatory disclosure rules and reporting means that the adviser must pre‑qualify “hallmarks” and ensure legal certainty. The solution developed at COREDO includes preliminary memoranda and pre‑transaction legal opinions to reduce the likelihood of disputes and provide legal certainty.

AML framework: 5AMLD/6AMLD, KYC/CDD/EDD and sanctions
anti‑money laundering and multi‑level schemes in the EU have moved to a risk‑oriented supervisory approach. KYC and CDD requirements for subsidiaries deepen with each level of ownership, and enhanced due diligence (EDD) for complex chains is the standard when there are non‑resident links. At the same time banks and providers apply PEP screening for politically exposed persons, sanctions screening and automation of controls, as well as transaction monitoring in multi‑level chains.

The group framework is particularly important: group‑wide AML policy and standards, compliance control through the group’s internal policies and internal audit provide a predictable compliance profile. AML supervisory authorities and national practices differ somewhat, but COREDO’s practice confirms: a unified governance framework reduces the risk of de‑risking banking relationships and increases access to financial services. Sanctions compliance and the response of the corporate network have already become a regular task, and I build contingency procedures at the holding level so as not to halt business processes in the event of external restrictions.

Directors, nominee services and liability

Illustration for the section «Directors, nominee services and liability» in the article «Multi‑level ownership structures in the EU – permissible limits»

Nominee directors and nominee shareholders are permissible in Europe within narrow limits, but nominee arrangements: the legal and risk aspects require caution. Fit and proper tests for directors and nominees in regulated segments (payment services, forex, crypto, investment firms) are becoming ever stricter. I rely on fiduciary duties and directors’ liability and do not use nominee solutions as a disguise for control, as this leads to piercing the corporate veil and precedents confirm the risks.

corporate governance in multi‑level groups: it is not an org chart, but a practice. I build a governance framework for multi‑level groups with regular meetings, a matrix of authorities, related‑party policies and treasury management. Regulatory enforcement: fines and enforcement measures in the EU and the United Kingdom have increased, so the reputational profile is more important than any short‑term savings; reputational risk assessment for complex schemes has become a mandatory stage of COREDO projects.

Structure tools: SPV, trusts, foundations and escrow

The use of SPVs and special purpose entities in structures is appropriate for basic risk isolation: an M&A deal, bond issuance, project financing. A combination of trusts and companies in multi‑level schemes is also possible, but I carefully compare trust vs foundation: the choice for asset protection has tax and regulatory consequences. Foundations in civil law jurisdictions play a different role from trusts; sometimes a foundation in Liechtenstein or the Netherlands provides predictable succession and independent management.

A trust protector and trust governance add a level of control but require a high‑quality legal infrastructure and UBO transparency for banks. In transactions I use escrow and protective mechanisms to minimise settlement risks and ensure the transfer of assets on the agreed terms. In some countries there is ring‑fencing and national restrictions on holdings, so I take local firewall rules for regulated assets into account in advance.

Design and registration: steps, jurisdictions, restructurings

Illustration for the section «Design and registration: steps, jurisdictions, restructurings» in the article «Multi‑level ownership structures in the EU – permissible limits»
company registration in the EU through a holding provides advantages in managing dividends and capital if the economic substance confirms the reality of the group. In Estonia we often use e‑Residency and EU business registration, combining it with an operational team in the Czech Republic or Slovakia and a holding in Cyprus with sufficient substance. In the United Kingdom and Singapore I consider the place of effective management when running the group so as not to create competing residency, and in Dubai I structure SPVs and regulated links with regard to local substance.

Cross‑border restructuring: legal steps include redomiciliation, cross‑border merger, migration of legal entities within the EU and restructuring of debts and equity. Before M&A the COREDO team conducts M&A Due Diligence for multi‑level purposes, prepares pre‑transaction legal opinions and checks obligations

Matters relating to DAC6 and ATAD. In international disputes I rely on forensic accounting and asset tracing in international disputes and on mechanisms of mutual legal assistance and cross-border investigation.
Financial model: liquidity, dividends, exit and repatriation

Liquidity and the distribution of dividends in a holding require not only tax planning but also operational treasury. I model dividend flows, interest and royalties in advance, taking into account the dividend regime, WHT and substance requirements. Exit strategies and profit repatriation depend on double tax treaties, anti‑abuse provisions and country‑by‑country reporting, as well as on how service agreements and transfer pricing are structured.

Compliance costs vs economic benefit: my ongoing benchmark. The holding’s operating expenses and scalability metrics should decrease relatively as the business grows; if this does not happen, the structure is obsolete. The COREDO team regularly reviews the cost‑benefit and proposes cross‑border restructuring or simplification of ownership levels to maintain efficiency.

Technologies and compliance control

KYC digital identification and e‑KYC reduce frictions in onboarding if a correct set of UBO and source of funds evidence is established. Beneficial ownership verification services, sanctions screening and control automation, as well as transaction monitoring in multi‑level chains increase compliance throughput. I implement compliance control through group internal policies, internal audit and independent oversight of the structure, as well as a digital audit trail for decision transparency.

Mutual recognition and regulator cooperation simplify Licensing when the group complies with unified reporting and AML standards. The COREDO team implemented a centralized repository for transfer pricing documentation, intercompany agreements and corporate protocols; this speeds up responses to requests from banks and regulators. This approach reduces the risk of blocks and simplifies access to payment providers, EMIs and banks in the EU, the UK, Singapore and Dubai.

COREDO cases: how it works in practice

For a payments group seeking an EMI license in the EU we designed a two‑tier holding with an operating company in Lithuania and a sub‑service‑centre in the Czech Republic. The solution developed at COREDO ensured economic substance requirements in European jurisdictions, evidenced by staff, offices and independent directors. We conducted a fit and proper check, built a group‑wide AML policy, carried out a DAC6 assessment and eliminated treaty shopping, and the bank approved onboarding without additional conditions.

For a crypto broker applying for a VASP license we built a structure with an SPV in Dubai and an operation in Estonia, where e‑Residency sped up the registration stage. I took into account the management and control test and place of effective management to avoid creating residency conflicts, and ensured EDD on beneficiaries and sources of funds. Sanctions and PEP screening we covered with an automated framework, and transaction monitoring was tuned to the jurisdictions’ risk profile.

For an investment group with assets in multiple EU countries and the UK, we carried out a cross‑border restructuring, replacing the outdated, overloaded nominee arrangements setup with a managed holding with a transparent UBO. Legal support for the holding networks included updating RBO, CbCR, transfer pricing, as well as preparation for possible asset tracing and mutual legal assistance in case of dispute. As a result, compliance costs decreased, dividend distribution accelerated and access to banking services improved after a period of de‑risking.

Role of providers and the team

The roles of corporate service providers when creating layers are critical: registration, company secretary services, licensing, audit and taxes must work in synchrony. At COREDO I bring together lawyers, tax advisers, AML officers and project managers into a single team so the client receives a holistic solution. We maintain compliance control, train directors on their fiduciary duties and build processes that withstand regulatory enforcement and legal scrutiny.

Limitations on the level of company ownership in the EU are shaped not by formal limits but by the risk profile: the more layers, the higher the likelihood of document errors, payment delays and questions from banks. I set the minimally sufficient number of levels and fix it in the governance documents so the structure remains manageable. This approach increases business continuity and risk management in the holding, as well as improves legal certainty.

Practical checklist: how to go through the process without mistakes

  • Goals and ROI

    • Formulate the economic goals and metrics: estimated ROI metrics for the ownership structure, scalability metrics, maintenance costs and the expected effect.
    • Conduct a cost‑benefit analysis of creating an additional level and a stress test for the risk of loss of control.
  • Tax architecture

    • Check BEPS/ATAD risk factors, apply CFC and hybrid mismatch rules, eliminate treaty shopping risks.
    • Prepare transfer pricing documentation, intercompany agreements and service agreements for real substance.
  • Residence and substance

    • Document the place of effective management, the management and control test, economic nexus and desk presence requirements.
    • Confirm economic substance requirements: office, staff, independent directors, local contracts and payments.
  • UBO and transparency

    • Set up chain of ownership mapping, RBO updates, beneficial ownership verification services.
    • Ensure CRS/FATCA compliance, CbCR (if applicable) and data protection.
  • AML and sanctions

    • Implement a group‑wide AML policy, KYC/CDD/EDD, PEP and sanctions screening, transaction monitoring.
    • Take into account national AML supervisory authorities and practices, set up internal audit.
  • Licensing and personnel

    • Check fit and proper for directors, avoid controversial nominee arrangements, and train on fiduciary duties.
    • Prepare pre‑transaction legal opinions and a DAC6 assessment.
  • Operations and banks

    • Test payment scenarios, liquidity, dividend withholding tax and double tax treaties.
    • Reduce the risk of de‑risking through transparent documentation and a single repository.
  • Restructuring and exit

    • Prepare a plan for cross‑border restructuring, M&A due diligence, escrow mechanics.
    • Formulate exit strategies and profit repatriation taking into account anti‑abuse provisions.

What complicates life and how I handle it

Cross-border holdings and tax consequences always carry uncertainty if the structure “lives” on paper. I avoid letterbox company by signs of sham and create a real footprint of activity in key points: contracts, risks, personnel, reports. impact of sanctions and freezes on multi-level networks I mitigate through alternative banks, providers and geographic diversification, as well as through sanctions procedures at the group level.

Nominee directors и номинальные акционеры иногда кажутся быстрым решением, но юридические и репутационные риски перевешивают выгоду. Вместо этого я формирую совет с квалифицированными резидентными директорами, прохожу fit and proper тесты и закрепляю ответственность через внутренние политики. В спорных кейсах я готовлю доказательственную базу на случай piercing the corporate veil и судебных разбирательств: протоколы, делегирование полномочий, казначейские политики.

Where this is especially important: licensing and international hubs

For licenses (crypto, banking, forex, payment services) regulators emphasize substance, risk management and UBO transparency. In the EU and the UK attention goes to AML, governance and capital adequacy, while in Singapore and Dubai – to risk management and technological control. The COREDO team supports licensing, sets up mandatory disclosure, prepares responses to inquiries and builds communication with regulators to accelerate mutual recognition and simplify onboarding.

In projects with the Czech Republic, Slovakia, Cyprus and Estonia I combine tax and regulatory advantages with real substance. For groups with international exposure I use separate SPV by lines, take into account ring‑fencing and national restrictions on holdings, and also arrange centralized internal audit. This approach ensures predictable taxation, access to accounts and readiness for inspections.

Conclusion: an architecture of trust and growth

Multi-layered ownership structures are a tool, not an end. When I design a holding, I build an architecture of trust: transparent UBO, sufficient substance, predictable taxes, a manageable AML framework and clear corporate governance. COREDO’s practice confirms: such a structure gives the business scalability, reduces the cost of capital and opens doors to licenses and banks.

If you plan to register companies in the EU through a holding, aim for licensing or are preparing M&A, lay the foundation from the start: substance over form, a clear ownership chain and risk control. The COREDO team has implemented dozens of projects in the EU, the UK, Singapore and Dubai, and I continue to develop an approach in which legal certainty, economic efficiency and compliance go together. This is the reliable path to sustainable international growth.

I regularly hear the same question from entrepreneurs: how to launch BNPL in Europe and the United Kingdom so that regulators support the model and the unit economics don’t fall apart? Since 2016 the COREDO team has been helping businesses register legal entities in the EU and Asia, obtain financial licences, build AML compliance and enter new markets without pauses in operations. During this time we have run dozens of “buy now pay later” projects and can see how quickly BNPL regulation is changing in Europe and the United Kingdom.

In this article I have put together a practical guide: from choosing a jurisdiction and structure to suitability/unsuitability algorithms, integration with credit bureaus and preparation for the FCA’s BNPL requirements for 2026. I deliberately use plain language and provide specifics from our practice so that you can make decisions as soon as tomorrow.

Changes in the market and regulatory framework

Illustration for the section «Changes in the market and regulatory framework» in the article «Licensing BNPL models in the EU»

BNPL regulation in Europe is becoming stricter due to the EU Second Consumer Credit Directive, which expands coverage to small loans and installment plans. This means tougher requirements for creditworthiness assessment, tariff transparency, disclosure of terms and the procedure for transferring data to credit registers. National competent authorities for BNPL in the EU: Finantsinspektsioon (FI) in Estonia, KNF in Poland, the Central Bank of Cyprus and, in some entities with an investment component, CySEC. We take into account that the directive’s rules are mandatory, while enforcement practices and thresholds are national.

In the United Kingdom, BNPL authorization United Kingdom is handled by the FCA. Expected are FCA BNPL requirements in 2026, including affordability and unsuitability tests, financial promotion rules and reporting.

For me, there’s one key trend: compliance has stopped being a «costly add-on»: it has become a product feature and a competitive advantage. The solution developed at COREDO is usually built around the principle «compliance‑by‑design»: KYC, AML and suitability processes are embedded in the sales funnel rather than bolted on.

Jurisdictions and models: where to get a license

Illustration for the section «Jurisdictions and models: where to get a license» in the article «Licensing BNPL models in the EU»

I often suggest starting with two basic scenarios: Licensing BNPL in the EU via Estonia or Cyprus, or a focus on Poland when planning active localization. This is not a universal truth, but COREDO’s practice confirms: this makes it easier to balance speed of launch, substance requirements and the possibility of cross‑border expansion.

  • BNPL financial license — Estonia. Estonia provides a clear dialogue with FIs, developed open banking practices and a mature e‑government infrastructure. With proper preparation, a cross‑border BNPL license from Estonia and Cyprus allows entry into 5–10 EU countries with minimal fine‑tuning. At the same time, you need to take into account local “threshold” exemptions and notifications.
  • Cyprus. For classic BNPL without investment instruments, supervision is carried out by the Central Bank of Cyprus. A CySEC BNPL license in Cyprus comes into play when the structure includes an investment component (for example, a credit fund, portfolio securitization or the use of investment intermediaries). The COREDO team has implemented several projects where coordination with both regulators was required.
  • Poland. KNF BNPL regulation in Poland is among the most demanding when it comes to pricing transparency, financial promotion and PKD/activity codes. For merchant platforms the Polish market delivers high conversion, but requires thoughtful localization and integration with local registers.
  • United Kingdom. Authorization focuses on consumer lending and financial promotion. The Temporary Permissions Regime (TPR) for BNPL is currently available in a limited way, effectively for companies that entered the regime earlier or acquire a business already in TPR. COREDO practice: parallel registration and application to the TPR is possible in an M&A structure, which minimizes downtime when entering the UK.
When choosing a jurisdiction, I always look at three axes: regulatory certainty, capital threshold and substance requirements. A BNPL license to enter 15 EU markets and further scale is realistic if based on: a unified compliance architecture and a well‑thought legal strategy of «passporting + local notifications».

Registration of a legal entity and substance tests

Illustration for the section «Registration of a legal entity and substance‑tests» in the article «Licensing BNPL models in the EU»

legal entity registration for BNPL in the EU is not a formality. Regulators check substance requirements when registering a legal entity in the EU: the presence of a local office and staff for the license, economic activity, and that key decisions are made on the territory. I plan in advance:

  • a physical office and SLAs with providers, confirming operational resilience;
  • specialized staff: MLRO/Compliance Officer, Risk, Head of Operations;
  • a local board of directors with relevant expertise and an independent director.

The structure of the charter and activity codes is critical. In Poland, correctly choosing PKD/activity codes for BNPL providers is part of licensing and subsequent inspections. In the EU we use NACE, but I always coordinate the wording with the local lawyer and the regulator to avoid discrepancies. For Cyprus and Estonia we assess transfer pricing and tax aspects in advance when registering in Cyprus/Estonia so that the chain of commissions and intercompany payments does not raise questions.

Documents for Cyprus and Estonia licenses

Illustration for the section «Documents for Cyprus and Estonia licenses» in the article «Licensing BNPL models in the EU»

What documents are needed for a BNPL license in Cyprus and Estonia? The set is similar, but there are nuances:

  • Incorporation documents, ownership structure, beneficiaries, group chart.
  • Policies: AML/CFT, KYC and Due Diligence for BNPL, EDD for high-risk cases, sanctions and PEP screenings for BNPL providers.
  • Assessment of BNPL customers’ creditworthiness: affordability methodologies, analysis of suitability and unsuitability for BNPL customers, decline procedures.
  • IT and security: operational controls, SLAs, RTO, RPO for the BNPL platform, BCP/DR plans and tests.
  • Product model: rules for customer disclosures and BNPL contract templates, regulations limiting hidden fees and transparency of payment schedules.
  • Finance: business plan, requirements for capital reserves and financial resilience, stress tests.
  • Reporting: how to build a roadmap for integration with credit registries, data quality control and compliance with reporting formats.

In Estonia the FI analyzes decisioning engines in detail, including automated decision-making systems (decisioning engines) for suitability. In Cyprus the regulator pays a lot of attention to governance and the role of independent directors. Our experience at COREDO has shown: a strong documented risk management model and a clear IT architecture speed up the dialogue and reduce the number of rounds of questions.

I — EU directive on credit for BNPL

Illustration for the section «I — EU directive on credit for BNPL» in the article «Licensing BNPL models in the EU»

The EU Second Consumer Credit Directive and BNPL: this is about expanding the scope of regulation. The directive requires:
  • an assessment of creditworthiness based on sufficient data, not only the customer’s statements;
  • transparency of pricing and a ban on hidden BNPL fees, clear APR equivalents where applicable;
  • debt limits and BNPL consumer protection, the right of withdrawal and standardized pre-contractual forms;
  • the transfer of data to credit registers and frequent reporting, including adverse events.

National exemptions and turnover thresholds for licensing exemptions exist, but I consider them a temporary solution. Exemption from licensing for small BNPL providers can help at the MVP stage, but scaling will inevitably require a full license and a review of processes.

FCA and TPR: financial promotion 2026

How to use TPR to minimize downtime when entering the UK? The scenario we applied: acquiring a company with an active TPR and simultaneously applying for our own authorization. Plus, market access with controlled risk; minus — thorough legal due diligence and systems integration. COREDO practice: parallel registration and TPR application during M&A reduced the client’s time-to-market by 6–8 months.

How will the FCA implement the unsuitability test from 2026? The draft rules focus on identifying groups of customers for whom a product is clearly unsuitable, even when affordability is positive. This includes age, social and behavioral markers, as well as patterns of ‘repeat missed payments’. FCA reporting requirements and the format of monthly summaries are another axis: detailed metrics on defaults, restructurings, vulnerable customers and the effectiveness of early intervention.

Rules on financial promotion for BNPL and liability for advertising will become stricter. I recommend implementing a two-tier review of promotional materials: legal and behavioral (fairness). This reduces the risk of claims for ‘misleading promotions’ and ensures a sustainable funnel.

Credit reporting: CRA and algorithms

Our team always includes integration with Credit Reference Agencies in the roadmap. Integration with Credit Reference Agencies and the transmission of BNPL transactional data to Credit Reference Agencies: a standard without which no regulator will give the “green light”. For the EU we use national bureaus and banking registers, in the UK: Experian, Equifax, TransUnion.

Open banking and PSD2 for assessing buyers’ incomes speed up checks and increase the accuracy of affordability. We apply debt burden monitoring and DTI for BNPL, taking into account external indebtedness and income seasonality.

How to prepare unsuitability and affordability algorithms? I build a hybrid: rules (policy‑based) + ML scoring, where ML is explainable and auditable. Credit history checks and scoring of BNPL borrowers are not a “black box”: regulators expect clear “reasons codes” for refusals.

API integration with credit bureaus and monthly reporting require mature data quality. I define the data owner in advance, SLA for fixing errors, reconciliation procedures and automatic alerts for discrepancies. Data quality control and compliance with the reporting format save months of correspondence with the regulator.

AML/KYC in the product funnel

AML compliance for BNPL providers: it’s not just screening. Integrating AML KYC into the BNPL product funnel increases conversion if made intuitive.

  • KYC and due diligence for BNPL with risk scanning and dynamic verification levels;
  • enhanced due diligence (EDD) for elevated AML risks;
  • sanctions and PEP screenings for BNPL providers with a triage process and manual verification;
  • KYB procedures for partner merchants (merchants) and monitoring of their transactional activity.

The legal bases for the transfer of personal data and GDPR in BNPL are covered by a combination of legitimate interest, performance of the contract and regulatory obligations. The COREDO solution includes a DPIA matrix and registration of processing purposes so that GDPR questions do not slow down market entry.

Consumer protection and fair pricing

Regulators pay close attention to how you explain costs and risks to the customer. Pricing transparency and a ban on hidden BNPL fees, a clear payment schedule, automatic reminders: the basic minimum. I add monitoring for repeated delinquencies and early-intervention mechanisms: offering a “payment holiday”, reducing limits, personal contact.

Customer disclosure rules and BNPL contract templates should undergo legal and behavioral review. National competent authorities assess not only the content but also the format: readability, the presence of key facts on a single page, warnings about risks. Regulatory compliance works as a competitive advantage for scaling when these principles are built into the product.

Partnerships between Marketplaces and Merchants

BNPL solutions for marketplaces and partner networks provide rapid scale but entail contractual risks. Negotiating terms with partner marketplaces and contractual risks include questions of allocation of responsibility for KYC/KYB, returns, chargebacks and marketing commitments. I recommend a responsibility matrix and a single playbook for promo materials to avoid being fined because of someone else’s advertising.

KYB procedures for partner merchants and anti-fraud procedures protect the portfolio from suspicious sellers. Document verification and anti-fraud procedures, including behavioral biometrics analysis and device fingerprinting, significantly reduce fraud levels without loss of conversion.

Timing, budget and ROI

Timing for obtaining a BNPL license in key jurisdictions varies. In Estonia: 4–6 months with a fully prepared package, in Cyprus: 4–8 months depending on the structure. Case: registration of a legal entity in Cyprus and obtaining the license in 4 months was made possible thanks to early agreement on governance, the completeness of the IT dossier and a ready plan for integration with registries.

The estimated budget for obtaining a BNPL license (lawyer, compliance, capital) includes legal preparation, IT and risk-function audits, initial capital and 6–9 months of operational runway. The cost of compliance and payback periods depend on the distribution channel: marketplaces have lower CAC. How is licensing ROI calculated (examples 250%–300%)? We take the margin on the portfolio, discount cancellations/defaults, and subtract the full cost of compliance and reserves.

How to calculate the breakeven point after obtaining a license — a question about the share of active users, average basket size, take‑rate and cost of funding. I factor in stress scenarios and seasonality.

KPI metrics: repayment rate 99%, early repayments 40% as a benchmark are possible with proper segmentation and early intervention. Questions for the manager: which KPIs should be tracked when launching BNPL in the EU? Retention, NPL 30+/90+, DTI by segments, CAC/LTV, average number of active merchants, integration speed, onboarding SLA, share of “clean” auto-approvals.

Reducing legal and reputational risks

Legal risks of BNPL and potential fines for non‑compliance with the Consumer Credit Directive in the EU and FCA guidance in the UK are significant. Grounds for refusal to grant a BNPL licence and avenues for appeal include insufficient substance, weak governance, an opaque ownership structure, and a leaky IT‑perimeter. We prepare a remediation plan, as well as licence‑refusal scenarios and wind‑down/redemption plans to protect customers and partners in stress‑scenarios.

risk management of BNPL and debt‑burden stress‑tests are a mandatory part of the risk‑framework. Methodologies for calculating stress‑tests for an instalment portfolio take into account rising unemployment, inflation, conversion declines and tightening credit policy. Managing reputational risks as a BNPL portfolio grows requires transparent communication, compliant advertising and clear complaint handling.

Collection strategies and the management of collections agencies I build in a “human‑centric” logic supported by regulators. First, soft reminders and restructuring offers, then escalation according to a clear script that does not violate consumer rights.

Scaling from Asia to the EU and 5+ markets

Scaling BNPL from Asia to the EU: the practical steps are quite pragmatic. Legal due diligence when entering the EU, choosing a core jurisdiction (Estonia or Cyprus), assessing cross‑border feasibility, coordination with national regulators and a timeline of local notifications. Practical steps for scaling BNPL from Asia to 5+ EU countries include a pilot in 1–2 markets, then sequential onboarding of countries on a quarterly cycle.

Passporting restrictions after Brexit and alternatives in the UK, appointment of an Appointed Representative, acquisition of a licensed business or participation in sandboxes. Sandboxes and accelerated access regimes for fintech BNPL provide a chance to demonstrate the model on real data and fine‑tune reporting before full authorization. The influence of national competent authorities on the market entry strategy is obvious: timelines, inspection focuses and consumer protection priorities differ, and this must be accounted for in planning.

Internal control and audit

Organizing internal compliance audit for BNPL is a common practice for financial institutions. I establish an independent function that tests procedures, verifies reporting and checks IT controls. Outsourcing options for compliance and control risks exist, but I prefer a hybrid: a core of competencies in‑house, targeted external support.

Infrastructure requirements: IT security and operational resilience are an integral part of the dossier. Regulators expect RTO/RPO for critical systems, penetration tests, vulnerability management, access segmentation, logging and monitoring. Operational readiness and the launch of BNPL sales depend on the maturity of these processes no less than on marketing.

International benchmarking/self-regulation

International experience: NCCP/ASIC comparison and benchmarking show that Australia has already gone through a tightening of BNPL. I use this experience as an “early indicator” for Europe and the UK, especially regarding reporting to CRAs and limiting “dark pattern” practices in onboarding. Implementing an industry BNPL code and self‑regulation helps build trust with regulators and the market.

Scope of laws: the Consumer Credit Directive, national acts, FCA guidance – the basic triad without which policy cannot be built. I’ll add GDPR, PSD2, AMLD and local advertising laws. This is the minimum I include in the project’s legal map.

COREDO Case Studies and Results

COREDO’s BNPL licensing case studies show that discipline during the preparation phase solves half the challenges. COREDO case: the result — a launch in 5 countries in 6 months — was achieved by building a unified compliance framework, standard API integrations with registries, and contract templates for local adaptation. At the same time, we prepared reporting and trained partner merchants.

A separate project: a large-scale marketplace with a core in Cyprus and an auxiliary office in Prague. We structured the charter and PKD codes for BNPL, implemented open banking integrations, established an unsuitability test for BNPL and early intervention triggers. Result: a repayment rate of 99% and early repayments of 40% as a benchmark in reporting to the board of directors.

Another example — UK expansion through TPR. We prepared a parallel submission for registration and TPR alongside M&A, agreed the FCA reporting requirements and the format of monthly summaries, implemented BNPL financial promotion rules and independent marketing verification. Downtime between deal closing and the start of sales took only a few weeks.

How to obtain a BNPL license in the EU

I complete each project with a detailed roadmap. Schematically it looks like this:

  1. Model and jurisdiction diagnosis
    – Regulation of BNPL in Europe: a map of requirements under CCD II and the UK.
    – “Quick win”: licensing buy now pay later in the EU via Estonia or Cyprus, assessment of cross‑border potential.
  2. corporate structure and substance
    – Registration of a legal entity for BNPL in the EU, substance tests: local office, staff, economic activity.
    – Transfer pricing, tax model, independent directors.
  3. Policies, product and IT
    – AML/KYC, EDD, sanctions/PEP, KYB of merchants.
    – Affordability, suitability and unsuitability test algorithms for BNPL; decisioning engines with explainability.
    – Open banking/PSD2, integration with CRA, reporting format.
    – Operational controls: SLA, RTO, RPO, BCP/DR plan.
  4. Submission and dialogue with the regulator
    – Preparation of a presentation for the national regulator (NCA), demonstrating governance and risk.
    – Responses to inquiries, pilot reporting, adjustments.
  5. Operational readiness
    – Team training, final “war‑games”, launch in the pilot market.
    – Scaling: sequential onboarding of countries, local notifications.
  6. UK‑track (if necessary)
    – Analysis of availability of TPR and/or AR, parallel submission, preparation for FCA BNPL requirements 2026.
    – Financial promotion, reporting, marketing controls.

Customer FAQs: short answers

  • BNPL licensing for fintech startups is possible with a minimal “skeleton” team, but the regulator will require real management and risk functions, not nominal ones.
  • Minimizing risks when scaling BNPL requires a unified compliance architecture and ready-made integration modules for registries.
  • How to prepare a presentation for the NCA? Include the business model, unit economics, governance, IT architecture, a stress-test plan, and a reporting map.
  • National exemptions and turnover thresholds help you start, but they weaken your position when scaling — regulators see that.
  • The consequences of a license refusal and blocked operations are painful. I always prepare a fallback plan and communications for clients and partners.

Comparison of regulators: what to look for

A comparison of CySEC, Estonia’s FI, and the KNF against BNPL requirements shows different emphases. FI delves more deeply into IT and algorithms; KNF focuses on behavioral practices and promotions; the Cypriot regulator emphasizes governance and substance. In the UK, the FCA pays particular attention to vulnerable customers, reporting, and promotional materials. Our experience suggests: readiness for any of these focal areas comes through a single roadmap, strong policies, explainable algorithms, and managed processes.

Why should investors act now?

The availability of market research (Statista forecasts) and an investment rationale are important in dialogue with the board of directors. Consumers are looking for convenient installment plans, and regulators are putting clear frameworks in place. The regulatory landscape is already visible: CCD II in the EU and upcoming FCA rules. Those who build compliance “baked into” the product now will capture the better economics tomorrow.

I often see how calculating the ROI of licensing BNPL changes the tone of the discussion. When a model includes a transparent cost of compliance, capital requirements, integration stacks, stress tests and wind-down scenarios, the decision stops being a risky bet. It becomes a manageable project with a clear payback horizon.

Conclusions

Successful BNPL in Europe and the United Kingdom: it’s a synergy of product, compliance and operational discipline. If you reduce the formula to its essence: a clear jurisdictional strategy, strong substance, explainable affordability/unsuitability algorithms, deep integrations with registries, and transparent communication with customers and partners. The COREDO team has implemented projects where this very formula made it possible to enter 5+ EU markets within six months and complete the UK track without downtime.

I don’t promise “magic buttons”, but I guarantee thoughtful work and an honest dialogue. If you are planning BNPL licensing in the EU, authorization in the UK, or scaling your portfolio, get involved at an early stage. COREDO’s experience confirms: the earlier we build the roadmap and compliance architecture, the faster and safer you’ll enter the market.

Since 2016 I have been developing COREDO as a solutions platform for entrepreneurs who build international financial services, crypto projects, payment companies and holding structures. During this time the COREDO team has implemented dozens of projects in the EU, Singapore, Dubai, the United Kingdom, Estonia, Cyprus, the Czech Republic, Slovakia and Canada, as well as in a number of countries in Asia and the CIS. I have seen how the same mistakes slow down launches, and how a properly assembled roadmap saves months and hundreds of thousands. In this article I will collect the working practices and methodologies that we regularly apply, and answer key questions: company registration abroad, choosing a jurisdiction for fintech, licenses (including MSB for cryptocurrencies and payments), substance requirements, opening a business account in the EU, compliance and AML.

COREDO’s practice confirms: when founders plan regulatory compliance, AML/CTF and banking Due Diligence in advance, the project passes auditors and regulators without unnecessary iterations. I will show how to build this, what to pay attention to and where the risks of bank and regulator refusals lie, and where the areas of highest return on investment (ROI) for licensing are.

Jurisdiction and Structure Selection Matrix

Illustration for the section “Jurisdiction and Structure Selection Matrix” in the article “MSB license outside the EU - when it really works”

A strong structure starts with the right jurisdiction. I always begin with a jurisdiction selection matrix in which we rank countries across six blocks: regulatory regime, cost and timelines, substance requirements, banking ecosystem, tax predictability, sanctions and reputational risks.

  • Regulatory compliance in the EU: clear rules, possibility of passporting for EMIs/PSPs within the EEA, but high expectations for governance and AML.
  • Asia (Singapore): strict but transparent MAS policy; suitable for forex/crypto with mature processes; strong ACRA requirements for disclosure of beneficial owners.
  • Middle East (UAE): free zone company setup is suitable for growth and tax optimization through free zones; sandbox regulatory regimes help quickly test fintech models.
  • United Kingdom and Estonia: a digital ecosystem, fast launch, developed e-residency and digital banking in Estonia; banks meanwhile closely verify proof of address and substance.

I always recommend not skimping on designing the holding structure for asset protection. A holding structure for asset protection may include a European holding company, operating companies in the EU/UAE, and a separate trust for IP. Hybrid structures: Dubai + Poland often provide a balance of tax burden, access to talent and payment infrastructure (in Poland we take into account Poland’s PKD codes for activity classification and NPI/SPI payment schemes).

Registering a company abroad

Illustration for the section «Company registration abroad» in the article «MSB license outside the EU - when it actually works»

Preparing corporate documents for the license and the registration itself: not just collecting certificates. Our experience at COREDO has shown: a clear description of the model, NACE codes for the EU, SIC codes for the UK and PKD codes — are part of the risk assessment for the bank and the regulator. An incorrectly chosen code makes the case «high-risk» in the eyes of compliance. I insist on early alignment: business model → activity codes → licenses → banking profile.

Substance requirements for companies have become the standard. To prove substance, banks and regulators expect:

  • office (lease/contract, photos, floor plan),
  • employees on the payroll with relevant functions,
  • local director (if required by law),
  • existing contracts with clients/suppliers,
  • local accountant and audit (if applicable),
  • a substance plan for 12–24 months.
I discuss the requirement for a local director and its risks with the client separately. A nominee director without actual involvement undermines the risk management logic, and nominee agreements and legal risks can easily lead to a bank refusal. Nominee service and confidentiality are possible, but I structure governance so that actual management and control comply with regulatory expectations and the transparency of the beneficial owner and the register of beneficiaries.

Account opening and due diligence

Illustration for the section «Account opening and due diligence» in the article «MSB license outside the EU - when it really works»

Opening a business account in the EU is not about “filling out a form”. Banks expect a full due diligence checklist: constitutional documents, UBO structure, a business plan for licensing/operational model, evidence of substance, AML/KYC policies, proof of address, contracts with key counterparties. I prepare the client in advance for typical bank requests and for preparing responses: startup costs, sources of funds, turnover forecasts, payment geography, sanctions risks.

Bank refusal incidents and successful account-opening cases show that the reasons for banks’ refusals during onboarding tend to repeat:
  • weak KYC/CDD policy,
  • risk appetite incompatible with client geography,
  • inconsistent UBO and CRS/FATCA documents,
  • insufficient substance and an unconvincing legal opinion for bank due diligence.
The COREDO team systematically reduces risks: we prepare a legal opinion, build due diligence for account opening, set up a sanctions risk matrix when working with clients and EU sanctions screening for bank compliance. We link opening a Swiss account for a holding to a clear cash management model and transparent governance. In the UAE we use free-zone banks and Emirates NBD for operational accounts, and in the EU — a combination of traditional banks and fintech providers (for example, Revolut Business and similar non-bank-licensed providers) as a temporary tool.
Estonia: a separate conversation. Estonian digital bank account opening practices allow you to move faster with e-residency; however, I always warn: e-residency as a way to obtain a bank account is not a guarantee. Banks value substance and the quality of compliance more.

Licensing of money services businesses, virtual asset service providers, payment institutions and foreign exchange providers

Illustration for the section «Licensing MSB/VASP/payment inst./forex» in the article «MSB license outside the EU - when it really works»

Authorization to operate: the central element of your strategy. A solution developed at COREDO for fintech‑companies covers roadmaps and preliminary assessments.

When and how MSB outside the EU and FINTRAC

MSB outside the EU is a practical option for crypto exchanges, payment operators and remitters. How to obtain an MSB in Canada? The Canadian model is FINTRAC MSB registration in Canada, not the classic “license”. MSB FINTRAC requirements include:

  • definition of service types: money transferring, dealing in virtual currency (MSB for cryptocurrencies),
  • appointment of a compliance officer/MLRO,
  • KYC/CDD and enhanced due diligence (EDD) for high‑risk clients,
  • AML/CTF policy, risk assessment, training, independent review,
  • SAR and threshold reports of suspicious transactions (threshold reporting),
  • customer due diligence records retention policy.

Canadian MSB procedural compliance usually takes 3–4 months (MSB registration timeline 3-4 months) with ready policies and IT‑controls. Timing and cost of obtaining an MSB depend on product complexity and geography. I recommend conducting an MSB licensing ROI assessment before launch: a cost‑benefit analysis of licensing and an economic model help understand payback (MSB license ROI: payback calculation) taking into account banking fees, IT integrations and team requirements.

VASP in Estonia: crypto‑AML

VASP in Estonia: this is registration/Licensing of virtual asset service providers with enhanced requirements after the reforms. VASP registration process and requirements include:

  • local office and board, real substance,
  • minimum authorized capital (depending on the model: exchange/custody),
  • appointment of MLRO and compliance officer, approved KYC and KYT (Know Your Transaction) policies,
  • AML monitoring for crypto-to-fiat flows and transaction monitoring systems (transaction monitoring),
  • independent compliance audit and regular reporting.
For crypto projects I implement crypto AML controls: PEP screening and management of politically exposed persons, OFAC and international sanction lists, EU sanctions screening, KYT and case management for SARs and investigations. RegTech integration into AML processes via AML SaaS solutions and integration with core banking dramatically improve manageability. AML program maturity indicators (KPIs) — alert processing speed, share of closed cases without escalation, average time for EDD.

Payment licenses in the EU and the UK

Obtaining a payment license in Lithuania (Lithuania payment institution regime and requirements): a popular route for PI/EMI: clear capital requirements for payment institutions, a regulator open to innovation and the possibility of passporting across the EEA (passporting vs local licence: when it is advantageous). In Cyprus CySEC oversees forex/CFD (CySEC forex), while the Central Bank of Cyprus decides on PI/EMI; the combination is useful if you are building a brokerage and payments stack.

The UK is traditionally strong in PSP, but banks are stricter about cross‑border payments. I include proof of address and a substance plan in the roadmap, as well as cross‑border payments flows and AML requirements for correspondent banking relationships and their limitation.

Singapore MAS license for forex and crypto

Singapore is a compliance benchmark. The MAS license for forex and crypto requires well‑thought governance, IT‑controls and risk management. Singapore MAS licensing timeline and requirements depend on the license class: for DPT (crypto) and e‑money — a longer fit‑and‑proper check; for capital markets services — a focus on operational risks. ACRA requirements for beneficiary disclosure and a strict reporting culture set a high bar, but allow building a business for Asia with a strong reputation.

Banking licenses: capital adequacy

If your goal is a bank or a large EMI, I discuss Basel III and the calculation of capital adequacy. Capital adequacy under Basel III for banks: the foundation that determines risk‑weights of assets and capital buffers. The timeline for submitting to the CNB for a banking license (Czech National Bank) is usually 12–18+ months. For EMIs and PSPs: separate requirements for capital and internal controls, including liquidity stress tests, the ICAAP/ILAAP procedure and an independent internal audit.

How to build a working AML/CTF program

Illustration for the section «How to build a working AML/CTF program» in the article «MSB license outside the EU - when it really works»

Compliance and AML for MSBs, PSPs and VASPs are not a set of documents but an operating system. I build the program around FATF recommendations, EU directives and local rules.

  • KYC/CDD policies compliant with FATF: risk-based approach, customer segmentation, triggers for EDD.
  • Transaction monitoring for payment services: scenarios, thresholds, behavioral patterns; AML risk scoring model for PSPs.
  • SAR/STR, transaction limits, CTR and threshold reporting: alignment with local laws (for example, 10,000 as an operational threshold in some jurisdictions).
  • Whistleblowing compliance and internal procedures: protected channels, investigations, lessons learned.
  • The role of the MLRO and compliance control functions: independence, access to the board of directors, regular reports.
  • Compliance program maturity model for ranking: from «ad‑hoc» to «optimized», with KPIs and an improvement roadmap.
  • Customer due diligence records retention policy: retention periods and reliability of registers.
  • Integration of AML monitoring with payment rails: core events of the payment platform, sanctions APIs, geolocation and device fingerprinting.

The COREDO team implemented AML SaaS solutions and RegTech integrations for companies with intensive P2P and merchant payment flows. As a result, the false-positive rate decreased, alert handling sped up, and regulatory inspections became predictable.

Sanctions, tax and corporate requirements

Assessment of sanctions risks during registration, a mandatory section. I use a jurisdictional risk assessment matrix to choose a jurisdiction and a sanctions risk matrix when working with clients: we cross-check OFAC, EU, UN lists, as well as media risks. Managing sanctions restrictions in international operations includes regular updates of lists, backtesting of transaction samples, and training.

CRS information exchange between tax jurisdictions and FATCA reporting requirements – a standard for banks and EMIs. I verify compliance with the UBO structure: transparency of the beneficial owner and the beneficiaries register, ACRA/EU disclosure, EU Directive 2017/1132 requirements for articles of association (objectives, capital, governing bodies).

In Poland we take into account PKD, in the EU: NACE, in the United Kingdom: SIC — correct codes are important for banks’ risk rating and licenses. For the MTF framework under MiFID II and VASP requirements in the EU we proactively separate investment and crypto services to avoid mixing regimes.

COREDO Case Studies

  • Canada, MSB for cryptocurrencies. The client planned OTC exchange and payments. We prepared an AML/CTF program, implemented KYT and transaction monitoring, appointed an MLRO, and completed FINTRAC registration of the MSB in Canada. Registration took 3.5 months, the bank approved the account after a legal opinion and a demonstration of case management for SAR. The project reached a positive ROI after 8 months.
  • Estonia, VASP and a holding structure. The regulator required enhanced substance: office, board of directors, audit. The COREDO team developed a substance plan, completed e‑residency and digital banking in Estonia as an auxiliary tool, and connected a Swiss account for the holding. The regulatory audit was passed without adjustments.
  • Hybrid structures: Dubai + Poland. We linked an operating company in a free zone with a Polish PSP under an NPI/SPI scheme. We set up tax optimization through free zones, provided AML consulting for international business and preparation for bank due diligence in the EU. We opened an account at Emirates NBD for opex and at a European bank for EU clients.
  • Cyprus and Lithuania: forex and payments. For a broker we obtained a CySEC forex (CIF) and simultaneously initiated licensing in Lithuania under the payment institution regime. We segmented risks by separating investment services and payments. The combination provided flexibility for EU passporting and local sales.

Licensing timelines and roadmap

I do not start a project without a roadmap for obtaining a financial license. It outlines the stages:

  1. Diagnosis and business model: NACE/SIC/PKD, license assessment, jurisdictional risk assessment.
  2. Structure and substance: office, staff, hiring plan, local director.
  3. AML/CTF: KYC/CDD/EDD, SAR/CTR, sanctions screening, training.
  4. IT and integrations: AML SaaS, transaction monitoring, case management, reporting.
  5. Documents: compliance policy, business plan, financial model, contracts, proof of address.
  6. Submission and communication with the regulator, responses to requests.
  7. Banking setup, legal opinion, account opening.
  8. Post-licensing monitoring and periodic audits.
Typical timing benchmarks:

  • MSB in Canada: 3–4 months with a ready program (MSB timelines and costs depend on complexity).
  • Lithuania, PI/EMI: 6–12+ months, with constructive dialogue with the regulator.
  • Singapore, MAS: from 9 months to 18+, especially for DPT/crypto.
  • Cyprus, CySEC (forex): 8–12+ months; payment institutions: via the Central Bank of Cyprus.
  • Czech Republic, CNB banking license: 12–18+ months.

COREDO applies practical COREDO checklists to launch within 2–3 months where permissible (for example, preparation of documents and compliance before formal submission), to accelerate the initial stages.

Banking and regulatory due diligence

Preparation for banking due diligence: it’s about logic and sequence. I coordinate:

  • legal and tax due diligence before registration,
  • assessment of CRS/FATCA statuses for all UBOs,
  • plan for account openings (EU/Switzerland/UAE),
  • exit strategies and restructuring after a refusal (if the risk is high).

The solution developed at COREDO includes templates for responses to banks, risk narratives, a request matrix and a set of evidence of substance. For correspondent banks, we predefine permitted geographies and MCC codes, set transaction limits and specify the process for stopping suspicious transactions.

Post-licensing support

A license is a start, not a finish. Ongoing compliance advisory and fixed-fee support keep the program up to date. Post-licensing monitoring and periodic audits include:

  • internal audit, regulatory audit and preparation for inspections,
  • updating KYC/CDD and EDD procedures,
  • integration of whistleblowing and internal investigative practice,
  • refresh of sanctions lists and AML program KPIs,
  • updating capital requirements for payment institutions and reporting.
Scaling a licensed business: operational challenges include increased alerts, MLRO workload, adaptation of transaction-monitoring rules, and new client geographies. The COREDO team helps set up automation: KYC automation and remote onboarding, digital client verification and IDV, integration of AML monitoring with payment rails. Where appropriate, we use regulatory sandbox regimes to roll out a new product without risks to the main license.

Brief checklists and best practices

  • Before registration:
    • Compare the business model against NACE/SIC/PKD.
    • Create a jurisdictional risk assessment matrix and a sanctions matrix.
    • Prepare a business plan, financial model, proof of address, and substance plan.
  • For licensing:
    • Collect KYC/CDD/EDD policies, AML/CTF per FATF, SAR/CTR, and retention records.
    • Appoint an MLRO and a compliance officer with relevant experience.
    • Set up transaction monitoring, KYT, sanctions screening, and case management.
  • For banks:
    • Obtain a legal opinion; verify the UBO structure for CRS/FATCA.
    • Prepare responses to standard queries and sources of funds.
    • Choose a bank according to geography and risk appetite, and provide for a backup account.
  • For crypto/fintech:
    • Check VASP requirements and the MTF framework (if there is an asset market).
    • Ensure crypto AML controls and an independent audit.
    • Calculate the ROI of an MSB license and compare it with alternatives in the EU/Asia.

What Really Works

I do not promise “quick wins” when it comes to licenses and banks. COREDO’s experience, however, shows: a transparent structure, tidy compliance and substance prepared in advance make a project predictable. In my approach there are no unnecessary steps: every policy and document has a purpose: to satisfy the regulator, open an account, preserve resilience and scale.

If you are building an MSB for cryptocurrencies, planning a VASP in Estonia, aiming to obtain a payment license in the EU or a MAS license in Singapore: you are already on the right track when you look at requirements holistically: from NACE/SIC/PKD to AML SaaS and Basel III. The COREDO team prepares not a “folder of documents”, but an operating system of compliance and banking relationships that withstands growth.

Conclusions

International company registration and licensing: it’s always about strategy. I build it on four pillars: a well-thought-out jurisdiction, impeccable compliance, demonstrable substance and banking reliability. This architecture saves time, protects assets and opens doors to the financial infrastructure of the EU, Asia and the Middle East. In COREDO’s real projects this logic has repeatedly proven effective: from FINTRAC MSB to CySEC and MAS, from Lithuania to Estonia and Dubai.

If you need a practical plan – from a jurisdiction-selection matrix to a regulatory audit and account openings, give us the context of your model. I will involve COREDO experts on licensing, AML and banking due diligence, and we will assemble a roadmap that will lead to a license and a sustainable operating model.

I see every day how even strong crypto companies and fintech projects face not so much technical challenges as banking and regulatory ones. The main choke points are correspondent banking, settlements and account freezes caused by insufficiently developed AML and weak “substance”. Over ten years my team and I at COREDO have gone through dozens of licensing processes, hundreds of legal-entity registrations in the EU, Asia and the Middle East, and numerous account-unblocking procedures. Below is a structured guide to the issues that most often lead to payment bottlenecks, and to the solutions that actually work.

Crypto business and correspondent banking

Illustration for the section «Crypto business and correspondent banking» in the article «Crypto business and correspondent banking - where blocks occur»
Crypto business and correspondent banking are directly linked today. If a correspondent bank detects an abnormal transaction velocity in your flows or “dirty” sources of funds, it will block the transfer before it is credited. Correspondent banks and crypto are an area of heightened scrutiny: SWIFT filtering and sanctions screening are in effect, and threshold rules and correspondent risk assessment models are applied.

Our experience at COREDO has shown that the key factor is the predictability and explainability of payment flows. When a business can separate fiat and crypto, produce correct proof of funds and maintain continuous blockchain monitoring, correspondent limits grow and credit lines are renewed without stress. COREDO’s practice confirms: a properly packaged client profile reduces the likelihood of crypto company account blocks many times over.

Choice of jurisdiction and company registration

Illustration for the section «Choice of jurisdiction and company registration» in the article «Crypto business and correspondent banking - where blockages occur»
Geography matters, but details decide: the required license, substance requirements, access to EMI and correspondent accounts, as well as local FIU and regulator support in dialogue with the bank. Below are the main areas where the COREDO team has implemented sustainable launch models.

EU: VASP/CASP/EMI and PKD codes

In the EU, crypto companies often find the best starting conditions in Lithuania and Estonia. VASP registration in Estonia today requires strengthened capital, designated AML officers and an internal auditor, as well as a precise description of Travel Rule procedures. The timeframe for document preparation and FIU review usually takes 2–4 months if KYC/E‑KYC and EDD on beneficiaries are set up in advance.

Cyprus is attractive for both CASP and EMI. An EMI license in Cyprus provides access to SEPA and the ability to build correspondent relationships through a sponsor bank and Nostro/Vostro accounts, provided the applicant has sufficient capital and demonstrated proof of business. In Poland it is important to specify PKD codes in the articles of association in advance for crypto operations and payment services to avoid discrepancies during subsequent bank checks. The solution developed by COREDO includes a matrix mapping PKD/NACE activities to banking profiles, which significantly speeds up the compliance assessment.

MPS/PSA in the UK and Singapore

In the UK the FCA’s regulatory requirements for crypto and payments are quite detailed, and a bank’s willingness to engage heavily depends on the transparency of UBO disclosure and the quality of the AML policy. Singapore sets a high bar on substance requirements: a local director, office, staff, and genuine operational activity. For MPS/payment licenses under MAS requirements, detailed AML/CTF procedures, IP/geo-analysis of counterparties and integration of an AML Rule Engine are critical.

The COREDO team implemented a “proof of presence” working model for Singaporean clients: a lease agreement, employment contracts, local accounting and an independent audit. Such a structure helps maintain accounts and reduces the likelihood of additional bank inquiries about the source of funds.

DFSA and DMCC in Dubai: nuances

Dubai via DFSA and DMCC offers flexibility but requires discipline. DFSA and DMCC in Dubai look at the Travel Rule, sanctions screening, and the separation of fiat/crypto flows when transferring via SWIFT and local clearing.

COREDO’s practice confirms: timely filing of a SAR (suspicious activity report) and engagement with the FIU help resolve potential blockages before an account is frozen.

EMI, forex, payment and crypto licenses

Illustration for the section «EMI, forex, payment and crypto licenses» in the article «Crypto business and correspondent banking - where blockages occur»
A license is not just a piece of paper, it is the language of communication with the bank and the correspondent. For EMIs, capital, governance and access to correspondent accounts via sponsorship arrangements are important. For forex providers and CASPs, EDD on beneficiaries, a KYC archive and storage of transaction metadata, as well as threshold monitoring, are critical.

Our approach at COREDO is to start with the business architecture: product map, client jurisdictions, currency of turnover, plan for correspondent relationships. When Licensing is backed by an operating model, the bank issues limits faster and is less likely to trigger SWIFT filtering with manual review.

Correspondent banks and crypto: risks

Illustration for the section «Correspondent banks and crypto: risks» in the article «Cryptobusiness and correspondent banking - where blockages occur»
Correspondent risk (correspondent banking risk) – is a combination of jurisdiction, client profile, sanction exposures and data quality. The bank takes into account OFAC sanction lists, EU/UK lists, as well as your response to sanction updates and watchlists. If the profile includes P2P operations, OTC desks and mixers, the risk score increases instantly.

The COREDO team builds multi-level schemes: primary settlement infrastructure through an EMI and local clearings, international SWIFT: via a bank with a strict sanctions screening workflow and a GPI tracker. Such a hybrid distributes the load and reduces the likelihood of a complete business shutdown due to a single correspondent.

AML for crypto business: from Travel Rule to EDD

Illustration for the section «AML for crypto business: from Travel Rule to EDD» in the article «Crypto business and correspondent banking — where blockages arise»
A strong AML is not a summary of rules, but a working pipeline. Here the Travel Rule and the FATF requirements, EDD configuration, continuous sanctions screening and transaction checks via blockchain analytics are important. Integration of Chainalysis and other blockchain‑forensic tools is already the standard, not an option.

The solution developed at COREDO provides an AML‑Rule Engine with transactional rules for velocity, structuring/smurfing patterns, geo‑behavior and ‘freshness’ metrics of funds. Such an engine logs events to SIEM, generates reports for the FIU and reduces manual alarm handling.

FATF Requirements and the Travel Rule

The Travel Rule requires transmitting information about the sender and receiver between VASP. Regulatory “overlays” are emerging in the EU and Asia, where ensuring provider compatibility is important. We configure field mapping and data validation processes to prevent rejections due to incompatible formats and unsynchronized time zones.

VASP compliance in the EU and Asia

In the EU, supervision is moving toward MiCA/CASP, with increased requirements for capital, reporting and risk management. In Asia there is a stronger emphasis on the technical side of monitoring and IP/geo‑controls.

Our experience at COREDO has shown that a hybrid approach delivers the best result: European‑level governance plus an Asian focus on technological detail.

Peer-to-peer Cryptocurrency Exchange Risk Control

P2P crypto exchange and risks is a topic where banks closely scrutinize escrow models, order allocation, turnover speed and sources of liquidity. In P2P there are sanction and entity risks, as well as an increased risk of payment structuring. The best AML practices for P2P exchangers in the EU include separate wallets for different classes of counterparties and separate fiat accounts for each on‑ramp channel.

The COREDO team implemented network segmentation of flows: “clean” inflows, OTC bridges, retail P2P and corporate clients are serviced through different accounting schemes. This helps avoid SWIFT filtering, maintain stable correspondent limits and pass regular checks without disruptions.

Account blocks: causes and mechanisms

The primary reasons for account blocks of crypto companies in the EU and Asia are lack of or vague AML policies, Travel Rule gaps, insufficient beneficiary documentation, and sharp spikes in transaction velocity. The use of privacy coins without compensating control procedures and suspicious links to mixers also trigger blocks.

When you receive a letter from the bank about the suspension of operations, it is important to act proactively. We prepare “evidence‑packages” with proof of funds, Chainalysis traces, counterparty profiles and KYC archives, as well as a plan of corrective measures. COREDO’s practice confirms that such a set works as a mechanism to unblock accounts in most typical cases.

Proof of Legality: KYC/E‑KYC

How to prove the legality of fiat inflows into a crypto company? We collect a chain: contracts, invoices, bank statements, tax returns, smart contracts and on‑chain evidence. Integration with Chainalysis for proof of legality routes addresses with “green” tags, shows a risk score and isolates toxic segments.

KYC/E‑KYC includes document validation, live verification, IP/geo comparison, telephony and email‑domain checks. EDD: enhanced Due Diligence for UBO – discloses beneficial ownership, source of wealth and professional biography. Such a package creates trust with the bank and speeds up unfreezing if it has occurred.

Confirm Substance and retain accounts

Substance is not a mailing address, but an ongoing operational presence: staff, office, contracts, reports, local taxes. Substance requirements in Singapore require a local director, an office lease and a clear hiring plan. In the EU and in Cyprus substance requirements also include a genuine managerial function and local payment arrangements.

We conduct an audit of substance and proof of presence: we verify that documents are consistent with each other and reflect actual operations. This reduces the risk of questions when renewing the account and during subsequent checks by the correspondent.

Opening and maintenance of accounts: banks, EMI

EMIs and access to correspondent accounts are a combination that banks assess through the lens of risk management and client profile. It is more appropriate to arrange several EMIs and one or two banks, using SWIFT‑GPI for transparency and separate Nostro/Vostro arrangements for different currencies. This provides resilience and manageable limits.

To reduce correspondent risk when entering the international market, we separate fiat and crypto flows, set limits on P2P volumes and configure the structure of payment counterparties. It is important to discuss correspondent limits and credit lines with the bank in advance so that scaling does not hit a ‘ceiling’.

Compliance technologies: Rule Engine, SIEM

Modern AML is built around the integration of AML‑Rule Engines, SIEM and API integrations for blockchain analytics. Sanctions screening operates through a multi-stage workflow: pre‑screening, on‑screening, post‑event review and escalation to case management. In effect, it is a compliance factory where every event is logged and can be presented to the FIU.

The solution developed at COREDO includes threshold monitoring and triggering rules that take regional thresholds, velocity and structuring patterns into account. We connect a response to sanctions updates and watchlists to automatically suspend high-risk operations until the review is complete.

Scaling without limits

Scaling a P2P‑platform without increasing correspondent limits can be achieved through segregated flows, local clearing systems and alternative rails. Alternatives to correspondent relationships for international fiat transfers include a sponsored payments model via a large EMI, local schemes (SEPA Instant, Faster Payments), as well as regulated on/off‑ramps with stablecoins, if compliance permits.

For privacy without blocks it is important to handle technologies properly. zk‑SNARKs and privacy coins (Monero, Zcash) carry increased risk: banks expect compensating measures: transparent on-ramps, address whitelists, ring signatures analysis and enhanced EDD. If the product uses such transactions, the control design must be agreed with the bank in advance.

COREDO Case Studies – practical stories

Estonia, VASP registration. The client came with a ready product but without a Travel Rule and with “high-risk” beneficiaries. The COREDO team implemented EDD packages, integrated a Travel Rule provider and built a KYC archive. Registration took 11 weeks, the bank opened an account with a base limit, which was doubled after three months with consistently “clean” flows.

– Cyprus, EMI license. The client needed access to SEPA and correspondents for multiple currencies. We prepared a business plan, a risk framework, sanctions screening workflow and proof of funds for the capital. Through a sponsor bank the client obtained Nostro/Vostro agreements and GPI trackers, and also increased limits after the first quarter without incidents.

– Dubai, a DMCC structure for a crypto business. The project faced account blocks due to P2P volumes and mixed flows. The solution developed at COREDO separated flows, implemented blockchain monitoring and established local substance. Blocks stopped, and the correspondent bank renewed the credit line without additional conditions.

– Account unblocking in the EU. The bank requested additional documents regarding suspicious crypto activity. We compiled an evidence package: Chainalysis reports, contracts, tax records, KYC/e‑KYC logs and IP/geo analytics. The account was unblocked in nine business days, and the bank approved a plan of preventive measures.

Compliance ROI and outsourcing

Outsourcing compliance for crypto often pays back within 3–6 months thanks to reduced downtime and losses due to blocks. ROI metrics for blocks include Loss of Revenue, Downtime, Cost of Funds and an increase in CAC due to frictions on the on‑ramp.

When compliance processes are streamlined, GPI‑routes become more stable, and correspondents less frequently require manual confirmations. Compliance outsourcing frameworks (Compliance‑as‑a‑Service) used by the COREDO team cover AML policy, Rule Engine, SIEM, sanctions screening and regular data audits. This creates a control environment that is clear to the bank and the regulator, and allows management to focus on the product and scaling.

Answers to clients’ frequently asked questions

  • What do banks pay attention to when assessing a crypto company as a client? The bank evaluates UBO disclosure, EDD‑packages, implementation of the Travel Rule, sanctions screening and segregation of flows. Substance and the quality of proof of business are important, as well as readiness for FIU interaction, including timely SAR/STR.
  • In which jurisdictions is the risk of correspondent account blocks lower? Where there is a clear regulatory regime (EU, United Kingdom, Singapore, Cyprus, Dubai) and real substance. Jurisdiction: half the success, the other half: the actual AML model and predictability of flows.
  • How to properly structure correspondent relationships when working with crypto flows? Start with a hybrid EMI+bank model, agree on limits and types of counterparties, document the Rule Engine and blockchain monitoring. Regularly share reports with the bank and do not mix P2P with corporate flows.
  • What documents does the bank request in case of suspicious activity and how many should be prepared in advance? They usually request proof of funds, KYC/E‑KYC logs, contracts, invoices, tax documents and a Chainalysis report. Prepare a “box” in advance, update it quarterly and retain transaction metadata for at least the required period.
  • How long does VASP registration in Estonia take? On average 8–12 weeks to prepare the package and 60–90 days for FIU review if there are no revisions. With quality pre‑screening of beneficiaries, the risk of delays is significantly lower.
  • How to reduce correspondent risk with P2P and avoid SWIFT filtering? Separate fiat and crypto flows, configure sanctions screening and the Travel Rule, limit velocity and volumes per client. Agree with the bank on lists of allowed counterparties and route payments via GPI with transparent remittances.
  • How much do FATCA/CRS affect opening accounts for crypto businesses? They have a significant impact, as tax reporting data forms part of the risk profile. It’s important to correctly and timely submit CRS/FATCA reports, avoiding discrepancies with bank questionnaires.
  • Which banks are tightening checks for OFAC and sanctions? This is a trend among all banks with access to dollar liquidity and large correspondents like Deutsche Bank, MUFG and Citi. Therefore, sanctions screening and watchlist updates must operate without delays.
  • Which licenses are suitable for scaling P2P? In the EU, CASP with a strong AML function, in Cyprus, CASP/EMI depending on the model, in Singapore, MPS/PSA with extended on‑ramps. The key: proper separation of flow risk segments and clear governance.

Checklists: documents, policies and steps

  • Proof of funds and an evidence‑package for the bank. Gather contracts, invoices, statements, tax returns, and on‑chain reports. Supplement with KYC/E‑KYC logs, IP/geo analytics, a counterparty profile, and a fund‑routing map.
  • Preparation of a business‑plan and AML policy for an EMI/Payment license. Describe the product map, customer segments, geography, and flow projections. Attach the AML policy with a Rule Engine, sanctions screening workflow, Travel Rule implementation, and an EDD plan.
  • Due diligence of beneficial owners for the bank. Prepare UBO disclosure, biographies, source of wealth, and supporting documents. Conduct an independent media search, political exposure checks, and sanctions screening with findings.
  • How to organize substance in Singapore to retain accounts. Sign a lease agreement, hire a local director and key staff. Maintain local accounting, document operational processes, and regularly confirm business activity.
  • Which PKD codes to specify to minimize blocks. Analyze the code’s conformity with the declared services and the bank profile. Exclude “grey” formulations and reflect specific crypto operations in the classifier’s language.
  • How to integrate blockchain monitoring into the AML policy. Describe data sources, threshold values, actions on alerts, and metadata storage. Include API integrations, white/blacklisting procedures, and case escalation to the FIU.
  • What to do when you receive a letter about suspension of operations. Immediately acknowledge receipt, request the list of requirements and deadlines. Compile an expanded evidence package and propose a corrective action plan with deadlines.

Partnership with COREDO

Crypto business and correspondent banking are not about luck but about process architecture and data accuracy. When AML‑policy, the Travel Rule, sanctions screening, substance and the evidentiary base are combined into a single system, account blocks become rare exceptions and scaling turns into a manageable routine. The COREDO team has implemented dozens of such systems in the EU, Asia and the Middle East, and I see how mature compliance increases business valuation.

If your plans include registering legal entities for crypto business in the EU, obtaining an EMI or CASP, entering Singapore with its substance requirements, or structuring in Dubai through DFSA/DMCC: rely on experience and proven methodologies. COREDO’s practice confirms: transparent processes, predictive metrics and readiness to engage in dialogue with the bank are the best way to retain accounts, expand limits and move forward without interruptions.

I have been leading COREDO since 2016 and every quarter I see the same thing: companies that treat the fight against money laundering (AML) as “a checkbox for the regulator” end up paying a high price for it — from account freezes and halted operations to prolonged inspections and the loss of partners. AML compliance works as an asset when it is embedded in a growth strategy, rather than living in a separate file on a server. When the COREDO team implements AML processes taking into account the specifics of the jurisdiction, business models and IT architecture, clients receive not only licenses and peace of mind during inspections, but measurable efficiency — reduced false positives, faster onboarding and a better ROI on investments in AML technologies.

Regulatory guidelines are clear: recommendations of FATF, EU directives AMLD5/AMLD6, EBA guidance, principles of the Wolfsberg Group. But a dry list of requirements rarely leads to a working system. The solution developed at COREDO always relies on a risk-based approach (RBA), a clear Risk Appetite Statement and transparent AML team KPIs. I call this “operational compliance”: not only do we comply, but we also bring value to the business.

RBA in AML compliance

Illustration for the section 'RBA in AML compliance' in the article 'Mistakes in developing AML policies – TOP 10'

A proper risk-oriented approach sets priorities, allocates resources and establishes rules for monitoring. Without it, TMS (Transaction Monitoring Systems) are overwhelmed with alerts, CDD (Customer Due Diligence) unduly burdens low-risk customers, while high-risk scenarios remain blind spots. COREDO’s practice confirms: a mature RBA is the best way to both strengthen protection and reduce operational costs.
We start by mapping the business model: product range, geography, channels, transaction typologies, counterparty and third-party risk. Then we form a Risk Appetite Statement, embed Customer risk rating and KRI at the board level. Such an RBA helps explain to the regulator why these monitoring rules are appropriate, and it also shows investors that the company manages risk systematically.

RBA mistakes and how to avoid them

  • Mixing product and customer risks into a single scoring. I separate these dimensions; otherwise we lose transparency and explainability.
  • Lack of a Risk Appetite Statement for AML. Without it, escalation and investigations become chaotic.
  • Universal rules that don’t consider the National Risk Assessment (NRA) of operating jurisdictions. The COREDO team always calibrates rules to the specific country and sector.
  • Underestimating false negative risk. We include stress tests and red-teaming to uncover blind spots.
  • Errors in customer risk scoring algorithms. Validation and periodic review of factor weights address this issue.

Mistakes in developing AML policies

Illustration for the section «Mistakes in developing AML policies» in the article «Mistakes in developing AML policies – TOP 10»
Each of these mistakes regularly occurs in real projects, and each can be fixed with a simple but disciplined approach.

  1. Mistakes in developing AML policies not tied to operational reality. The policy describes an ideal, but procedures and systems do not support it. I ensure full alignment: “policy: procedure: control, data”.
  2. Typical KYC mistakes in a client’s policy. Insufficient verification of documentary evidence, lack of dynamic data updates, ignoring LEI. We connect reliable data sources and set update frequency according to risk level.
  3. Shortcomings in the policy for identifying beneficial owners (Beneficial ownership). Errors arise when using only registries. I add a cascading approach: corporate trees, independent sources, verification of indirect control.
  4. Errors in screening PEPs and sanctions lists. Incomplete sources, infrequent updates, narrow matching algorithms. At COREDO we build multi‑source screening, take into account Sanctions lists update frequency and flexibly configure fuzzy matching.
  5. Errors when configuring transaction monitoring. Universal thresholds lead to an avalanche of False positives, while excessive filtering leads to missing suspicious schemes. I apply alert tuning, analysis of the economic efficiency of rules and Explainable AI.
  6. How to set up SAR/STR procedures without errors. Clear escalation criteria, deadlines, roles, Case management and quality control. We build standard templates and train analysts to work with FIU.
  7. Mistakes in the risk appetite statement for AML. Uncertainty creates delays and paralysis in decision-making. I document the principles and threshold values at the board level.
  8. Insufficient customer segmentation in CDD as an error. One size does not fit all. In COREDO projects segmentation is based on behavior, geography, product and channel.
  9. The impact of shortcomings in data recording and storage on STR investigations. Without a quality Retention policy and Audit trail, investigations stall. We implement Data quality and MDM practices.
  10. Why an independent AML audit is mandatory. An external view reveals model drift, process conflicts and weak spots in Governance. I schedule an audit annually and after major changes.

Implementing an AML policy in the company

Illustration for the section «Implementing an AML policy in the company» in the article «Mistakes in developing AML policies – TOP 10»
My principle is simple: I don’t implement a policy until I see how it “works through” the system from onboarding to the report to the FIU. Each role understands its tasks, and integrations and access rights are exercised on test scenarios.

ERP/CRM implementation roadmap

  • Audit of current systems, data catalog, API integration map, assessment of real-time monitoring vs batch processing.
  • Setting up Role‑based access control and Segregation of duties to eliminate conflicts of duties.
  • Integration of KYC services and sanctions providers with ERP/CRM and the front office.
  • Testing end-to-end scenarios: onboarding, data updates, escalation, SAR/STR.
  • Documentation, version control, training, and go-live with metrics for alert disposition.

TMS configuration: rules and results

I always start with transaction typologies and historical data. This allows us to set thresholds, rule and scenario sensitivity without guesswork. We measure false positives, processing time, share of escalations, share of SAR/STR, and calculate cost‑benefit for each rule. If the model uses ML/AI, we configure Explainable AI, perform model validation, guard against model drift, and document the pipeline.
To reduce false positives in the TMS, I take three steps: risk segmentation, contextual features (behavioral, geographic, seasonal) and iterative alert tuning with analyst participation. This reduces backlog and eases the team’s workload.

SAR/STR: Case management and escalation

A clear SAR/STR procedure is about speed and quality. I set SLAs at every stage: initial analysis, escalation, final decision, submission to the FIU. Best practices for escalating suspicious transactions include dual control for high-risk cases and involvement of the AML officer at “bottlenecks”. Case management must store a full audit trail, document versions, decision history and timeline controls.

KYC, CDD and EDD: depth and control

Illustration for the section «KYC, CDD and EDD: depth and control» in the article «Mistakes in developing AML policies – TOP 10»
KYC – it is not a form, but a process. It begins with proper segmentation, continues with collecting Documentary evidence and ends with the continuous updating of the client’s profile. CDD: the basic level of verification, EDD – enhanced for high-risk clients and complex structures.

Client risk segmentation

Insufficient client segmentation in the CDD methodology leads to unjustified workload and gaps. I apply a Customer risk rating that takes into account the industry, country, product, channel, counterparty type, PEP status and sanctions risks.

We eliminate errors in client risk scoring algorithms through periodic validation, back‑testing and peer benchmarking across the industry.

Beneficial owners, LEI and evidence

Identifying beneficial owners: an area where mistakes are often made. I use a multi-layered methodology: registries, corporate trees, contractual links and signs of indirect influence. LEI speeds up legal entity verification and facilitates matching. For CDD/EDD it is important to accumulate Documentary evidence with clear controls on timeliness and sources.

Depth of PEP and sanctions screening

PEP screening and Sanctions screening require up-to-date sources and flexible algorithms. We set the Sanctions lists update frequency, use multiple data providers and configure fuzzy matching with control of False negative risk.

Sanctions compliance overlaps with trade compliance, so the policy should describe the areas of intersection and the escalation procedure.

GDPR and cross-border data transfers

Illustration for the section «GDPR and cross-border data transfers» in the article «Mistakes when developing AML policies – TOP 10»
Without a data culture, AML processes lose effectiveness. I start with data quality and master data management: consolidation of reference data, field quality control, automatic validators, unified identifiers. Audit trail records all actions, and the retention policy accounts for retention periods by jurisdiction and processing purpose.

GDPR: security and access

For cross-border data transfers I assess legal bases, standard contractual clauses and local restrictions. Cloud-based AML solutions provide flexibility if RBAC, encryption and monitoring are configured correctly.

The incident response plan outlines actions in case of a data breach, and regular drills help the team act quickly and cohesively.

Role of the board in governance

Governance and oversight shape the compliance culture. I ensure board engagement: approval of the Risk Appetite Statement, review of KRIs and KPIs, AML officer reports and a development plan.

Board-level accountability increases discipline in business units and speeds up decision-making.

AML officer independence and training

How to set up the role and independence of the AML officer? A direct channel to the board, veto rights in high-risk areas, a resourcing mandate and performance assessment based on KPIs, not on “no incidents”. Training and awareness programs raise the “compliance literacy” in sales, operations and IT.

Third-party management

Outsourcing AML functions helps to scale, but typical mistakes when outsourcing AML functions include: unclear SLAs, lack of quality control and a weak data access model. I build Third‑party risk management and vendor due diligence: provider assessment, test assignments, KPIs, sample case audits, and a contingency plan.

For VASPs and payment companies integrations are important: API integration, Travel Rule, data exchange with partners and correspondent banking risks (Correspondent banking risks). The COREDO team configures these processes so that compliance doesn’t slow down business.

Preparation for FIU and regulator inspections

Why an independent AML audit is mandatory and what to avoid? An external assessment will reveal gaps the internal team doesn’t notice because of a “jaded” view. I use Realistic testing and red‑teaming of AML policies to ensure scenarios actually catch risk typologies.

Preparation for an FIU and regulator inspection

I build an “inspection folder”: policies and procedures, versions and change history (Documentation and version control), KPI/KRI reports, training log, TMS logs, examples of SAR/STR, escalation decisions, Independent audit results and a remediation plan. Regulatory change management records how the company updates policy to meet new requirements. We take into account the National Risk Assessment of each country of presence.

AML Technologies and Effectiveness

The business expects measurable results. Therefore, I build KPIs and performance metrics for the AML team:

  • Alert disposition metrics: false positive rate, average processing time, escalation rate, confirmed case rate, share of SARs/STRs.
  • Backlog remediation: a plan to reduce backlog and keep it within SLA.
  • Cost‑benefit analysis for AML solutions: cost per alert, cost per SAR, cost-effectiveness of monitoring rules and models.
  • KRI: percentage of high-risk customers, percentage of customers with EDD, sanctions match rate.
I measure the ROI of investments in AML technologies through reduced FP, faster onboarding, reduced manual work, and lower regulatory fines and reputational risk. When COREDO configures Explainable AI and optimizes rules, companies see faster processes and improved investigation quality.

Crypto AML and VASP specifics

For providers of virtual assets the Travel Rule, on‑chain analytics and integration of address risks into the TMS are important. Common mistakes in virtual asset service provider (VASP) policies include ignoring mixer chains, weak counterparty due diligence and lack of procedures for high‑risk jurisdictions. We implement real‑time monitoring, sources of address and route risk assessments, and STR procedures for higher‑risk transactions.

Mistakes in the use of ML/AI in transaction monitoring are common:
  • insufficient training dataset,
  • lack of model validation and drift monitoring.

The COREDO team sets the MLOps standard for AML: data versioning, result replication, Explainable AI and regular retraining.

COREDO cases in the EU, Asia and the CIS

  • EMI‑license in the EU and TMS integration. A client with a product in the Czech Republic and Slovakia was preparing for licensing in one of the EU countries. The COREDO team implemented RBA, Risk Appetite Statement, deployed a TMS with contextual features and Explainable AI. Result: a 42% reduction in False positives, shortening corporate client onboarding from 7 to 3 days, and a successful regulatory review without findings.
  • payment license in Singapore. For the payment services license under MAS we created an AML policy and procedures, taking into account local requirements and the GDPR for cross-border data transfers. The solution developed by COREDO included RBAC, case management and strict SLAs. Outcome: the regulator noted the maturity of governance and the quality of escalations.
  • VASP‑project in Estonia with Travel Rule. A client from the EU was planning expansion to Dubai. We established Crypto AML and Travel Rule processes, conducted vendor due diligence for providers of address risk, set up an independent audit and a Regulatory change management plan. Result: flawless STR filing and a successful product launch in several jurisdictions.

How to remediate AML violations

When the FIU or a regulator points out deficiencies, it’s important to respond quickly and in a structured way.

Our experience at COREDO has shown that an effective roadmap consists of the following stages:

  1. Gap assessment and prioritization by risk and business impact.
  2. Quick «wins» (quick wins): policy updates, alert tuning, eliminating bottlenecks in SAR/STR.
  3. Strategic changes: review of RBA, update of the Risk Appetite Statement, implementation of KPI/KRI at the board level.
  4. Data & tech: improving data quality, Model validation, drift monitoring, tuning Explainable AI.
  5. Governance: strengthening the role of the AML officer, updating documentation and version control, a plan for an independent audit.
  6. Backlog remediation and monitoring the sustainability of changes.
I record responsibilities, deadlines, and success metrics for each step. COREDO’s experience confirms: this discipline restores the trust of the regulator and partners.

How COREDO supports businesses

When we launch projects, I look beyond just AML compliance. Legal entity registration in the EU, Czech Republic, Slovakia, Cyprus and Estonia, support in the United Kingdom, Singapore and Dubai, is the foundation. Obtaining financial licenses (crypto, payment, forex, banking) requires consistent policies and a mature operating model. The COREDO team builds the entire chain: from corporate structure to AML processes, integrations, training and independent audit.

For those scaling across multiple countries, we design an AML/CFT centre of excellence, a single policy framework with local branches, a common metrics system and a unified data standard. This reduces cost of ownership, accelerates market entry and strengthens the trust of banking partners and payment providers.

AML as a competitive advantage

A good AML policy works like navigation: it shows routes, warns about risks and helps you move faster. AML compliance delivers business results when it relies on a mature RBA, a clear Risk Appetite Statement, high-quality data and technological discipline. I see client teams start making decisions faster, reduce false positives, ease the burden on the front office and strengthen relationships with banks and regulators.

COREDO builds exactly such a system: practical, measurable and scalable. If you are planning to register a company in the EU, Asia or CIS countries, preparing to obtain a financial license or want to strengthen the fight against money laundering (AML), draw on experience. My team has already solved similar tasks in the Czech Republic, Slovakia, Cyprus, Estonia, the United Kingdom, Singapore and Dubai. We speak the language of both business and regulators and turn requirements into working processes – with transparent KPIs, reliable governance and a sustainable ROI.

Since 2016 I have been building COREDO as a platform where entrepreneurs receive not just company registration abroad and access to banking, but a resilient architecture of payment flows and compliance processes that withstand regulatory audits and business growth. Over these years the COREDO team has implemented projects in the EU, the Czech Republic, Slovakia, Cyprus, Estonia, the United Kingdom, Singapore and Dubai, as well as in a number of CIS countries, and I have a clear understanding of the pain points of high-risk segments: from de-banking and account freezes to fragmented AML and licensing requirements. This article is my condensed experience and a working methodology that we apply daily in payment organizations, fintech, crypto (VASP), forex, e-commerce and related verticals.

My goal is to provide practical support: how to structure registration solutions and obtain licenses, how to build control over payment flows and reduce AML risks in high-risk businesses, how to implement compliance programs for high-risk industries so that scaling does not break the system. COREDO’s practice confirms: predictability and transparency of processes reduce time-to-market, increase the trust of banks and acquirers and make compliance a driver of growth, not a brake.

Registration of payment infrastructure

Illustration for the section «Registration of payment infrastructure» in the article «Payment flows and AML risks in high-risk businesses»

registration of a legal entity for the high-risk segment: not a formality, but part of the risk profile. Our experience at COREDO has shown that ownership structure (UBO), corporate transparency and availability of beneficial ownership registers in the EU and Asia directly affect access to banks, correspondent accounts and payment providers. I recommend starting with risk-based jurisdiction mapping: we assess the regulatory regime (AMLD5/AMLD6, PSD2), case law, banks’ attitude to MCC classifications and high-risk models, as well as local requirements for an AML officer and reporting.

Registering a legal entity in the EU to access banks makes sense if the payment model is thought through in advance: SEPA/SWIFT routes, possible access to local acquiring, requirements for KYB and source of funds/source of wealth. The solution developed at COREDO for clients in the Czech Republic and Estonia includes preparation of a KYB package, UBO verification, geographic and jurisdictional risk analysis and a transaction monitoring implementation plan. This increases the likelihood of passing the bank’s risk committee and reduces onboarding time.

Correspondent banking and counterparty risk remain critical. In the SWIFT payment chain sanctions monitoring, OFAC and international sanctions compliance are important, as well as control of exotic routes through third-party payment processors. In COREDO cases we implement combined checks: sanctions, PEP, adverse media and continuous synchronization of sanctions lists. Such duplication reduces the likelihood of false negatives in cross-border payments and maintains the required SAR rate.

Migration of payment providers during de-banking is a separate task. I’ve seen high-risk PSPs lose an acquirer due to chargeback ratio and non-compliance with PSD2 and AMLD. We restarted the infrastructure through reserve acquiring partners, reworked MCC coding and anti-fraud strategies for PSPs and aggregators. Important lesson: prepare a “warm” reserve — an alternative PSP, a PayFac model, and also a package for rapid repeat KYB with a new provider.

Payment facilitators and merchant onboarding require precise profiling of merchant risk, MCC validation and implementation of KYC and KYB for high-risk merchants. The COREDO team implemented multi-level onboarding schemes: basic KYC/KYB, then EDD (enhanced Due Diligence) for complex clients, including documenting sources of funds, beneficiary verification and adverse media. Such segmentation reduces frictions for low-risk sellers and protects from accumulation of latent risk in the long tail of merchants.

Compliance: risk-based approach and EDD

Illustration for the section «Compliance: risk-based approach and EDD» in the article «Payment flows and AML risks in high-risk businesses»

risk-based approach to transaction screening is a standard that turns AML into a probability-management system. I insist that the risk appetite be formalized in policy: which geographies are acceptable, which goods/services are excluded by MCC, how we assess payment structuring (smurfing) and layered schemes. This approach makes it easier to tune AML rules and reduce false positives without compromising security.

KYC/KYB: it’s not just collecting identity documents and corporate extracts. In a high-risk environment combined checks are needed: document verification (OCR), liveness, customer authentication, biometric verification and beneficial ownership (UBO) checks. In COREDO projects we combined data enrichment via global data providers, entity resolution for corporate clients and adverse media monitoring to rule out synthetic identity and hidden connections.

In the VASP and AML segment when working with cryptocurrencies the linkage is important: licensing requirements (for example, registration in Estonia or in several Asian hubs), blockchain analytics and a travel rule policy. Using blockchain analytics to trace transactions enables detection of high-risk sources (mixers, sanctioned wallets) and supports preparation and filing of SARs/reports of suspicious activity. In one COREDO case EDD procedures for a VASP reduced risk by 40% according to an internal model, and escalation time was halved.

Trade-based money laundering (TBML) in payment flows is often underestimated. We encountered document forgery/substitution, false valuation of goods, inflated invoices and anomalous refund schemes. TBML control requires matching logistics, price benchmarks, counterparty profiles and graph analytics across the supplier network. Paired with sanctions monitoring this is a powerful barrier against circumventing restrictions via trade transactions.

Geographic and jurisdictional risk must be measurable. I rely on FATF recommendations and risk assessments, as well as on local regulatory requirements in the EU, Asia and the CIS. We adapt scoring models taking into account FinCEN guidance on high-risk sectors, local lists and the specifics of bank de-risking. This is especially important in transit jurisdictions where counterparty risk and de-banking can flare up suddenly.

Transaction monitoring and anti-fraud

Illustration for the section «Transaction monitoring and anti-fraud» in the article «Payment flows and AML risks in high-risk businesses»

AML architecture: real-time vs batch monitoring: a key design decision. In high-risk verticals you can’t avoid real-time: instant payments, cards and crypto move quickly, and time-to-detect determines losses. The solution developed at COREDO combines real-time alerts for high-priority scenarios and batch processing for complex transaction graph analysis and counterparty network analysis. Such a hybrid reduces load and improves TPR while keeping FPR under control.

Transaction monitoring rules and scenarios should cover patterns: structuring, geo-velocity, spikes in amount/frequency, chains through related counterparties, indicators of money laundering on refunds, fraud schemes with intermediaries and escrow abuse. We also include sanctions screening in cross-border payments at the counterparty and beneficiary level, plus management of false negatives through regular scenario validation.

Integration of AML with KYC authorization and 3DS is an important loop for card-present and card-not-present operations. Add device fingerprinting, behavioral biometrics and dynamic risk rules. For PSPs and aggregators, anti-fraud strategies should account for acquiring risk, chargeback fraud and maintain a healthy chargeback ratio for relationships with the acquirer. In one COREDO project, optimizing 3DS routines reduced fraud by 32% with no noticeable drop in conversion.

Data enrichment, entity resolution and graph analytics close the “blind spots”. I welcome the use of external sources, but insist on GDPR and data privacy: minimization of personal data, transparent retention policies and encryption at rest. From a channels perspective, control risks in SWIFT, SEPA and local ACH: differences in cut-off times, returns and reconciliation create operational gaps that bad actors exploit.

Scoring and explainability

Illustration for the section “Scoring and explainability” in the article “Payment flows and AML risks in high-risk businesses”

Machine-learning-based transaction scoring models are applicable when you have enough labeled events and a mature validation process. In a high-risk environment ensemble models for transaction scoring that combine gradient boosting and simple rules perform well. For detecting anomalies using clustering and semi-supervised approaches we use reference profiles of merchants/payers and monitor spikes in activity.

Explainability of ML models and model validation are not a luxury. Regulators expect transparent reasons for alerts: feature importance, reason codes, threshold stability, and a protocol for drift detection and model retraining. The COREDO team implements regular challenger models, bias checks and calculation of metrics: FPR, TPR, precision, recall, as well as operational KPIs: time-to-detect and time-to-resolve. This disciplines product decisions and minimizes “blind spots”.

A cost-benefit analysis of implementing AML systems and the ROI from automating AML and anti-fraud systems: a question for the CFO. We calculate the total compliance costs, the cost of SARs (in addition to direct operational hours this includes the risk of fines and lost revenue from false blocks), the economics of reducing chargebacks and fraud loss. In COREDO projects, RPA automation for alert handling and SAR preparation reduced TAT by 25–40%, and a 20% reduction in false positives often paid off the project within 6–9 months.

Managing false negatives requires careful tuning: regular analysis of “caught/missed” cases, retro-simulations and backtesting. I recommend allocating an independent quality control (QA) for compliance alerting to avoid confirmation of one’s own hypotheses and to maintain an objective assessment of risks.

Compliance: people, processes, outsourcing

Illustration for the section «Compliance: people, processes, outsourcing» in the article «Payment flows and AML risks in high-risk businesses»

AML duties officer and building the compliance function are the foundation. The AML officer sets the risk appetite, approves policies, oversees regulatory monitoring and AML reporting, escalates complex cases, and organizes preparation for regulatory audits and internal inspections. In mature PSPs and VASPs we also see separate roles for sanctions, KYC/KYB, monitoring and investigations, as well as a model owner for ML.

Outsourcing vs in-house AML: advantages and risks are balanced between control and speed. AML outsourcing allows you to quickly scale alert processing, implement 24/7 coverage and cover rare competencies (for example, TBML or crypto analytics). When choosing a provider and SLA I insist on checking quality controls, TAT speed, the possibility of an independent audit, staff redundancy and incident-management procedures. In a number of cases COREDO acted as an integrator: we built an in-house core and handed off peak load under SLA.

Regulatory requirements in the EU, Asia and the CIS vary, but the common framework includes: FATF, AMLD5/AMLD6 in the EU, PSD2 for cards and payments, OFAC and international sanctions, and FinCEN guidance for high-risk. I recommend a single global standard with local add-ons to avoid a ‘zoo’ of policies. This makes regulatory reviews and audit preparation easier, and simplifies staff training and the awareness program.

Data privacy, GDPR and data retention are mandatory lines of defense. I adhere to the principles of privacy by design: data segregation, role-based access control, encryption, masked data in analytics, and archiving and audit logs for investigations. We separately maintain incident management and escalation of suspicious cases: who makes the decision to block, how the client is notified, when a SAR is filed, and within what timeframe we perform a post-incident review.

Third-party and counterparty management is an area of heightened attention. Counterparty checks and supplier due diligence include risk profile, sanctions/PEP/adverse media, testing return and chargeback processes, as well as control of payment agents. If you operate as a PayFac, regular reviews of the merchant portfolio, MCCs and monitoring of transaction patterns are mandatory.

COREDO real-world cases

Case 1: PSP and merchant profiling. An aggregator approached us facing a rise in chargeback fraud and the threat of losing its acquirer. We implemented merchant risk profiling, reviewed MCC coding, integrated KYC with the CRM and payments platform, and implemented transaction monitoring rules. The chargeback ratio dropped below the threshold, the SAR rate stabilized within acceptable limits, and the acquirer confirmed continuation of cooperation.

Case 2: VASP and blockchain analytics. The crypto provider required a license and an AML platform to detect high-risk flows. The COREDO team deployed blockchain analytics, implemented EDD for complex clients, configured sanctions filters and a source-of-funds policy. As a result compliance processes became scalable, and the regulator approved the license without additional rounds.

Case 3: de-banking and payments migration. A fintech from a high-risk vertical faced account closure and acquirer refusal. Within 30 days we prepared a package for a new bank in the EU, restored SWIFT/SEPA routes, switched part of the traffic to a backup provider, and optimized anti-fraud. Downtime was minimal, and correspondent risk was reallocated to more reliable partners.

Case 4: TBML in cross-border e-commerce. Invoice and logistics mismatches indicated possible TBML. We implemented graph analytics, matched prices against benchmarks, and tightened counterparty checks. Suspicious patterns were documented, SARs were filed, and vulnerabilities in returns processes were closed.

90–180 days to compliance: manager’s plan

  1. Diagnostics. Audit of payment flows and AML risks, jurisdiction map, geographic risk assessment, inventory of MCCs and merchant portfolio, review of KYC/KYB and EDD. I record current metrics: FPR, TPR, precision, recall, time-to-detect, time-to-resolve, SAR rate.
  2. Policies and risk appetite. We approve a risk-based approach, sanctions rules, SAR procedures, roles of the AML officer, third-party controls. We prepare compliance with AMLD5/AMLD6, PSD2 and local regulations, and synchronize OFAC/sanctions lists.
  3. Monitoring architecture. We define real-time vs batch pipeline, transaction monitoring scenarios, integration of KYC with 3DS and anti-fraud, add device fingerprinting and behavioral biometrics. We connect data enrichment and entity resolution.
  4. Automation and ML. We introduce RPA for handling alerts and preparing SARs, launch pilots of ML models (if data is available), set up explainability and model validation, and monitor drift detection. We define a plan to reduce false positives/negatives.
  5. Operational resilience. SLAs for internal teams and outsourcing, incident management plan, escalation procedures, archiving and audit logs. We prepare documentation for regulatory inspections and internal audits.
  6. Banking and providers. We update KYB packages for banks and PSPs, check correspondent chains, prepare fallback routes in case of de-banking. We update due diligence for vendors and payment agents.
  7. Training and culture. Awareness program, training on TBML, sanctions screening, chargebacks and escrow abuse, regular tabletop exercises for compliance and risk management teams.

Private aspects are often forgotten.

  • verification of the source of funds (source of funds) for large transfers should be standardized: standard templates, lists of acceptable documents, affiliation checks. This reduces TAT and lowers conflicts with clients. For source of wealth, keep decision logs and a link to external sources: this helps during audits.
  • Models «refund = low risk» are flawed. Refunds are often used to “clean up” traces, and money-laundering indicators related to refunds should be included in the rules. Add checks for the time between payment and refund, the frequency, and beneficiary overlaps.
  • Corporate transparency is more important than «speed of registration». Nominee directors and complex trusts without a business purpose raise questions with banks. I prefer simple structures with a clear UBO and understandable business logic – this increases trust and speeds up access to banks.
  • Sanctions compliance is not a one-time check but an ongoing process. Sanctions lists and automatic synchronization, adverse media monitoring and updating scoring weights should be scheduled. Ignoring updates: a direct path to operational risks.

Maturity metrics and reporting

Key AML metrics — SAR rate, false positive rate, TAT and TTR — indicate not only efficiency but also the health of the process. Regulatory monitoring and AML reporting should include alert trends, escalation rate, share of EDD cases and the ratio of real-time to batch processing. In mature, well-tuned systems I see FPR steadily trending down while TPR remains stable and SAR volume is adequate.

Cost of SAR and overall compliance expenses: practical financial metrics. They can be optimized through automation and SLA review, but it’s important not to “cut back on security.” You should also capture savings from prevented fraud, reduced chargebacks and fewer fund freezes: this is what creates the ROI from automation.

Regulatory audits – no panic

Preparing for regulatory audits and internal inspections is about order in documentation and consistency of practice. I ask teams to keep an “audit shelf”: policies, playbooks, investigation examples, escalation logs, training reports, model cards and ML validation reports. The solution developed at COREDO includes a pre-audit review and dry run interviews with responsible persons to eliminate discrepancies.

The legal consequences of AML non-compliance can strike not only with fines but also through banks: de-risking, account freezes, and termination of correspondent banking relationships. Timely SARs, transparent reporting and effective communication with the regulator reduce reputational damage and demonstrate maturity.

Scaling without losing control

Scaling AML processes as a company grows is about modular architecture, backup providers, a unified data dictionary and a flexible risk model. I recommend roadmaps for 12–24 months: phases of geographic expansion, planning new licenses (including payment services and forex), updating anti-money laundering policies for payment service providers and an integration plan for new channels.

Scoring and anti-fraud models must evolve. Anomaly detection, graph analytics and ensembles are living components that require regular retraining and review. COREDO’s practice confirms: discipline in models and metrics reduces operational surprises and makes growth manageable.

Managing payment agents and PayFac: an area where a small oversight turns into a systemic problem. Regular portfolio reviews, MCCs, geographies, due diligence for suppliers and reputation risk checks through adverse media are not bureaucracy, but insurance against the “domino effect”.

What’s important to do today

If you run a business in a high-risk industry, take three steps. First, fix your risk appetite and a map of payment flows with clear “red zones”. Then check the resilience of onboarding: KYC/KYB, EDD, UBO, sanctions and sources of funds — without gaps and manual “workarounds”. And finally, assess the economics of automation: where RPA and ML will deliver quick wins in TAT, FPR and fraud reduction, and where it’s more critical to strengthen the team and processes.

COREDO is a team that brings together jurisdiction registration, Licensing (including VASP, payments and forex), AML consulting and an engineering approach to transaction monitoring. I am open to a conversation in the language of metrics, architecture and regulatory requirements. If you see that it’s time to turn compliance into a lever for growth, let’s discuss how to adapt the practices described to your scale and vertical.

Over ten years of managing COREDO I have become convinced: the speed and quality of compliance decision-making determine a company’s competitiveness no less than product and marketing. Regulation is tightening, sanctions regimes change dynamically, and clients want a fast onboarding solution without compromises. That is why OSINT checks of beneficiaries have become the foundation of our KYC/KYB approaches and a key supporting layer for AML controls.

OSINT is structured work with open sources, where not so much the ‘breadth of internet searching’ matters as discipline: verifiable sources, matching methodologies, data provenance and reproducibility of results. When entrepreneurs ask me how to shorten time-to-onboard and reduce risk exposure, I answer: build an end-to-end KYC OSINT pipeline balancing automation and manual expertise. It is this kind of architecture that delivers reliable results and withstands regulator scrutiny.

COREDO’s practice confirms: properly built AML OSINT checks reduce the cost of due diligence, speed up the bank’s account decision and simplify Licensing (PI/EMI, crypto, forex). I often see how a single properly documented audit trail with links to registries and adverse media answers committee questions and saves weeks of communications.

UBO: How banks verify beneficiaries

Illustration for the section «UBO: how banks check beneficiaries» in the article «OSINT-check of beneficiaries — which sources banks use»

Identification of the ultimate beneficial owner is not a formality but the central element of CDD/EDD procedures. Banks are required to conduct UBO checks taking into account ownership chains, nominal directors and trust structures. In my practice, a significant share of onboarding delays arises from incomplete tracking of indirect ownership.

Banks build beneficiary checks around several main layers: corporate structure (incorporation registers), sanctions checks of beneficiaries by OFAC/EU/UN, PEP and OSINT screening for adverse publications. The COREDO team has implemented dozens of complex cases where such a combined approach revealed hidden controllers and substantiated risk classification for the bank or regulator.

Risk-based approach FATF/AMLD5/6

FATF directly recommends a risk-based approach to CDD: the depth of review increases with the risk of the jurisdiction, the type of activity and the transaction profile. In Europe AMLD5/6 enshrined the obligation of access to beneficial ownership registers and expanded expectations for EDD, especially for PEPs and complex corporate structures. Our experience at COREDO has shown that early calibration of the risk model and linking OSINT sources to risk categories reduce FPR and increase explainability for the regulator.
When a client is preparing for EMI/PI licensing in the EU or for crypto registration, I always recommend: establish an internal CDD methodology with references to FATF and AMLD5/6, define EDD triggers and the procedure for documenting sources. This is not bureaucracy – it is an operational tool for the compliance team and the foundation for a successful audit.

PEP, sanctions, adverse media: screening

PEP and OSINT are a constant “pair” in the daily work of compliance. A PEP flag alone does not mean prohibition, but requires EDD, source verifications and contextual analysis of adverse media. We use a combination of sanctions lists (OFAC SDN list, EU sanctions, UN sanctions), OpenSanctions as an aggregator, and negative news processed with NLP filters for sentiment and relevance.
The solution developed at COREDO allows separating “noise” from material publications: panel data and adverse media are calibrated by source, date, geography and proximity to the client’s profile. This approach reduces false positive triggers and speeds up committee decisions, especially for international business structures.

OSINT sources for banks: what works

Illustration for the section «OSINT sources for banks: what works» in the article «OSINT beneficiary check - which sources banks use»

The most common question at strategic sessions: which public sources do banks use to check beneficiaries? It is important not to rely on a single registry, but to build a “portfolio of sources” covering the EU, Asia and the CIS while taking local specifics into account. Below: a core set that has proven itself in COREDO projects.

Company and beneficial ownership registers in the EU

In the EU, the backbone is formed by public company registers and beneficiary registers of the EU. For the UK, Companies House with API and open filings, and in a number of EU countries beneficial ownership registers are available (with different access modes). We often use OpenCorporates for cross-checks and OpenCorporates owner checks help quickly build the “skeleton” of a structure.

Global LEI (Legal Entity Identifier) and GLEIF provide standardized entity identification and links to subsidiary structures. For Due Diligence this is valuable: LEI speeds up entity resolution, and links to GLEIF add trust when sharing with a bank. In our practice the combination of the national trade register, GLEIF and OpenCorporates provides a strong basis for further graph analysis of ownership.

Where to check UBOs in Asia and the CIS

In Asia the set of sources is more fragmented: commercial registers, trade registries and chambers of commerce databases. The COREDO team has systematized reliable sources for UBO checks in Asia: Singapore’s ACRA, Hong Kong registries, corporate databases of the UAE (including free zones), as well as local court publications. For MENA we add checks of Arabic-language media with attention to transliteration.
In the CIS and Kazakhstan, checking company owners requires the local language and knowledge of regulatory specifics. We use company registers, court portals and publications of securities regulators. Beneficiary verification in Asia and the CIS is effective only with a human-in-the-loop: local language, variability in name spellings and corporate forms require combining automation with manual validation.

Databases and panel data for KYC

Commercial databases for KYC speed up collecting corporate structures and financial profiles. Orbis (Bureau van Dijk) helps with international links, ownership history and directors. For sanctions and PEP we use OpenSanctions as a flexible layer, and for negative news — aggregators with NLP features. OSINT screening tools like Maltego, SpiderFoot and Recon-ng are indispensable in EDD cases involving complex chains.

Panel data and adverse media are needed not only for one-off checks but also for continuous monitoring. It is important to understand the difference between “data for signaling” and “data for evidence.” The former quickly point the direction, the latter form the evidentiary base for the regulator and the banking partner.

How to handle adverse media

Data leaks and journalistic investigations (Panama Papers, Paradise Papers) are important in high‑risk profiles, but they must be handled cautiously. I recommend using them as an indicator for EDD, followed by verification against official filings and court registers. This approach reduces reputational risks from relying on unverified publications.

Social networks for owner checks (LinkedIn, Facebook, Instagram) are applicable within local laws. We use privacy-preserving search methods, capture screenshots with timestamps and always note the limits of reliability. Additionally, we use WHOIS and archives (Wayback Machine) to verify the digital footprint, especially for fintech startups without a long corporate history.

How to integrate OSINT into an AML validator

Illustration for the section «How to integrate OSINT into an AML validator» in the article «OSINT-check of beneficiaries - what sources do banks use»

Compliance architecture benefits when OSINT is not kept “on the side”, but is embedded in the AML validator and case management. On COREDO projects we build an automated screening pipeline where external and internal sources are connected via API, and results undergo normalization, entity resolution and human-machine validation.

Entity resolution and name disambiguation

Name ambiguity is the main source of false positives. We apply fuzzy matching and name matching taking into account local languages, transliteration and alias detection. Name disambiguation algorithms rely on dates of birth, positions, addresses and LEI links, as well as on local language sources and transliteration issues, which is critically important for Asia and the CIS.

To increase precision without losing recall, the COREDO team configures multi-level attribute weights and introduces human-in-the-loop for “grey” cases. This hybrid approach reduces the false positive rate in KYC and makes the solution explainable to the compliance officer and an external auditor.

Ownership analysis and hidden beneficiaries

Graph analysis of ownership makes it possible to untangle company ownership chains (ownership chains) and identify hidden beneficiaries through multi-layered structures, funds and SPVs. We use graph analysis of ownership to visualize controlling participants, thresholds at 25%/10% and trust bridges. In EDD projects cross-border linkages often emerge, and the visual graph speeds up decision-making and communication with the bank.

Beneficiary checks using graph analysis of connections pair well with data from GLEIF, OpenCorporates, Orbis and court filings. Such a “combo package” provides not only a visual, but also evidence that can be attached to the case file and used to defend the case before the regulator.

Screening APIs, SaaS and human-in-the-loop

Automating OSINT processes in a bank begins with choosing APIs for bulk beneficiary screening and integrating them into the AML case management system. In COREDO projects, SaaS OSINT platforms for banks and screening APIs are often used, covering sanctions, PEP and adverse media. For corporate structures, connectors to trade registers and OpenCorporates.

At the same time, human-in-the-loop remains mandatory, especially for EDD and disputed matches. We build workflow automation for due diligence: an automated process scans and prioritizes, an analyst confirms and documents, and the validator records the decision and creates an audit trail. Such a process is resilient to client base growth and meets regulator requirements.

Legal frameworks for risk-free OSINT collection

Illustration for the section 'Legal frameworks for risk-free OSINT collection' in the article 'OSINT checks of beneficiaries — which sources do banks use'

Legal restrictions on scraping in the EU and Asia (GDPR, local laws) are a topic I raise at every implementation. Access to open data does not mean freedom to collect and process it en masse without justification and notification. It is important to define the legal bases, retention periods, purposes and minimization mechanisms in advance.

GDPR and the legality of web scraping

The legality of web scraping in the EU depends on access conditions and the source’s copyright. We assess the legal admissibility of scraped data and try to use official APIs and licensed channels. In Asia, rules vary, and COREDO’s practice involves a separate legal memo for key jurisdictions and coordination with offshore registries or chambers of commerce.

GDPR and the processing of open data allow KYC/KYB when there is a lawful interest and a regulatory obligation, but require principles of minimization and transparency. I recommend recording the legal bases in the compliance policy and training the team to handle personal data in OSINT scenarios.

Evidence and explainability for the regulator

The evidential base (audit trail) in OSINT checks: these are screenshots, links, timestamps, hash signatures and a description of the search methodology. Evidence collection for compliance ensures reproducibility and protects the decision during regulatory oversight.

Explainability: the next layer. How to ensure explainability of OSINT results for the regulator? We keep the scoring rules, the weights used for attributes, the compliance officer’s rationale and a link to the primary source. This approach addresses questions during inspections and speeds up license approvals.

Performance and Quality Metrics

Illustration for the section «Performance and Quality Metrics» in the article «OSINT verification of beneficiaries — which sources banks use»

Without metrics, OSINT turns into a «black box». I insist on measurability: precision/recall in AML matching, false positive rate in KYC, share of manual escalations, average time per case and the quality of data sources. Metrics allow adjusting rules and proving the ROI of a business line initiative to the board of directors.

False positives: Precision/recall, FPR

Efficiency metrics for OSINT screening (FPR, recall, precision) reflect the balance between speed and quality. By raising name-matching thresholds, it’s easy to lose recall on transliterations and aliases. Therefore the COREDO team applies stratified thresholds: different rules for PEPs, sanctions and adverse media, as well as separate profiles for the EU, Asia and the CIS.
Managing false positive triggers in OSINT includes linguistic filters, local dictionaries, contextual features and black/white lists. Using linguistic analysis and NLP for adverse media is especially effective with streaming news, where it’s important to separate legal facts from opinions.

SLA, data quality scoring, monitoring

How to build an SLA with an OSINT data provider? Specify the update frequency, delivery delays, coverage of jurisdictions and quality metrics. Vendor due diligence of data providers is a mandatory part of implementation, and I recommend assessing data quality scoring by completeness, timeliness and legal permissibility of use.

Continuous monitoring vs one-time checks – the choice depends on risk and licensing. In the fintech segment we more often implement continuous monitoring of sanctions and adverse media, as well as quarterly reassessment of beneficiaries. Such a decision brings predictability and reduces the risk of regulatory sanctions.

Economics of an OSINT Platform: ROI and Budget

Executives ask me: how much does deploying an OSINT platform for KYC cost and when will the project pay off? The calculation is simple: reducing cost per onboarding, shortening time-to-onboard and reducing regulatory risks. If onboarding used to take 15 days and now takes 5–7, the bank or payment company gains in conversion and turnover.

Deployment and Onboarding Costs

The budget depends on sources (public/commercial), onboarding volume, level of automation and storage requirements. For mid-size fintech players, basic integration of screening APIs, connecting registries and configuring an AML validator fit into a modular budget that is usually spread over 3–6 months. In the Cost per onboarding include licenses, infrastructure, analysts’ time and audit.

The ROI of deploying OSINT tools in the bank’s AML processes shows up through faster decision-making, a reduced share of manual work and a decrease in risk of fines. In COREDO projects we see double-digit reductions in FPR and growth in the compliance team’s throughput without increasing headcount.

Scaling and time-to-onboard

How to scale OSINT checks as the client base grows? Horizontal scaling of APIs, task queues, prioritization of EDD cases and caching of stable sources. We also recommend separating the primary identification pipeline from monitoring so as not to block onboarding with re-checks of “slow” sources.

Time-to-onboard metric: a key indicator of customer experience. Reducing time must not reduce quality, so human-in-the-loop and risk stratification are mandatory. Continuous monitoring covers residual risks and improves the overall compliance health of the portfolio.

COREDO cases and solutions

Here: a few examples from projects where the solution developed at COREDO helped secure licensing and bank onboarding without unnecessary delays. I deliberately generalize the details to preserve confidentiality.

UBO verification for a PI/EMI license

An EU fintech was preparing for a payment institution license. The partner bank required an in-depth UBO check and ownership chain across three countries. The COREDO team gathered corporate documents and incorporation registries, engaged GLEIF, OpenCorporates and national registries. We performed the bank’s UBO verification in a “mirror” format: we replicated the bank’s logic, including OFAC/EU/UN sanctions lists, PEP screening and adverse media.

Thanks to graph analysis of ownership and entity resolution we quickly identified a previously missed director in an affiliated structure. Case management recorded the audit trail, and the regulator accepted the package without additional requests. As a result, time-to-onboard was halved, and the license was obtained on schedule.

AML OSINT for crypto in VARA/MAS/Estonia

A crypto provider operating in Dubai and Singapore was going through regulatory approvals (VARA/MAS) and bank onboarding in the EU. OSINT checks of beneficiaries included UAE free zone registries, ACRA in Singapore and the Estonian financial supervisor for VASP status. COREDO’s practice showed that a combination of OpenSanctions, Orbis and local court publications works well to identify reputational risks.

We integrated OSINT screening tools into the client’s AML validator, using KYC APIs and configuring NLP filters for negative news monitoring. Thanks to human-in-the-loop we reduced false-positive matches on similar names in the MENA and Southeast Asia markets. The bank approved the account, and regulators accepted the EDD justifications without iterations.

Asia and CIS counterparty due diligence

A trading company from the EU was expanding into Central Asia and the CIS. The task: counterparty due diligence using OSINT and LSI with a focus on hidden beneficiaries and litigation risks. The COREDO team used trade registries, local court registers, media in local languages and graph analysis of company ownership chains with name transliteration.

We identified the affiliation of two counterparties through a common UBO and historical links in registries. Documentation for the regulatory audit included data provenance, a reference list of sources and match explainability. The client received a clear, validated picture of risks and optimized contract terms.

Best practices and common mistakes

COREDO’s accumulated practice has produced a list of recommendations that improve the reliability of OSINT checks and reduce costs. Below is what most often distinguishes a mature process from “ad hoc searches” on the internet.

Banks conduct OSINT UBO checks in the EU.

  • Defining the perimeter: corporate structure, jurisdictions, licenses, transaction volumes.
  • Collecting the corporate database: EU public company registries, EU beneficial owner registries, OpenCorporates, GLEIF/LEI.
  • Sanctions/PEP: OFAC SDN list, EU sanctions, UN sanctions, OpenSanctions; configuring matching rules.
  • Adverse media: sources with NLP filters, negative news monitoring, linguistic specifics.
  • Graph analysis: ownership chains, trusts, nominee directors, documents and company filings.
  • EDD: public court registers, deal announcements and corporate news, WHOIS/Wayback for digital traces.
  • Documentation: audit trail, data provenance, legal memo on GDPR/local laws, explainability of rules.
  • Monitoring: continuous monitoring for sanctions and adverse media, periodic UBO review.
This is how banks use OSINT to check UBOs in the EU: in a structured way, with traceability and clear SLAs within the compliance function. The COREDO solution complements this approach with manual validation methods and flexible integrations.

Implementation mistakes: how to avoid them

  • Lack of a risk-based approach: the same depth of checks for all clients raises FPR and prolongs timelines.
  • Ignoring local laws: legal restrictions on scraping in the EU and Asia and incorrect legal bases undermine protection in a dispute.
  • Overestimating “major” sources: which open-source beneficial owner registries are considered reliable is an important question, but without local registries and court publications the picture is incomplete.
  • Underestimating name ambiguity: to deal with name ambiguity and fraudulent pseudonyms – use entity resolution, alias detection and linguistics.
  • Weak audit trail: without evidence collection for compliance it’s difficult to explain decisions and defend them during an inspection.
  • Lack of SLAs and quality control: how to set SLAs with an OSINT data provider and manage data quality is key to process stability.

Legal and compliance issues when using social networks to verify owners are addressed through regulation, trained roles and data minimization. For dark web monitoring, maintain strict rules and separate tools so as not to mix it with basic KYC.

Beneficiary verification system with COREDO

OSINT: not a “search engine”, but a discipline that combines sources, technologies, law and methodology. When I help clients enter the EU, the United Kingdom, Singapore or Dubai, I see how a mature KYC OSINT system removes barriers: accounts open faster, licenses are granted without delays, and compliance teams work predictably and confidently. This is what our work aims to do: integrate OSINT into an AML validator, build an evidentiary base and give businesses transparency of processes.

The COREDO team has implemented projects in the EU, Asia and the CIS – from legal entity registration to obtaining financial licenses and comprehensive AML support. We know how to combine automated and manual beneficiary checks, configure tools for OSINT screening, document decisions and pass regulator audits. If your plan is scaling, entering new markets or obtaining licenses in a complex jurisdiction, COREDO’s practical solutions will help turn compliance into a manageable and measurable process.

Ultimately, reliability is built on three pillars: correct sources, the right architecture and a team that takes responsibility for the result. I have been developing this approach since 2016, and it consistently works – regardless of the country, licensing regime or industry.

I founded COREDO when it became clear: global expansion of companies is not constrained by the speed of registration or the cost of a license, but by management’s ability to manage AML and sanctions-compliance risks systematically and demonstrably. Over ten years the COREDO team has completed dozens of projects in the EU, the UK, Singapore and Dubai, helping clients register legal entities, obtain financial licenses (crypto, forex, payment services, fintech) and build viable AML programs. In this article I have compiled the practical experience and tools I use myself and that we implement for clients. It will address the personal liability of a director, the requirements for 2026, and how to turn compliance into a strategic advantage rather than a set of punitive risks.

Why the director is in the crosshairs

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The director is not only the “tone from the top”, but also the primary recipient of claims from regulators and banks. A director’s AML liability has ceased to be an abstraction: in EU and UK practice the approach of corporate and personal accountability is actively applied, combining corporate liability for money laundering and the director’s criminal and civil liability. Courts increasingly apply the doctrine piercing the corporate veil when they see personal involvement or negligence of management, as well as ineffective internal controls.

Fiduciary duties and the standard of care for directors imply duty of care and duty of loyalty: a director must reasonably organize the AML internal control system, provide resources, appoint a qualified MLRO/AML officer and document oversight. Delegation of AML functions reduces the operational burden, but does not remove residual responsibility. Our experience at COREDO has shown: it is timely oversight by the board of directors and the reporting line, supported by minutes and metrics, that becomes key exculpatory evidence when claims arise.

Frameworks 2020–2026: what is changing

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Between 2020 and 2026 regulators accelerated the “compliance revolution.” AMLD5 strengthened beneficial ownership registers (beneficial ownership registers), expanded requirements for VASP/virtual asset service providers and enhanced EDD for high-risk jurisdictions. AMLD6 (EU Sixth Anti-Money Laundering Directive) established corporate liability, expanded the list of predicate offences and introduced liability for aiding and abetting and incitement. At the same time, FATF recommendations for management and national practices of FIU, FCA, EBA, MAS and HKMA came into effect, strengthening the emphasis on a risk-based approach (RBA) and the role of the director.

The European AML directive 2026: it is not a single document but a final configuration: a single AML rule (AMLR), the institutionalization of supranational supervision and clarification of management’s responsibilities. In 2026 companies operate in an environment where directors are expected to provide active oversight, set a risk appetite, approve threshold indicators and demonstrate the effectiveness of monitoring systems. COREDO’s practice confirms: regulators and banks check not only the existence of policies but also their implementation, KYC/KYB data, the speed of investigations and the quality of SARs.

At the same time the overlap between AML and privacy is growing: GDPR and AML data sharing require lawful bases, transparent notices and a well-considered data retention policy. These are supported by data minimization, the appointment of a DPO and clear retention periods that align with AML data retention requirements.

The director’s role in AML policy

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The director is responsible for the full viability of the AML policy, not its PDF version. This includes setting the risk appetite, appointing and overseeing the MLRO, approving RBA matrices, transaction monitoring protocols for management and an independent channel for hotlines and internal reporting of breaches. The COREDO team builds reporting lines so that the MLRO has direct access to the board and can escalate incidents without delays.

Separate section: UBO disclosure and the director’s responsibility. In complex holding structures (including offshore links) the director must ensure transparency, verify beneficial owners and record in the minutes the grounds for relying on counterparties’ documentation. Otherwise the risks of criminal liability for AML increase, especially in schemes to conceal beneficiaries and nominee-arrangements, where the risks for nominee directors are many times higher.

Delegating CSP without losing control

Many companies rely on corporate service providers (CSPs) and external corporate services. This is rational but requires governance: SLAs with KPIs for KYC/KYB, checks of the provider’s compliance culture, regular audits and an incident playbook. The responsibility of corporate service providers does not replace the director’s personal responsibility, so contracts include disclaimers of liability and indemnification, but the director documents oversight and effectiveness testing.

How a director can reduce AML risks by 2026

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I assemble a five-layer program: counterparties, transactions, sanctions/PEP, investigations and evidentiary base. This structure provides a quick overview for the board and a clear architecture for auditors.

Onboarding: KYC, KYB and EDD as a pipeline

  • KYC customer screening for companies and KYB for corporate counterparties is built on risk stratification: jurisdiction, industry, product, channels. Enhanced due diligence (EDD) obligations are activated by red flags: complex trusts, politically exposed persons (PEP), links to high-risk countries, and cross-border transactions with atypical transaction economics.
  • Sanctions compliance and the director’s personal risks require sanctions screening across multiple sanctions lists, PEP checks and conflict-of-interest management. To reduce false positives through data enrichment we connect external data and transaction context, which increases scoring accuracy.

Transaction monitoring and alerts

  • Real-time transaction analytics and alerts are important, but their value is determined by the process: a closed loop from detection to investigation and SAR. The COREDO team implements a risk-based approach (RBA) in rules, configures threshold indicators and key AML metrics: investigation speed, FP rate, SAR rate and the share of cases with confirmed economic substance.
  • For digital assets, AML requirements for directors include blockchain analytics and transfer tracing, accounting for the travel rule for virtual asset providers and risk management of crypto conversion services. AML specifics in DeFi and smart contracts require scenarios for self-hosted wallets, mixer risks and chains with bridges.

Documentation as protection for the director

  • Directors and evidence of good faith (exculpatory evidence) are built on keeping compliance logs and proofs of good faith: board minutes, MLRO reports, a refusal-to-serve log, EDD checklists and the rationale for decisions on non-standard cases.
  • The SAR filing process and MLRO duties are important not only legally but also reputationally. The director ensures resources for timely reporting of suspicious activities (SAR), as well as legal privilege and information sharing during investigations: through agreed channels with external lawyers.

Incident management and investigations

  • A playbook for internal AML investigations includes triggers, team composition, timelines, evidence retention rules and a communication plan with banks and the FIU. Incident management for suspicious activities should complement, not replace, the SAR process.
  • Remediation programs and appointing an independent monitor can be mitigating factors. COREDO’s practice confirms: a transparent remediation roadmap and checkpoints at 30/60/90 days help reduce regulatory risks.

Training for staff resilience

  • A director’s AML duties in 2026 include personal training: training programs for top management and proof of AML training are recorded in HR systems and board minutes. This is critical as evidence in an AML investigation against the director.
  • D&O insurance and AML risk coverage reduce financial consequences, but it’s important to understand exclusions in the D&O policy for AML breaches. I recommend an annual gap analysis: what is covered, what is excluded, and what limits are needed for cross-border claims.

Cooperation with banks and regulators

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Interaction with regulators and investigations: an area where the director sets the tone. Regulators EBA, FIU, FCA, MAS, HKMA expect a mature dialogue: a clear reporting structure, readiness for thematic reviews and regulator inspections, and documented risk governance. In cross-border cases mutual legal assistance and international cooperation come into play, which requires consistency of data and a coherent legal strategy.

Interaction with banks and the director’s role in KYC processes go beyond the onboarding package. Correspondent banking and enhanced monitoring require advance preparation: a description of the business model, sources of funds, sanctions policy and an SAR playbook. The solution developed at COREDO includes a “dossier for the bank” with compliance metrics, which reduces the number of follow-up queries and speeds up onboarding at international banks.

AML Economics: CAPEX vs OPEX ROI Metrics

A strong compliance program pays off if you measure it. AML economics: CAPEX vs OPEX when implementing systems should rely on TCO and clear KPIs: reduction of FP rate, speed of escalations, conversion of alerts into SARs and time to close investigations. The technology stack for an AML office: monitoring and screening includes sanctions and PEP lists, case management, graph-based link searches, blockchain analytics and BI.
Cost optimization of an AML program for holdings is achieved through centers of competence, unified standards and local adaptations. Regulatory sandboxes for crypto companies (for example, in Singapore or certain EU jurisdictions) help test monitoring without the risk of a “production outage”. At COREDO we built pilots where reductions in false positives reached double-digit percentages thanks to data enrichment and dynamic thresholds.

COREDO case studies: licenses, registration, AML

  • EU and payment services. The COREDO team supported company registrations and obtaining EMI/PI licenses in the EU, building a sanctions screening policy, EDD protocols for high-risk clients and board oversight through quarterly MLRO reports. The correspondent bank approved the account after presentation of the “director’s dossier” with exculpatory documentation.
  • Forex and investment services in Cyprus. For a multi-jurisdictional group we implemented AML procedures for holding structures, developed a risk appetite with threshold indicators and conducted an AML audit and formalized management’s responsibilities as an annual calendar. As a result, the company passed the regulator’s thematic review without sanctions.
  • Crypto and digital assets in Estonia, the UK and Dubai. Our experience at COREDO showed that the travel rule and blockchain tracing require leadership attention. We built monitoring protocols, implemented a hot/cold wallets policy, addressed risks of crypto conversion services and established cooperation with the FIU on SARs. In Dubai the project was based on the local regulator’s requirements and international FATF standards.
  • Asia and payment licenses. In Singapore the project included third-party risk management and vendor management, the intersection of GDPR-like rules with AML, as well as interaction with banks on KYC. The client obtained a license, and the board received clear performance metrics.

In all cases we took into account risk-based Due Diligence in M&A and the risk of personal liability, especially when acquiring portfolios inherited from regulated entities. In two projects the board approved defensive strategies: exculpatory documentation and protocols for closing historical “tails”.

Board risk management

Compliance culture and board accountability are evident in three situations: during scaling, in a liquidity crisis, and when winding down the company’s operations and the risks to former directors. In the wind-down phase the director documents client exits, notifications to regulators, data retention and the end of monitoring; otherwise civil-law sanctions and disqualification from managing a company are possible.

In cross-border transactions the risks of facilitation and the commission of crimes through corporate channels increase, especially in correspondent payments and agency schemes. I recommend limitation-of-liability and indemnification clauses in agreements with partners, but always with confirmed oversight. Where there are sanctions or secondary sanctions, the director personally assesses the risk of refusing to proceed with the transaction.

Transfer and Transitional Provisions 2026

Compliance Revolution 2026: requirements for executives strengthen the director’s role in demonstrable risk management. The transfer and transitional provisions of the AML reforms provide adaptation periods, but regulators expect interim results: system pilots, training, initial metrics. At COREDO we prepare clients in advance for thematic inspections: forensic accounting expertise in investigations, asset confiscation and recovery, as well as international legal assistance require a coordinated strategy and a playbook for internal AML investigations.

Director’s daily plan: concrete steps

  1. Week 1–2: update the risk map, approve the risk appetite and AML threshold indicators. Re-check UBO disclosures and beneficiary registers, close documentation gaps.
  2. Week 3–4: conduct a sanctions screening stress test, review PEP and EDD protocols for high-risk clients. Approve onboarding workflows and red-flag indicators.
  3. Week 5–6: launch an audit of transaction monitoring, evaluate real-time alerts, implement reduction of false positives through data enrichment. Configure key AML metrics and board reports.
  4. Week 7–8: conduct training for the board, MLRO and senior executives; record evidence of training. Update the D&O policy and verify exceptions related to AML violations.
  5. Week 9–10: sign SLAs with the CSP and critical vendors, strengthen supplier risk management and the board’s accountability. Re-check the SAR filing process and legal privilege.
  6. Week 11–12: conduct a thematic review of readiness for a regulatory visit, prepare exculpatory evidence: minutes, reports, decision log, remediation plan.

What the director gets: managed risk

When a director runs the program as described above, they don’t get “tick-boxes” but protection: evidence of due diligence, clear control over residual risks, and stable relationships with banks. At COREDO we measure compliance ROI not in words but in numbers: investigation speed increases, the share of false positives decreases, SARs are filed on time, and onboarding at banks is faster.
The solution developed by COREDO combines strategies for the EU, the UK, Singapore, Dubai and CIS countries. We take into account FATF recommendations and their implementation, AMLD5/AMLD6 requirements, the specifics of licenses (crypto, forex, payment services), as well as the reality of cross-border operations. This approach builds trust and gives management the freedom to act.

Conclusions

I believe in compliance as a growth strategy. A director who invests in AML governance gains a sustainable business model and demonstrable integrity. The COREDO team helps to move from policy on paper to a living system: from company registration and obtaining financial licenses to building AML procedures for holding structures, digital assets and complex cross-border models.

If you are preparing your business for the 2026 requirements, start with manageable steps: risk appetite, board oversight, monitoring technologies, documented SAR practice and management training. COREDO’s practice confirms: this order of actions reduces directors’ personal AML-related risks and strengthens the company’s position in the international market.

When I launched COREDO in 2016, fintech seemed like a race of ideas. Today it’s not ideas that win, but sustainable models: legally sound, regulatorily mature, and operationally reliable. Over the years the COREDO team has implemented dozens of projects for registering legal entities in the EU and Asia, obtaining electronic money (EMI) licenses, setting up AML/CFT, and providing comprehensive support for payment businesses. In this article I have compiled what actually works, where entrepreneurs typically “lose” time and capital, and how to build a roadmap to a license so that in a year we are discussing scaling, not remediation.

Why it makes sense to build an EMI in the EU today

Illustration for the section «Why it makes sense to build an EMI in the EU today» in the article «EMI license in the EU: how to choose a country with the lowest regulatory risks»

The EU payments market remains one of the most sizable and predictable. The EMD2 and PSD2 regulatory framework sets clear rules, and the passporting mechanism allows services to scale quickly across the Union. For many of our clients, registering a payment company in the EU is not only about access to SEPA and IBAN, but also about access to a reliable correspondent network and partnerships with leading card providers.

At the same time, EMI regulation in Europe has become more complex: the EBA has raised expectations for governance, safeguarding and cyber resilience, and national regulators are carefully testing “fit and proper” and substance. Our experience at COREDO has shown: those who win are the ones who build an operating model from day one to meet supervisory requirements, rather than trying to “fine-tune” it at the last minute.

Regulatory map: EMD2, PSD2, EBA and national regulators

At the core: the Electronic Money Directive (EMD2) and the Second Payment Services Directive (PSD2). The first defines what electronic money is and how to issue it; the second sets the framework for payment services, access to accounts and security requirements. EBA recommendations complete the picture: from governance and internal controls to incident reporting and outsourcing requirements.

National regulators — Bank of Lithuania, Central Bank of Ireland, BaFin, ACPR/ Banque de France, De Nederlandsche Bank, Banco de España and others — implement these rules through local guidance and expectations. It is important to understand the principle of home state control vs host state supervision: obtaining an EMI license in the country of domicile and operating across the EU via passporting is easier than trying to obtain several local licenses.

Choosing a country for an EMI license: a strategic crossroads

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COREDO often starts with the question: how to choose an EU country with the lowest regulatory risks for an EMI license? I suggest looking at four dimensions at once: EMI capital and substance requirements, timelines for obtaining an EMI license and the regulator’s readiness to engage in dialogue, the availability of banking infrastructure and correspondent relationships, and the total cost — from licensing fees to OPEX for compliance and reporting.

Lithuanian EMI license: advantages and risks

Lithuania has become a magnet for fintech thanks to the Bank of Lithuania, its transparent processes and reasonable timelines. For companies with a clear model of issuance of electronic money and e-wallets, integration into SEPA and ready technology, this is a fast route to market. Passporting an EMI in the EU via Lithuania works predictably, and the regulator is open to constructive engagement.

Risks: a high threshold of expectations regarding substance, real management and local managers, as well as close attention to safeguarding mechanisms and correspondent banks. For COREDO clients, an important part of the project here becomes early confirmation of access to safeguarded accounts and building relationships with banks from the “white list”.

EMI license Ireland: requirements and expectations

The Central Bank of Ireland is traditionally strict on governance, the senior managers regime and independent directors. In return, Ireland provides strong access to the talent pool and the ecosystem of international payments players. Requirements for cybersecurity and operational resilience here are above average, but predictable. If your goal is partnerships with global brands and a project with a high level of risk management, Ireland is a strong option.

Malta EMI license: for fintechs with an international model

Malta is attractive for its flexibility and access to an English-language legal environment. The MFSA pays close attention to AML/CFT and outsourcing, but timelines are negotiable if you can demonstrate a mature risk-based approach and technological readiness. For fintechs planning card acquiring and multicurrency wallets, Malta can provide a good entry point, but enhanced controls on reporting and audits will be required.

Capital, own funds and safeguarding: financial resilience of EMI

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Minimum initial capital for an EMI in the EU depends on the business model, but basic thresholds are defined by EMD2 and local acts. In addition to start-up capital, regulators expect own funds, calculated according to prudential requirements taking into account issuance volumes and payment operations. In COREDO’s practice, confirmation of the source of capital and the stability of funding is one of the first things we prepare for the meeting with the supervisor.

Safeguarding is the cornerstone. Requirements for the safekeeping of funds (safeguarding) imply segregation of client funds in trust accounts or segregated accounts, or insurance/guarantee mechanisms. We choose the option taking into account the availability of banks and the cost of capital. The solution developed by COREDO for one of the projects included a multi-bank safeguarding model with automatic rebalancing according to risk limits.

Correspondent banks and access to SEPA/IBAN

Key operational risk for an EMI: correspondent relationships and de-risking. Correspondent banks and EMIs often “look” at each other through the prism of industry risk statistics. Here it is important to demonstrate mature AML/CFT, a transparent ownership structure and a clear client geography. Our COREDO practice confirms: a preliminary AML audit and stress-testing of monitoring scenarios increase the chances of opening safeguarded accounts and gaining access to SEPA.

Organizational structure and substance

Subsidiary vs branch: it’s not only a matter of legal formality, but also regulatory perception. A subsidiary structure gives more sovereignty over governance and independent directors; a branch can sometimes speed up the process but is more complicated regarding local management and tax substance. I prefer the subsidiary model for an EU electronic money license if the goal is long-term scalability.

Place of effective management (mind and management), risk/audit committees and independent directors are not “tick-boxes” but the basis of dialogue with the regulator. Fit and proper tests for key executives assess not only experience but also the ability to challenge risk. In COREDO projects we set up in advance the calendar of meetings, responsibility matrices and evidence of local management involvement.

Tax substance and transfer pricing for EMIs: areas of increased scrutiny. It is important that functions and risks are located where the income arises, and that the transfer pricing policy is documented. This directly affects the perception of substance and reduces regulatory risks of an EMI license during cross-border inspections.

Licensing procedure: from the business plan to interaction with the regulator

How to obtain an EMI license is a question of discipline. The business plan for an EMI application must reflect unit economics, customer portfolio strategy, risk appetite and a governance plan. Licensing documentation includes AML policies/CFT, safeguarding, IT security, outsourcing, an incident plan, a 3–5 year financial model and a description of the technological architecture.

Fit and proper, senior managers regime and governance: an area where many waste time. The regulator assesses the management team, their powers, independence and the system of internal control. In one project the COREDO team replaced “nominal” roles with real functional leaders, added an independent director with banking experience and disclosed the risk escalation mechanism; the application passed the interview without additional cycles.

Timing and cost. Typical licensing timelines are 6–12+ months, depending on the country and the applicant’s readiness. Costs for obtaining an EMI license consist of consultants’ fees, government charges, audit costs and the launch of internal systems. Annual OPEX includes compliance, reporting, audit, AML systems, cybersecurity and the board of directors. I always advise allowing a 12–18 month financial “buffer” to withstand pauses on regulator queries.

AML/CFT and compliance: a system trusted by banks and regulators

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EU regulators operate according to AMLD5/AMLD6, FATF and EBA recommendations. The working standard, a risk-based approach to AML: client segmentation, KYC/CDD by risk levels, PEP screening, sanctions screening, geographic indicators and continuous revision of risk profiles. For one client COREDO implemented KYC-as-a-Service with independent verification and centralized third-party management: this reduced CAC and simplified auditing.

Transaction monitoring is the heart of the system. You need a combination of rules, scenarios and machine learning, clear thresholds for CTR, STR procedures and escalation protocols. It’s important to ensure end-to-end traceability of the solution: from trigger to report. We often carry out a cost-benefit analysis of AML systems implementation to avoid “gold-plated” IT and preserve alerting accuracy.

Outsourcing and third-party risk is an area where regulators have become stricter. In contracts for cloud hosting and KYC providers we establish the right to audit, BCP/DR plans, data location requirements and incident reporting deadlines. The COREDO team pre-defines control points and termination criteria to avoid vendor lock-in.

Technological and operational resilience

Cybersecurity and incident reporting, a mandatory layer. You need policies on access, encryption, vulnerability management, penetration testing and response plans. Regulators expect incident reports within set deadlines and evidence of lessons learned from incidents. GDPR defines the contours of working with personal data, consents, DPIA and data subject rights.

Operational resilience is not only data centers and clouds, but also business continuity. BCP/DR should have tests, critical RTO/RPO and scenarios for loss of a correspondent bank. In one project COREDO modelled a switch to backup safeguarded accounts within 48 hours: that proved the operational model’s maturity to the regulator.

Tokenization and stablecoins are a borderline area. E-money is the issuer’s obligation, not a crypto-asset. If the product involves work with stablecoins or tokenization, it’s important to clearly separate payment services and any digital asset elements so as not to exceed the scope of the EU electronic money license and to avoid falling under additional regimes. We pre-agree the architecture with the regulator to avoid surprises.

Market strategy and ROI

ROI metrics for an EMI should be pragmatic: CAC by segments, LTV accounting for churn and interbank fees, unit economics by product, payback period. I ask teams to show base, realistic and stress scenarios, including de-risking by banks and delays in integrations.

Passporting and scaling in the EU is a strong driver of ROI. But remember host state supervision: some countries impose additional requirements on notifications, marketing localization or reporting. At the initial stage we focus on 3–5 countries with the best ratio of market size to requirements.

Scaling in Asia and the Middle East requires different approaches. Singapore and Dubai have separate licensing regimes; EU passporting does not work there. COREDO supports clients in these jurisdictions through local licenses and partnerships, often using the European EMI as an “anchor” center of competence and risk management.

Risks and scenarios: from revocation to remediation plans

Grounds for license revocation: systemic safeguarding failures, insufficient capital, weak AML/CFT, a management vacuum, critical incidents without remediation. In COREDO’s roadmap there is always a playbook: triggers for capital reinforcement, quick provider replacement, AML forensics and communication with the regulator.

How to minimize regulatory risks when entering the EU market? First, a transparent ownership structure and beneficial ownership registers. Second, substance and the place of real management. Third, a stress-test of own funds and a plan in case of transactional volume growth. Fourth, regular internal audits and independent AML/CFT reviews.

Exit strategy and M&A. EMI: an asset whose value depends on compliance quality. We pre-plan options: portfolio sale, merger, conversion to another license type, transfer of operations between subsidiaries and branches (corporate structure rework). Such flexibility reduces risks and increases ROI.

COREDO Case Studies

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  • Registration of a payment company in the EU with passporting. Client: a multcontinental group, target segment: SMB cross-border. We prepared the business plan, financial model, governance, substance, conducted a fit-and-proper assessment, obtained an EMI license and set up passporting for five countries. Result, entry into SEPA in 10 months and stable access to correspondent banks.
  • Launch of an EMI for a crypto-fiat on-ramp. Task: clear separation of e-money and digital assets. The COREDO team developed a tokenization policy, AML/CFT for conversion scenarios, sanctions screening and transaction monitoring. The regulator accepted the architecture, correspondent banks approved safeguarded accounts provided that flows were segregated.
  • AML remediation and restoration of banking access. The client faced de-risking and a requirement to strengthen monitoring. COREDO’s practice proved effective: targeted calibration of scenarios, implementation of independent KYC and team training, revision of thresholds for STR/CTR. Within 90 days we restored two correspondent lines and closed the regulatory order.

Answers to common strategic questions

  • What are the key regulatory risks for a business when opening an EMI in the EU and how to mitigate them? These are capital adequacy, safeguarding, AML/CFT, governance and cyber resilience. We mitigate them through early gap analysis, capital stress testing, an independent AML audit, BCP/DR and an incident reporting plan.
  • How to compare licensing cost, capital requirements and time-to-market? We build a matrix: country × time-to-market × minimum capital × banking availability × OPEX. We take into account license fees and administrative expenses, as well as cost of compliance over a 3-year horizon.
  • Which ROI metrics to use? CAC, LTV, unit economics by transaction types, share of safeguarding cost in revenue, payback and NPV with a risk discount.
  • How to structure a corporate group and operating model to scale across Europe and Asia? A subsidiary in the EU as the licensing hub, branches for operations and marketing, separate local licenses in Asia, shared services for IT/AML, and a transparent TP model.
  • What are the long-term consequences for banking access from choosing a jurisdiction? The choice of country affects banks’ perception, the speed of account openings, access to SEPA and partnerships with card schemes. A jurisdiction with strong supervision can increase banks’ trust, but will require higher OPEX.
  • Which exit scenarios and license revocation risks should be planned for in advance? A remediation plan, capital strengthening under stress, provider switch options, M&A and mothballing operations with protection of client funds.
  • What requirements for the place of effective management and substance are critical? Local directors, making key decisions in the licensing country, physical presence, independent committees and documented functions.
  • What is the typical cost of annual compliance (OPEX) and how to optimize it? It includes audit and reporting for EMI, AML systems, cybersecurity, board of directors, software licenses. We optimize through risk-oriented outsourcing, KYC-as-a-Service, harmonizing reporting under the EBA and automation of monitoring.

Practical checklist from COREDO before applying to an EMI

  • Confirm minimum own capital and sources of funds, calculate own funds according to prudential requirements taking into account peak volumes.
  • Demonstrate safeguarding mechanisms: agreements for trust/segregated accounts, daily reconciliation policy, backup bank.
  • Establish governance: independent directors, committees, authority matrix, conflicts of interest policy.
  • Build AML/CFT: KYC/CDD, PEP and sanctions screening, transaction monitoring, STR/CTR, training, internal audit.
  • Prepare the technology base: cybersecurity requirements for EMI, incident log, BCP/DR plan, DPIA under GDPR.
  • Describe outsourcing and third-party management: SLA, audit rights, data location, replacement plans.
  • Develop a market entry strategy and financial model: ROI, CAC/LTV, de-risking scenarios, a map of passporting and local requirements.

How we work at COREDO: process, roles, transparency

The project roadmap typically includes four stages: pre-licensing diagnostics and jurisdiction strategy; governance, AML, and IT architecture; compilation and submission of the application package, interaction with the regulator; launch of operations, passporting, and reporting setup. Each phase has readiness metrics and checkpoints, and communications follow the timeline agreed upon at the start.

I am personally responsible for key negotiations with the regulator and complex structural crossroads. It is important to me that the application reflects the real business and withstands scrutiny not only at the licensing stage but also after two years of active growth. In projects where COREDO acts as a long-term partner, the speed of decision-making and transparency of processes become our shared competitive advantages.

Conclusion: what to do now

  • Identify target markets and align them with passporting opportunities. If Asia is a priority, add local licenses to the scaling plan.
  • Conduct an honest gap analysis on capital, safeguarding, AML/CFT and IT. Fix the gaps before engaging with the regulator.
  • Prepare the team for fit and proper: real roles, independent directors, a clear governance calendar.
  • Early dialogue with correspondent banks is critical. Without safeguarded accounts, a license doesn’t turn into a business.
  • Assess ROI and OPEX across three scenarios. A strong financial model is your language with the regulator and banks.

COREDO builds projects that are a pleasure to look at years later. If you’re designing an EMI license in the EU, looking for answers on PSD2 and EMI licensing, planning passporting and a bank relationship strategy, we have practical solutions and the experience to deliver results. Contact us, and together we’ll turn your idea into a sustainable payments business.

I have been managing COREDO since 2016 and I see: the relocation of a fintech company between jurisdictions is no longer an exception. It is a practical tool for managing regulatory risks, scaling and reducing operating costs. But every fintech company relocation is not just about a “new license”; it is about the business model, substance, the AML framework and resilience to supervisory stress.

Our experience at COREDO has shown that a successful transition does not begin with choosing “where a permit will be issued faster”, but with the question “which market, regulatory regime and tax status will deliver the best return with controlled risks”. In this article I have compiled a practical guide for executives and CFOs responsible for international company registration, Licensing and compliance. I will be specific, drawing on COREDO’s practice in the EU, the United Kingdom, Singapore, Dubai and a number of Asian and European jurisdictions.

When should fintech companies change their jurisdiction?

Illustration for the section «When fintech companies should change their jurisdiction» in the article «Relocation of a fintech company between jurisdictions - regulatory traps»

Relocation makes sense when the combination of regulatory pressure, bank de-risking and the tax model makes the current jurisdiction less competitive. Often the trigger is a change in rules, for example requirements for safeguarding client funds or capital adequacy for EMI/PI, which have sharply affected unit economics. In that case relocation allows you to preserve margins and access to payment rails.

The second scenario is limited scalability. If PSD2 passporting is unavailable or has been lost after corporate changes, or local rules do not recognise the agent or distribution model, it is sensible to consider restructuring: a subsidiary in the EU, a local license instead of an agency scheme, or moving core functions to a jurisdiction with stable banking access. COREDO’s practice confirms: a timely transition prevents the cascade risk of correspondent account closures and loss of the client base.

Finally, relocation is justified when the new jurisdiction objectively increases market trust: supervisory reputation, the presence of a RegTech ecosystem, stability of interaction with the FIU, and predictability of onsite inspections. These factors directly translate into the cost of capital raised and the speed of integrations with partner banks.

Risks and the business model of relocating

Illustration for the section “Risks and business model when relocating” in the article “Moving a fintech company between jurisdictions - regulatory traps”
Regulatory mapping and gap analysis

Any project begins with regulatory mapping: we build a map of requirements in the current and target jurisdictions, compare PSD2/EMI/PI, MiCA/AMLD5–AMLD6, local safeguarding and governance rules. The COREDO team has implemented dozens of such maps and sees a recurring pattern: significant “gaps” lie in governance (the role of independent directors, frequency of committees), transaction monitoring (SAR rules, TMS scenarios) and data governance (GDPR, data localization).

The gap analysis covers: licensing (local license requirement vs license passporting), FIU reporting obligations and SAR submission deadlines, requirements for UBO disclosure and beneficial ownership registers, equivalence of sanctions screening, as well as supervisory cooperation and information exchange between regulators. The result: a remediation roadmap with budget and KPIs.

How relocation affects business and ROI

Change of jurisdiction affects ROI through four channels: capital requirements (capital adequacy for EMI/PI), the cost of safeguarding (trust vs ring-fencing), compliance costs (CCO staff, TMS/RegTech), and taxes (transfer pricing, tax residency of management and the company). The solution developed at COREDO includes a financial model with sensitivity to de-risking of correspondents, sanctions screening and the probability of onsite inspections.

We reduce the financial model to metrics: CAC/LTV after transfer, the share of AML-related blocks, delays in cross-border payments (SEPA/SWIFT), and the “license price” in annual operating costs. With significant capital controls or currency regulation we add a liquidity risk coefficient.

Structure, substance and governance

Substance: not about the “legal address.” Regulators test managerial substance: whether management decisions are actually made in the jurisdiction, whether there is an office, key personnel, regular board meetings. I constantly stress to clients: lack of substance is a direct risk of license refusal and subsequent supervisory enforcement.

Corporate structure and tax optimization during relocation must comply with transfer pricing rules and tests of beneficial ownership of income. We use a matrix: functions (governance, risk management, AML), assets (TMS, core banking), risks (credit, operational) — and allocate them among group companies so that the tax residency of management does not conflict with the license and reporting.

Correspondent account compliance

De-risking of banking correspondents is one of the most painful topics. Banks terminate relationships when sanction pressure rises, when working with high-risk jurisdictions, or when screening against OFAC/EU lists is insufficient. I advise building correspondent banking relationship management as a strategic function: regular meetings, sanction compliance scenario tests, and reports on screening effectiveness.

The COREDO team implemented a sanctions framework for clients taking into account the FATF greylist, international sanctions control networks and local advisories. This helped protect positions in the payment rails and reduce the risk of sudden disconnections.

Licensing PSD2, EMI/PI, MiCA and VASP

Illustration for the section 'Licensing PSD2, EMI/PI, MiCA and VASP' in the article 'Relocating a fintech company between jurisdictions - regulatory traps'

Licensing and “migration” of licences comes to the fore when a company changes jurisdiction or product matrix: this concerns PSD2, EMI/PI, MiCA and VASP. Let’s examine which elements can actually be transferred when changing jurisdiction, and what will require re-certification and adaptation to new requirements.

License transfer when changing jurisdiction

The term “migration of an e-money licence” or “transfer of a payment institution licence” is often used, but literally the licence does not “move”. In most cases it refers to obtaining a new licence in the target jurisdiction, parallel work on passporting (if available in the EEA) and a structured wind-down of the old permission. Exceptions: rare cases of re-domiciliation while preserving legal succession, but this is rather a corporate reorganisation followed by reauthorisation.

COREDO’s practice confirms: a properly planned transition includes a regulator-agreed plan for transferring operations, safeguarding and communications with clients and agents. This reduces the risk of service interruption and supervisory claims.

Registration of an entity for PSD2 passporting

registration of a legal entity in the EU for fintech is not a formality, but the foundation for passporting. License passporting under PSD2 within the EEA allows providing payment services via notifications, but does not replace a local licence outside the EEA. Equivalence decisions improve cooperation and sometimes speed up banks’ due diligence, but do not substitute authorisations.

We start interaction with the regulator with pre-approval consultations and regulatory notifications. Supervisory cooperation simplifies the exchange of information when transferring clients and agents, especially if an agent distribution model is used.

Safeguarding and capital requirements

Capital requirements for EMI/PI depend on the volume of operations and the risk profile; capital adequacy is an area of close attention during relocation. I separately review models for safeguarding client funds: trust accounts, ring-fencing, escrow and trustee accounts. Regulators assess the frequency of reconciliation, the procedure for liquidity stress-testing and plans in the event of a partner bank default.

Liquidity and e-money requirements include rules on the immediate availability of funds and the independence of managers of client funds from the company’s commercial cashflow. During the transition period it is critical to ensure continuity of safeguarding and the correct transfer of balances.

MiCA, VASP and the travel rule in crypto

Licensing a crypto company in the EU is undergoing qualitative changes because of MiCA. VASP registration in Europe increasingly becomes a full authorisation with an emphasis on governance, risk management and consumer protection. The travel rule for crypto transactions is becoming a standard; non-compliance is a frequent reason for banks to refuse service.

Licensing crypto-assets requires a licensing checklist: descriptions of tokenomics, KYC procedures/CDD and EDD for PEP, transaction monitoring with SAR rules and on-chain analytics, as well as a sanctions screening policy covering EU and OFAC lists. The COREDO team runs MiCA projects with a focus on integrating AML systems and addressing conflicts between blockchain privacy technologies and regulatory expectations.

Licensing timelines

Timelines for obtaining a fintech licence in the EU usually range from 6 to 12 months, in Asia: from 4 to 9 months, depending on the completeness of the document package, substance and the maturity of compliance. There are sandbox programmes (FCA, MAS, BaFin) that shorten the path to product testing but do not replace full licensing. Sandbox exit strategy: a mandatory part of the plan: commercialisation, migration of clients and compliance with the full set of requirements.

Agreements on mutual recognition of licences are encountered sporadically, more often in capital markets or insurance, and not in payments and e-money. Therefore, when relocating a fintech I rely on local licensing or passporting within the EEA.

Sanctions framework during AML/CTF relocation

Illustration for the section 'Sanctions framework during AML/CTF relocation' in the article 'Moving a fintech company between jurisdictions - regulatory traps'

When relocating a company it is critically important to consider AML/CTF issues and build an effective sanctions framework to minimize legal and operational risks.

risk-based approach in AMLD5/AMLD6

Risk-based approach is the basic methodology. We combine FATF recommendations, AMLD5 and AMLD6 requirements and local empirical regulatory practices. The risk matrix includes geography, product type, customer behavior, partner and agent risk. FIU reporting obligations are documented specifying transaction thresholds, SLAs for filing SAR/STR and escalation procedures.

An important element is preparing for supervisory enforcement trends: regulators check not only the existence of a policy but also evidence of its implementation. I recommend conducting mock onsite inspections and independent AML audits before submitting the license.

KYC, CDD, EDD and UBO

KYC/CDD policies should cover identity, address and source-of-funds verification; EDD should pay attention to PEPs and customers from high-risk jurisdictions. KYB (Know Your Business) is mandatory for partners and agents, including verification of corporate structure, UBO and sanctions status.

Verification of beneficial owners (UBO) during relocation is often complicated by differences in beneficial ownership registers and the public availability of data. We use multiple sources to verify the beneficial owner: government registers, international databases, data provider reports and corporate documents with an apostille. This reduces the risk of a bank refusing onboarding.

Transaction monitoring and RegTech

Transaction Monitoring systems and SAR rules: the heart of the AML framework. I insist on risk-scoring models responsive to the patterns of the specific business, and on effectiveness metrics: share of alerts resulting in SARs, alert closure time, and escalation rate. AML monitoring metrics and KPIs for the CCO are formalized in the policy and reviewed quarterly.

Integration of AML systems during mergers and relocation requires migration of historical data, regression testing of rules and their implementation into core banking and TMS. The solution developed at COREDO includes a RegTech stack (KYC, KYB, TMS) taking into account GDPR, data localization and performance at peak volumes.

Sanctions and high-risk jurisdictions

Sanctions compliance: not only screening for OFAC/EU, but also a policy to control transactions with high-risk jurisdictions, monitoring the FATF greylist and local restrictions. The sanctions framework should be validated by regular testing, staff training and independent audit.

In international practice we see an increasing importance of engagement with correspondent banks on sanctions: joint tabletop exercises and analytical exchange help preserve access to SWIFT and the resilience of cross-border payments.

Operational: data, payment rails

Illustration for the section «Operational: data, payment rails» in the article «Moving a fintech company between jurisdictions - regulatory traps»

Operational issues include data, payment rails and outsourcing, three pillars on which regulatory compliance and service quality depend.

GDPR, localization and data privacy

Cross-border data transfers are subject to GDPR requirements and local personal data protection laws. Data localization may be required for specific markets; we define storage architecture and access routes in advance. Privacy conflicts between blockchain technologies and regulators are resolved through selective disclosure, cryptographic proofs and the delineation of controller and processor roles.

In critical processes: agreeing the DPA with providers, DPIA for high-risk operations and an incident response procedure.

Payment rails and anti-fraud

Cross-border payment rails (SEPA, SWIFT, IBAN) require strict compliance with AML and sanctions procedures. Anti-fraud controls and chargeback management must be synchronized with the TMS to avoid conflicting decisions and reduce false positives.

PSD2 SCA requirements for authentication apply in parallel. Incorrect SCA implementation hurts conversion, so we validate UX and risk-scoring for exemptions while maintaining compliance with regulatory expectations.

Compliance outsourcing and agents

Outsourcing compliance functions saves costs but carries risk. Regulators require the licensed entity to retain decision-making responsibility, to supervise the provider and to have a business continuity plan. I recommend splitting outsourcing into operational (KYC onboarding, screening) and analytical (model risk management) and explicitly defining metrics.

Agent banking and the agent distribution model are powerful tools, but regulatory traps are obvious: limits on delegating licensed functions, requirements for agent training and monitoring, and KYB for partner networks.

Safeguarding and wind-down during relocation

Safeguarding client funds during relocation: an area of heightened attention. The license closure procedure and transfer of operations must include agreement with the regulator, client notifications, transfer of trust/escrow agreements and an independent reconciliation of balances.

The contingency plan (contingency planning) provides for surrendering the licence and an orderly wind-down if relocation takes longer or the regulator requires additional conditions. This reduces legal and reputational risks.

Taxes and reporting in corporate governance

Tax issues, accurate reporting and corporate governance practices directly affect a business’s financial stability and managerial risks.

Tax consequences of transfer pricing

Tax consequences of changing a fintech’s jurisdiction affect overall profitability. Analysis of regulators’ expectations regarding transfer pricing and taxes is no less necessary than licensing analysis. Group reporting, transfer pricing policy and allocation of functions in the value chain must be aligned with substance and risk management.

We also take into account capital controls and currency regulation: restrictions on capital outflows, reporting on foreign exchange transactions and requirements for documenting intercompany settlements.

Supervision and reporting

Supervisory requirements and reporting for fintech companies vary, but the overall trend is increased frequency and depth. Regulatory notifications and pre-approval consultations reduce the risk of ‘surprises’. We prepare a package in advance for onsite inspections: policies, training logs, AML KPI reports, committee minutes.

Whistleblowing processes and internal investigations are a mandatory component. They are part of a risk management culture and an important element during inspections.

How governance affects reputation

The impact of corporate governance on obtaining a license cannot be underestimated. The composition of the board of directors, independent members, risk and compliance committees: these are signals to the regulator. Legal entity management during restructuring must ensure continuity of authority and transparency of beneficial ownership.

Reputational risk management and crisis PR are not secondary. Regulators and banks closely monitor incident management, information disclosure and readiness for stress.

M&A and due diligence: exit strategies

In M&A transactions for fintech companies, a detailed Due Diligence is especially important — it shows not only the financial condition but also the resilience of the technology platform and compliance with regulatory requirements.

Due diligence when buying a fintech

Acquiring a licensed asset speeds up market entry but increases risks. Due diligence when buying a fintech in another jurisdiction includes vendor due diligence, third-party risk, KYB checks of counterparties and agent networks. We check the quality of AML programs, the history of FIU reporting, inspection results and outstanding regulatory orders.

The COREDO team handles such deals with a focus on regulatory gaps and a remediation plan to avoid surprises after closing.

Mistakes when opening a subsidiary

Regulatory traps when opening a subsidiary include inconsistent functional allocation, attempting to rely on license passporting where a local license is required, and underestimating substance requirements. The solution is early dialogue with the regulator, a clear governance plan and a transparent intra-group revenue model.

De-risking by banks and the closure of correspondent accounts often follow from an unclear business model. Therefore I always include a bank relationship management program at the planning stage.

License refusal: Plan B

The consequences of a license refusal are not the end. Exit strategies include re-filing with remediations, relocating to an alternative jurisdiction, purchasing a licensed asset, or temporary operation through an agency model. A contingent plan must be ready before submitting the application: it saves months and protects P&L.

The assessment of costs and return on investment (ROI) of relocation is updated at every stage: new information from the regulator, requirements for staffing or safeguarding can change the initial assumptions.

COREDO case studies: three relocation scenarios

Relocating a payments business to the EU

Client: a payment organization with a PI in one EU country. Goal – expansion to multiple EEA markets. We conducted regulatory mapping, assessed PSD2 license passporting, prepared notifications and agreed on a plan to expand the agent network. At the same time we strengthened safeguarding: opened additional trust accounts and implemented daily reconciliation.

Result: 4 months of preparation and 2 months for passporting, with no interruption to operations. A bonus was reduced compliance costs thanks to the unification of the TMS.

Licensing a crypto company under MiCA

Client: a wallets and exchange services provider. We compiled a licensing checklist under MiCA, prepared KYC/CDD and EDD policies for PEPs, integrated the travel rule and on-chain analytics into the TMS. Special attention was paid to GDPR and cross-border transfer of personal data, including a DPIA and DPAs with providers.

As a result, the regulator accepted the application without significant queries, and partner banks accelerated onboarding thanks to a transparent sanctions policy and reports on effectiveness.

Relocation between Asia and Europe

A fintech licensed in Asia planned to enter the EU. We compared local license requirements in the EU and sandbox opportunities (FCA/BaFin), assessed substance and the tax residency of management. Interaction with the Asian regulator took into account the lack of mutual recognition of licenses, so we built a separate European structure with transparent transfer pricing.

The operational transition proceeded in stages: testing in the sandbox, applying for a license, migrating clients and surrendering part of the Asian products. The company retained access to SWIFT and expanded SEPA corridors without downtime.

Step-by-step plan: timeline

Preliminary audit (2–4 weeks)

  • Regulatory mapping and gap analysis.
  • Financial model: ROI, capital adequacy, safeguarding cost.
  • Assessment of substance, UBO and governance, sanctions and AML risk.

Registration of legal entity and substance (4–8 weeks)

  • company registration, opening an office, hiring key personnel.
  • Governance setup: committees, independent directors, conflict of interest policy.
  • Protocols for relationships with correspondent banks and agents.

Licensing (3–9 months)

  • Preparation of package for EMI/PI or VASP/MiCA.
  • AML implementation/KYC/CDD/EDD, TMS and sanctions screening.
  • Pre-approval consultations, responses to regulator requests, sandbox pilots if necessary.

Client and funds migration (4–12 weeks)

  • Plan for transfer of operations, notifications, contractual framework, travel rule and cross-border payments.
  • Safeguarding transfer: escrow/trustee, reconciliation, testing period.
  • Procedure for license termination and transfer of operations in the old jurisdiction.

Post-licensing oversight (12 months)

  • KPI for CCO, AML monitoring metrics, independent audit.
  • Onsite readiness, regular reports, whistleblowing processes.
  • Continuous improvement program and stress tests.

Fintech relocation checklist

  • Regulatory mapping and gap analysis for PSD2, MiCA, AMLD5/AMLD6.
  • Assessment of license passporting vs local license requirements.
  • Substance plan: office, staff, managerial substance tests.
  • Governance: board of directors, committees, CCO role policy.
  • AML program: risk-based approach, KYC/CDD, enhanced due diligence for PEPs.
  • KYB for partners and agents, vendor due diligence and third-party risk.
  • TMS: transaction monitoring, SAR rules, integration into core banking.
  • Sanctions compliance: OFAC/EU screening, control of high-risk jurisdictions, FATF greylist.
  • Safeguarding: trust vs ring-fencing, escrow and trustee accounts, liquidity tests.
  • Payment rails: SEPA, SWIFT, IBAN; anti-fraud and chargeback management.
  • GDPR: cross-border data transfers, data localization, DPIA and DPA.
  • Taxes: transfer pricing, tax residency of management and the company.
  • Supervision: FIU reporting obligations, supervisory cooperation, regulatory notifications.
  • Exit strategies: license refusal, contingency planning, license surrender and wind-down.
  • RegTech stack: AML, KYC, KYB, TMS; performance metrics and SLAs.
  • Plan for managing correspondent banks and de-risking consequences.
  • Analysis of equivalence decisions and mutual recognition agreements (where applicable).
  • Local agency networks and restrictions on delegating licensed functions.
  • Verification of data sources for verifying beneficial owners.
  • Reputational risk management and crisis PR.

COREDO’s role as a partner

Relocating a fintech company is the synchronization of licensing, AML/sanctions compliance, governance, data and taxes. A mistake in any one element leads to a chain reaction: banks’ de-risking, release disruptions, and prolonged regulator inquiries. COREDO’s experience shows that those who start with regulatory mapping and an honest assessment of substance, and then execute the plan precisely with KPI control, win.

The COREDO team has delivered projects in the EU, the UK, Singapore and Dubai while maintaining operational continuity, correctly migrating safeguarding and with predictable timelines for obtaining approvals. If you are preparing a change of jurisdiction for a fintech license, VASP registration in Europe, migration of a payment institution model, or implementing MiCA/PSD2/SCA, join the conversation at an early stage. My colleagues and I will apply a methodology proven by dozens of projects and build an architecture that will withstand supervisory reviews and deliver the ROI that motivates relocation.