If you are not sure whether you need to register, it is important you consider at an early stage whether, according to the conditions in the legislation, you are carrying on in-scope cryptoasset activity by way of business in the UK.
Also, we will assist business in preparation of following policies and procedures and supporting documentation:
- Customer onboarding agreements and process.
- Customer due diligence and enhanced due diligence procedures, meeting the minimum standards required in the regulations.
- Transaction monitoring procedures.
- Record-keeping and recording procedures.
- Business continuity plan.
- Outsourcing arrangements policy.
- Governance arrangements and internal control mechanisms.
- Anti-Money Laundering/Counter Terrorist Finance framework and risk assessment.
- Business-wide risk assessment.
- Budget forecasts and financials for the first three financial years.
- Money Laundering Reporting Individual forms for all directors, executives and officers.
- Beneficial Owner forms for shareholders.
We are here to help: Compliance House, email: hello@compliancehouse.co.uk, Telephone: 02032864003
What information do we need To assist you?
We will need information relating to your business and information of all key individuals who hold a relevant function at your business to assess business’s conditions that business falls under the scope of cryptoassest activity and key individuals are fit and proper to run the business.
We will assist you in preparing the following documents to make the application for registration:
Programme of operations: setting out the specific cryptoasset activities for the business.
Business Plan: setting out the business objectives, customers, employees, governance, plans and projections including adequacy of financial and non-financial resources.
Marketing plan: including a description of customers and distribution channels.
Structural organisation: a description of how business is structured and organised including a description of relevant outsourcing arrangements, if any.
Systems and controls: provide details of the key IT systems which will use to run the business, including details of IT security policies and procedures.
Individuals, beneficial owners and close links: directors and any other persons who are or will be responsible for the management, must have a good reputation, and have the appropriate knowledge and experience to act in this capacity or appoint a person to be responsible for MLRs compliance, to monitor and manage compliance with policies, procedures and controls relating to money laundering and terrorist financing and to act as the nominated officer under the Proceeds of Crime Act 2002. We can assist the business in appointing a person who has the knowledge, experience and training as well as a level of authority and independence as well as sufficient access to resources and information, to enable them to carry out the cryptoasset business.
Governance arrangements and internal control mechanisms: details of governance arrangements, the internal control mechanisms in place to identify and assess risks and a description of money laundering and counter terrorist financing control measures in place.
Anti-Money Laundering/Counter Terrorist Finance framework and risk assessment: this should highlight the risks specific to business model activities and provide details on how business mitigate those risks including Anti-Money Laundering/Counter Terrorist Finance staff training material.
Business-wide risk assessment: with monitoring and mitigation policy.
All cryptoassset public keys/wallet addresses: this should include all of the cryptoasset addresses controlled by the business and used in the activity of the business for each cryptoasset that the business deals with.
