Crypto & Web3
Fiat Rails That Survive the Compliance Review
Banking & Payments Consultancy for Crypto Businesses. Exchanges, custodians, and token issuers do not get de-risked because their compliance is weak. They get de-risked because the bank on the other side of the application applies a blanket policy that has nothing to do with their file. We know which institutions underwrite VASP-registered and CASP-authorised businesses case-by-case, and we tell you which one before you apply.
- MiCA
- the transition every EU-facing exchange is mid-way through
- 8+
- VASP/CASP jurisdictions we place against regularly
- 2-6 wks
- typical, crypto files with clean source-of-funds
- Since 2018
- advising crypto businesses on fiat rails
Five specific failure points, and the mechanism that answers each one
De-risking of VASPs. Correspondent banks and even some EMIs still apply blanket "no crypto" policies at the compliance-committee level, regardless of your own KYB file.
We place with the specific institutions that underwrite crypto on a case-by-case basis, and we know which ones changed policy and when, so you are not applying to a bank that rejects the sector on principle.
The MiCA/CASP transition. Exchanges and custodians registered under a national VASP regime are mid-migration to the EU-wide CASP authorisation, and banks are unsure which status to trust during the overlap.
We sequence the banking conversation around your actual authorisation timeline, whether you are VASP-registered today, CASP-authorised, or mid-transition, and we brief the bank on what that status does and does not mean.
Source-of-funds on tokens. A compliance analyst who can trace fiat cannot trace a wallet unless the file does it for them, so on-chain provenance becomes the single slowest part of underwriting.
We pre-package wallet provenance, chain-analysis output, and the narrative that connects it to your KYB file, so the bank receives a source-of-funds story it can actually close, not a blockchain explorer link.
Correspondent-bank crypto policies. Even when your direct bank accepts crypto, its correspondent bank three hops up the SWIFT chain may not, and that policy is invisible until a payment gets held.
We place with institutions whose correspondent relationships are known to tolerate crypto-linked flows, and we flag the settlement chain risk before you commit, not after a payment sits in limbo.
FATF Travel Rule compliance gaps. A VASP that cannot originate or receive Travel Rule data reads as an AML gap to any receiving bank, independent of how clean its own KYB actually is.
We confirm your Travel Rule tooling and messaging standard before introducing you to a bank, because that single control is often the difference between a fast approval and a six-month review.
What a compliance team actually flags on a crypto file
Nobody publishes this part. Here is the sequence a compliance analyst runs, in the order it actually happens, not the marketing version.
- 1
UBO transparency first: any layered ownership structure without a clear chart gets flagged before the analyst reads a single transaction.
- 2
Wallet-to-KYB linkage: on-chain addresses that cannot be tied back to a verified legal entity read as an unexplained source of funds, regardless of volume.
- 3
Travel Rule capability: whether you can originate and receive counterparty data is treated as a proxy for your entire AML programme, not a checkbox.
- 4
Token classification ambiguity: if legal counsel has not opined on whether your token is a currency, a security, or a utility instrument, underwriting stalls until someone does.
- 5
Correspondent-chain exposure: your direct bank may accept the file, but the analyst still checks whether the correspondent bank three hops up the SWIFT chain tolerates crypto-linked flows.
- 6
Volume-versus-history mismatch: a request for high limits from an entity with three months of operating history reads as a red flag even when the underlying business is legitimate.
VASP and CASP jurisdictions, honestly compared
Registration cost and speed are only half the decision. Banking acceptance is the half nobody publishes, so here it is. Every EEA row below is mid-transition to MiCA authorisation, whatever the current national regime says.
| Jurisdiction | Regime | Cost band | Timeline | Banking acceptance |
|---|---|---|---|---|
| Lithuania | VASP registration | €€ | 6-10 weeks | Moderate: several EMIs accept, banks remain selective |
| Malta | VFA / CASP-track | €€€ | 4-8 months | Good: MGA-adjacent regulatory reputation helps |
| Estonia | VASP licence (tightened regime) | €€ | 3-6 months | Moderate: post-reform scrutiny is heavier than pre-2022 |
| Czechia | VASP registration | € | 4-8 weeks | Moderate: cost-effective entry, thinner banking bench |
| Poland | VASP registration | € | 4-8 weeks | Limited: registration is fast, banking takes longer to place |
| Dubai (VARA) | VARA full-market permit | €€€€ | 4-9 months | Good: regional banks increasingly comfortable with VARA |
| Seychelles | No dedicated VASP regime (general licence) | € | 4-6 weeks | Limited: works as a holding layer, rarely the banked entity |
| Cayman Islands | VASP registration/licence | €€€ | 3-5 months | Moderate: respected offshore standing, banking is case-by-case |
Cost bands and timelines are indicative ranges and vary by applicant history and counsel. Banking acceptance reflects our current placement experience, not a guarantee for any specific institution.
The regulators, the vocabulary, and the rooms
Regulators & regimes
MiCA, VASP registration, CASP authorisation, and the FATF Travel Rule are the vocabulary of every conversation we have on your behalf.
Your vocabulary
On/off-ramp, custody split, chain analysis, wallet provenance, de-risking. We do not need it translated before we can act on it.
Where we meet this vertical
Token2049, Web Summit, and Money20/20, in person, most years since 2018.
The account is the point. Licensing and processing serve it.
The services around the account
Licensing
We advise on VASP registration, the CASP transition, and adjacent licences, timed so your authorisation status supports the bank application instead of confusing it.
ExplorePayment Processing
We do not process payments ourselves. Where a crypto business needs on/off-ramp processing or card acquiring, we introduce a vetted partner PSP on a referral basis, and stay focused on the banking, licensing, and structuring that sits underneath it.
ExploreCrypto & Digital
Wallet provenance packaging, Travel Rule readiness, and the fiat on/off-ramp structuring that keeps your banking relationship intact after the honeymoon period ends.
ExploreWhat to actually expect, with the caveats stated
2-6 wks
A clean file: existing VASP registration, documented wallet provenance, and Travel Rule tooling already in place.
6-12 wks
A mid-transition file: registration exists but the CASP authorisation is still in progress, or source-of-funds documentation needs building from scratch.
3-6 months
New entities with no operating history, or token issuers awaiting a classification opinion before any bank will proceed.
Files carrying an unresolved token-classification question or a history of prior bank offboardings run longer than these ranges, and we say so before you commit to anything, not after.
The document checklist, with the reason behind each line
Corporate structure chart with UBO disclosure
A bank cannot underwrite an entity it cannot fully see through. Layered structures without a clear chart are the single fastest way to a decline.
VASP/CASP registration or licence certificate
Confirms your authorisation status and jurisdiction, the first thing a compliance analyst checks before reading anything else.
Wallet provenance and chain-analysis summary
Substitutes for a traditional source-of-funds statement. Without it, the bank is being asked to trust a blockchain address on faith.
AML/CFT policy and Travel Rule tooling confirmation
Shows the bank you can originate and receive Travel Rule data, which is often the deciding control in a crypto file.
12 months of transaction history or projected volume model
Lets the bank size the relationship correctly the first time, avoiding a mid-review renegotiation of limits.
Legal opinion on token classification (where applicable)
If you issue or handle a token, the bank needs to know whether it is being asked to bank a currency, a security, or a utility instrument.
Two crypto placements, anonymised
Crypto exchange · EU EMI placement
A mid-sized exchange, de-risked by its previous bank after a routine review, placed with an EU EMI and a backup rail in nineteen days.
See the casePre-licence founder · jurisdiction sequenced first
A founder checked banking recognition before incorporating anywhere, then banked in three weeks once the licence was granted.
See the caseFrequently asked questions
Do you work with offshore-licensed exchanges?
Yes, with an honest caveat. An offshore VASP registration (Seychelles, for example) is usually treated as a holding-company layer rather than the banked entity itself. We tell you upfront which of your entities a bank will actually want to see, rather than letting you apply on the wrong one and collect a rejection.
Can you bank a business that only just registered as a VASP?
Often yes, but the timeline stretches. Banks want to see either an operating history or a very clean compliance file if the registration is new. We will tell you honestly whether your case is placeable now or needs three to six months of operating record first.
What happens if our token gets reclassified mid-review?
It happens, and it resets the conversation. If a regulator or a bank's legal team reclassifies your token during underwriting, we requalify the file against the new classification rather than pretending nothing changed. Being upfront about this risk before you apply is part of the check.
Do you help with the MiCA transition specifically?
We advise on how your current VASP status maps to CASP authorisation and how to sequence banking conversations around it, but we are not a MiCA legal-authorisation provider. Where full legal authorisation work is needed, we coordinate with counsel while keeping the banking track moving in parallel.
Will a bank ask where our crypto actually sits?
Yes, in detail. Custody arrangement, cold versus hot wallet split, and who controls the private keys are standard underwriting questions for a crypto file. Coming prepared with a clear answer is one of the fastest ways to shorten the review.
Is there a version of this that does not work, even with you?
Yes. A structure built purely to obscure beneficial ownership, or a token with no credible utility and no legal opinion behind it, will not clear underwriting anywhere, and we will tell you that for free rather than take a fee to file a doomed application.
Related reading from the field notes
Know who will bank your crypto business, before you apply
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A person reads it the same day. Not a bot.
You get a written answer within 48 hours, under NDA.
Free pre-approval check
Tell us where it hurts. A written read on your options in 48 hours.