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 CASP-authorised and offshore VASP-licensed businesses case-by-case, and we tell you which one before you apply.
- MiCA
- CASP authorisation is now the only route to serve the EU
- 8+
- CASP and offshore 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 crypto businesses. 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.
Life after the MiCA grandfathering deadline. The national VASP registrations that Lithuania, Poland, Czechia, Estonia and others ran are gone: CASP authorisation under MiCA is now the only way to serve EU clients, and banks increasingly ask to see the authorisation itself rather than a legacy registration certificate.
We sequence the banking conversation around your actual status, whether you hold CASP authorisation, are still in the application queue, or have moved the EU-facing business to a non-EU licence, and we brief the bank on what that status does and does not permit.
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.
CASP and offshore jurisdictions, honestly compared
Authorisation cost and speed are only half the decision. Banking acceptance is the half nobody publishes, so here it is. Every EEA row below now runs on a single MiCA CASP authorisation: the national VASP registrations closed with the grandfathering window, so what still separates these jurisdictions is regulator pace, substance expectations, and the depth of the local banking bench. Figures are indicative.
| Jurisdiction | Regime | Cost band | Timeline | Banking acceptance |
|---|---|---|---|---|
| Lithuania | MiCA CASP authorisation | €€€ | 6-12 months | Moderate: deep EMI bench, banks want the authorisation in hand |
| Malta | MiCA CASP authorisation | €€€ | 6-12 months | Good: long-standing regulatory reputation helps the file |
| Estonia | MiCA CASP authorisation | €€€ | 6-12 months | Moderate: scrutiny stayed heavy through the regime change |
| Czechia | MiCA CASP authorisation | €€€ | 6-12 months | Moderate: workable entry, thinner domestic banking bench |
| Poland | MiCA CASP authorisation | €€€ | 6-12 months | Limited: authorisation helps, banking still takes longer to place |
| Dubai (VARA) | VARA full-market permit | €€€€ | 4-9 months | Good: regional banks increasingly comfortable with VARA |
| Seychelles | VASP licence (dedicated regime since 2024) | € | 2-4 months | 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
Standards
Vocabulary
Where we meet you
Every term above is defined in plain English in our high-risk banking glossary.
The account is the point. Licensing and processing serve it.
The services around the account
Licensing
We advise on MiCA CASP authorisation for EU-facing business, on offshore VASP licensing where the EU is not the target market, and on adjacent licences, timed so your 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: authorisation already granted, documented wallet provenance, and Travel Rule tooling already in place.
6-12 wks
An in-flight file: the CASP application is lodged but not yet granted, 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.
CASP authorisation, or the offshore VASP licence certificate
Confirms your authorisation status and jurisdiction, the first thing a compliance analyst checks before reading anything else. Since the MiCA grandfathering window closed, a lapsed national VASP registration no longer answers this question for EU-facing business.
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 licence (Seychelles, for example) is usually treated as a holding-company layer rather than the banked entity itself, and it does not permit serving EU clients now that CASP authorisation is the only EU route. 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 was only just authorised?
Often yes, but the timeline stretches. Banks want to see either an operating history or a very clean compliance file if the authorisation 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.
We missed the MiCA grandfathering deadline. Can we still be banked?
It depends on what you do next, and we will be straight with you about it. The national VASP registrations are gone, so serving EU clients now requires CASP authorisation. If your application is in the queue, banks will usually engage but rarely conclude before the authorisation lands. If you have moved the EU-facing business to a non-EU licence, that is bankable, but only if the structure honestly reflects where your customers actually are. What does not work is presenting a lapsed registration as though it were still live.
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
Know who will bank your crypto business, before you apply
You tell us your situation in a line or two.
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.