Case Study: German License Application

We were tasked with supporting a crypto exchange in the application for a licence pursuant to section 32 (1) of the German Banking Act (Kreditwesengesetz, KWG), § 14 of the German Reports Regulation (Anzeigenverordnung, AnzV) for providing principal broking (Finanzkommissionsgeschäft) pursuant to section 1 (1) sentence 2 no. 4 KWG, Proprietary Trading (Eigenhandel) pursuant to section 1 (1) sentence 2 no.4  KWG and crypto custody business (Kryptoverwahrgeschäft) pursuant to section 1 (1a) sentence 2 no. 6 KWG. 

The initial task was to provide the technical input to the AML section of the application. Our team successfully completed the job and subsequently was able to provide further technical input to the entire application with a particular focus on Compliance, Risk Management, Outsourcing and Business Strategy. 

We also came up with an initial draft version and consulted with legal counsel to create the final version of the application. Internally we set up the required processes and designed the organisational structure to accommodate the German requirements as defined in MaRisk and the existing internal Group structure .