Assisted the electronic money institution in implementing procedures for CASPS customers

Our team represented Nandi Pay, the electronic money institution, that targets high-risk clients. With upcoming MICA regulation, our client identified the business opportunity to onboard crypto-asset services providers (CASPS) as clients, open payment accounts for them and provide payment services. Our team supported the client in building up and implementing a CASPS onboarding process. Considering the risks that the crypto business entails, our team has adapted the current customer onboarding procedures and KYB questionaries, T&C, and risk management tools for establishing a business relationship with CASPS.

In this process, our support was based on the best practices of international organisations (FATF, Wolfsberg group) and national authorities (FIU, Banks’ Association) to ensure that the company’s potential exposure to risks related to the activities of clients in the crypto sector is covered.

The complexity of the issue stems from the incomplete regulation of the activity, the multitude of risks that could arise, the uncertain geography of cryptocurrency service providers’ customers, and the fragmented regulation that has been applied to them in different countries.

It is also worth mentioning that we have a long-standing relationship with this client. We started with the electronic money institution authorisation process in 2019 and since then we have assisted the client on compliance matters regularly.