You keep using the term
crypto wallet. If it is similar to say
blockchain.com you won't need a license, so what exactly is it you want to setup?
Technically, there are two types of so-called Estonian
cryptocurrency licenses:
- Providing services of exchanging a virtual currency against a fiat currency
- Providing a virtual currency wallet service
Most operators possess both of them though. If Blockchain.com was incorporated in
Estonia, IMO, it would have been obliged to obtain the second license, as it falls under scope of relevant national legislation.
Now, getting back to the question raised by TS, there is no simple, one-fits-everyone, solution if we speak frankly. There are banks and EMIs out there that accept crypto-related businesses, but as usual nowadays, it would depend on:
- What exact business do you intend to carry on through your licensed entity (e.g. do you plan to setup some sort of crypto buy-sell facility, trading venue, or conduct ICO/STO/IEO)
- What measures would you be able to implement (not only on the template of
KYC policy you've got from your CSP, but practically) to mitigate fraud, sanctions, terrorism-related and other ML risks. That is a very important point to consider, especially given 5th MLD entry in force as of January.
- Who's running the company and what's their profile (
citizenship, residence, experience, presence or absence of adverse media info);
- The most important point of consideration is: would the business you plan to bring in to the FI be worth the risks dealing with cryptos? Would you be able to make some sort of security deposit (10-50-500 k EUR) and commit to a certain monthly turnover that would show that you are serious about that business and it is not all for laundering some petty
cash from phony ICO?
So, now you have a clearer picture of what needs to be demonstrated in order to secure credible banking relationships.
Some EMIs that can consider crypto-related projects are:
- Lithuanian EMIs, such as Pervesk etc.
- Wirex (according to the latest reports, has major banking problems)
- Sterling Payments (technically not
EMI, various credibility reports)
I wouldn't name any banks or some other EMIs on a public forum for obvious reasons.