VASP registration and banking for a digital-asset treasury
A family office investing in crypto that needed a compliant way to move money in and out, kept separate from its trading business, with bank accounts that would pass a 'where did the money come from' review.
The situation
A family office investing in crypto was doing it through the same company as a separate trading business. Banks were uneasy, the people they dealt with were confused, and the story of where the money came from mixed two unrelated histories.
- The crypto investments and the trading business had to be genuinely separate companies, dealing with different parties.
- The 'source of funds' file had to piece together ten years of asset history to the standard a bank expects.
- The country of registration had to be one banks would accept, not just the quickest.
- How the crypto was held had to satisfy both the bank and the family's own risk committee.
Two companies, two clear stories, two sets of partners — which is what made the banking possible.
- Fiat in
- Normal money comes in through the banked VASP company, backed by a documented source-of-funds file — never through the trading business.
- Custody
- The crypto is held by a qualified custodian in the VASP company's name, within limits set by the family's risk committee.
- Reporting
- The 'travel rule' (sending sender and receiver details with crypto transfers) and anti-money-laundering duties are handled inside the VASP, so the trading business's file stays clean.
What we did, step by step
- 01Separation first
Split the crypto investments from the trading business before going to any bank, because no bank would accept the combined story.
- 02Jurisdiction chosen for bankability
Picked the country to register in by asking banks what they'd accept, not by how fast it was.
- 03Source-of-funds reconstructed
Pulled ten years of asset history into one file, cross-checking exchange records, blockchain evidence and tax returns.
- 04AML programme built
Put the policies, reporting officer, transaction monitoring and travel-rule handling in place before registration was granted.
- 05Two banks, in parallel
Applied to both at once with the same file, so one refusal couldn't hold everything up.
- 06Custody and limits
Appointed a qualified custodian and agreed written limits with the family's risk committee.
- VASP registered in a country that the banks accept.
- Two crypto-friendly banks took the family on, both accepting the source-of-funds file first time.
- The trading business kept clear of the crypto side's regulatory profile.
- Custody arrangements and limits written down and reviewed every quarter.
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