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.
De situatie
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.
Wat we deden, stap voor stap
- 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.
Een softwaregroep onder leiding van de oprichter, met bedrijven in drie landen en zonder holdingmaatschappij erboven, negen weken voordat de verkoop aan een Amerikaanse koper wordt ondertekend.
Een Britse familie die na april 2025 de oude non-dom-regeling verloor en een family office nodig had dat echt vanuit de VAE werkt, terwijl hun Europese vastgoed gewoon inkomsten bleef opleveren.
Een betalingsgroep uit het Midden-Oosten die zakelijke betalingen in de EU wilde aanbieden en een licentie nodig had die in heel Europa bruikbaar is, los van het bestaande moederbedrijf.