The VFA services are classified in four classes of licence:
|Services||Reception and Transmission of Orders|
|Placing of Virtual Financial Assets|
|Execution of Orders on Behalf of Other Persons|
|Custodian and Nominee Services|
|Dealing of Own Account|
|Operation a VFA Exchange|
|Minimum Share Capital||€50,000 or €25,000 + PII||€125,000||€730,000|
Requirements to file an application to obtain a VFA Service Provider Licence
The main requirements to file an application and obtain a VFA Service Provider licence are the following:
- Substance in Malta – The applicant must be a legal entity constituted under Maltese Law and must have physical presence in Malta.
- VFA Agent – A licensed VFA Agent must be appointed by the applicant who will file the application with the MFSA and act as liaison between the applicant and the MFSA.
- Fitness and Properness Assessment – A number of individuals involved in the structure including designated persons, directors, senior management, qualifying shareholders and ultimate beneficial owners have to undertake a fitness and properness assessment.
- Financial Instrument Test – The applicant must undertake, a Financial Instrument Test (FIT) to ensure that the DLT asset in relation to which the applicant will be providing the VFA Service falls within the meaning of a virtual financial asset as per the VFAA.
- Appointed Parties – The board of administrators / directors must effectively be directed by at least two individuals. The applicant needs also to appoint a compliance officer, a money laundering reporting officer, a Systems Auditor or an IT Auditor as necessary, and in certain instances a Risk Manager as well.