The VFA services are classified in four classes of licence:


Classes  1 2 3 4
         Services Reception and Transmission of Orders  checkmark  checkmark   checkmark checkmark 
Investment Advice checkmark   checkmark checkmark  checkmark 
Placing of Virtual Financial Assets checkmark   checkmark  checkmark  checkmark
Execution of Orders on Behalf of Other Persons    checkmark checkmark   checkmark
Portfolio Management    checkmark  checkmark  checkmark
Custodian and Nominee Services    checkmark checkmark   checkmark
Dealing of Own Account      checkmark checkmark 
Operation a VFA Exchange        checkmark
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.

Practice Areas