Regulatory Documentation Preparation
Regulator documentation is not just a bundle of papers. It demonstrates that you understand your business risks and manage them. Regulators don't reject those with some risks — they reject those who can't explain how to handle them.
What Most Regulators Require
Despite jurisdictional differences, core document package is similar:
Business Plan: describe activity, business model, revenue streams, target markets, competitive analysis, financial forecasts for 3 years. Regulator must understand: why this business exists, how it makes money, is it financially sustainable.
Corporate Structure Chart: ownership diagram — who is ultimate beneficial owner, all legal entities in group, their jurisdictions and shares. Regulators require transparency to natural persons with share > 10-25%.
AML/CFT Policy (Anti-Money Laundering / Counter Financing of Terrorism): describes entire company AML program. Key sections:
- Risk Assessment (customer, product, geographic risk assessment)
- Customer Due Diligence (CDD) procedures
- Enhanced Due Diligence (EDD) for high-risk clients
- Transaction Monitoring
- SAR (Suspicious Activity Report) procedures
- Record Keeping
- Training program
Compliance Officer CV and appointment: most licenses require dedicated Compliance Officer with AML experience. Their CV and appointment — separate document.
IT Security Policy: describes data protection measures, access controls, encryption, incident response. For exchanges and custodians — also Penetration Testing report.
Business Continuity Plan (BCP): how company continues operations during technical failures, cyber attack, loss of key personnel.
Jurisdiction Specifics
Estonia (FIU): requires detailed description of transaction monitoring system with alert rule examples. Estonia's FIU is known for detailed follow-up questions — prepare for 2-3 clarification rounds.
Dubai VARA: Business Plan must include UAE-specific market analysis and description of how business will use UAE as hub. Requires designation of local compliance representative.
Malta MFSA: most detailed package in EU — includes Internal Audit Framework, Risk Management Framework, separate System Audit from independent IT auditor.
Lithuania (FIU): relatively straightforward, but 2023-2024 significantly tightened requirements. Now requires demonstration of real operational activity in Lithuania.
Common Mistakes
Generic AML Policy: regulators recognize downloaded templates well. Policy must describe your specific business model with real risk scenario examples.
Unrealistic Business Plan: financial forecasts without assumptions explanation. If projecting $10M revenue in first year — explain where it comes from.
Missing edge case procedures: regulators ask "what do you do if client is PEP?", "what do you do receiving funds from high-risk addresses?". Answers must be documented.
Incomplete beneficial ownership disclosure: trying to hide real owner through nominee structures — direct cause of rejection and potentially criminal prosecution.
Complete regulatory documentation package preparation: 4-8 weeks. Includes: consultation on requirements, development of all policies, review and iterations.