VFA Services in Malta - CSBGroup

Virtual Financial Assets (VFA) Services in Malta

VFA Services

The Virtual Financial Assets Act, defines a VFA service, as any services falling within the Second Schedule to the Virtual Financial Assets when provided in relation to a DLT Asset which has been determined to be a virtual financial asset. A license will be required for the provision of a VFA Service.

The Second Schedule to the Act describes the types of VFA Services which may be offered in terms of the Act:

Reception & Transmission of Orders: The reception from a person of an order to buy, sell or subscribe for virtual financial assets and the transmission of that order to a third party for execution.

Execution of Orders on behalf of other persons: Acting to conclude agreements to buy, sell or subscribe for one or more virtual financial assets on behalf of other persons.

Dealing on own account: Trading against proprietary capital resulting in conclusion of transactions in one or more virtual financial assets.

Portfolio Management: Managing assets (one or more virtual financial assets or the arrangements) belonging to another person having discretion to invest any of those assets in one or more virtual financial assets.

Custody or Nominee Services: Acting as custodian or nominee holder of a virtual financial asset and, or private cryptographic key; or holding a virtual financial asset and, or private cryptographic key as nominee, where the person acting as nominee is so doing on behalf of another person.

Investment Advice: Giving, offering or agreeing to give, to persons in their capacity as investors or potential investors or as agent for an investor or potential investor, a personal recommendation in respect of one or more transactions relating to one or more virtual financial assets.

Placing of virtual financial assets: The marketing of newly-issued virtual financial assets or of virtual financial assets which are already in issue but not admitted to trading on a DLT exchange, to specified persons and which does not involve an offer to the public or to existing holders of the issuer’s virtual financial assets.

Operations of a VFA Exchange: An exchange where only Virtual Financial Assets may be transacted.

Obtaining a VFA Licence

In order to be able to provide the above services an applicant would need to obtain a VFAA Licence as described hereunder.

VFAA Class 1

  • Licence holders authorised to receive and transmit orders and, or provide investment advice in relation to one or more virtual financial assets and, or the placing of virtual financial assets.
  • Application Fee €6,000
  • Annual Supervisory Fee
  • For revenue up to €50,000 = €5,500
    Further tranches of €50,000 up to a maximum of €1,000,000 = €700 per tranche

VFAA Class 2

  • Licence holders authorised to provide any VFA service and to hold or control clients’ money, but not to operate a VFA exchange or deal for their own account.
  • Application Fee €10,000
  • Annual Supervisory Fee
  • For revenue up to €250,000 = €9,000
  • Further tranches of €250,000 up to a maximum of €5,000,000 = €800 per tranche

VFAA Class 3

  • Licence holders authorised to provide any VFA service and to hold or control clients’ money, but not to operate a VFA exchange.
  • Application Fee 14,000
  • Annual Supervisory Fee
  • For revenue up to €250,000 = €12,000
    Further tranches of €250,000 up to a maximum of €50,000,000 = €800 per tranche

VFAA Class 4

  • Licence holders authorised to operate a VFA exchange and to hold or control clients’ money, virtual financial assets and, or private cryptographic keys and custodian or nominee services solely in relation to the operation and activities of such VFA exchange.
  • Application Fee €24,000
  • Annual Supervisory Fee
  • For revenue up to €1,000,000 = €50,000
  • Further tranches of €1,000,000 up to a maximum of €100,000,000 = €5,000 per tranche

Our VFA Services

As a leading Services Provider in Malta, CSB Group is able to provide further information and assistance on what Malta has to offer in relation to blockchain and cryptocurrencies. Backed with years of experience in company incorporation, tax advisory and regulatory and compliance, our team can give complete solutions to anyone wishing to set up a fintech operation in Malta.

Our Services include:

  • Accounting & Bookkeeping Services;
  • Assistance with MFSA Application Process (ICO, Crypto Exchange, VFA Services);
  • Assistance with setting up of local presence & substance (office space and personnel);
  • Assistance with MFSA meetings, forms and due diligence requirements;
  • Assistance for the attainment of EMI/PSPs & MiFID Licences;
  • Bank Account Opening;
  • Company Formation;
  • Company Re-domiciliation;
  • Drafting of legal documents;
  • Drafting or Review of ICO White-Paper;
  • Drafting or Review of Business Plans;
  • Drafting Policies, Website T&Cs, GDPR compliance;
  • Financial Instruments Test;
  • Financial Projections;
  • Licence Advisory Services;
  • Legal opinions;
  • Ongoing Monitoring;
  • Tax and VAT Services;
  • VFA Agent Services.

For any assistance required please do not hesitate to contact our Fintech team on [email protected] or +356 2557 2557.

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CSB Group
[email protected]

+356 2557 2557