Year: 2021

Faisal Khan LLC Banking Payments Cryptocurrency Fintech Blockchain Compliance

What is the largest opportunity in Nigeria right now for money transfer?

tl;dr: Buy foreign exchange from within Nigeria by paying for it in Naira and have access to the US Dollars / Euros / other currencies outside of Nigeria to be traded/transferred as and when one desires.  Nigeria is a new import economy, so that means the demand for foreign exchange to be spent outside of …

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Faisal Khan LLC Banking Payments Cryptocurrency Fintech Blockchain Compliance

Can a money transfer agent location be opened in a consulate or an embassy?

The answer is no. When we look at making a consulate or an embassy, as a money-transfer agent location, you have to understand that the consulate or the embassy itself is not US Territory (assuming this question was being asked of the US) in fact this can be applied to any other licensed jurisdiction. With …

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Faisal Khan LLC Banking Payments Cryptocurrency Fintech Blockchain Compliance

Montana does not require a money transmitter license, if I register a company there, am I exempt from money transmitter licenses?

You may be exempt from money transmitter licenses only in the state of Montana. Because you have an exemption in the state of Montana, does not mean that you can offer your financial services nationwide. The exemption is only valid for the state of Montana and Montana alone. This means that the transaction must originate …

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Faisal Khan LLC Banking Payments Cryptocurrency Fintech Blockchain Compliance

Is a money transmitter license adequate for launching crypto-related services in the US?

No. In certain US states like New York, for example, a BitLicense is required to trade in Cryptocurrency related services. In addition to the NY Money Transmitter License, you would require an NYDFS issued BitLicense to operate within the crypto domain in the state of New York. Other US states are also slowly putting a …

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Faisal Khan LLC Banking Payments Cryptocurrency Fintech Blockchain Compliance

Do Trust companies provide money transmitter license coverage?

This is widely debated. The short answer is that they can provide limited money transmitter license coverage, for their own products/services and that too in a limited number of US states that recognize the charter of the Trust company in question. For example, if you want to start an over-the-counter bitcoin trading services, OTC services …

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Faisal Khan LLC Banking Payments Cryptocurrency Fintech Blockchain Compliance

What is cryptocurrency-as-a-service?

Crypto-as-a-service or cryptocurrency-as-a-service (CaaS) has not yet fully been defined. It can literally mean any sort of Software or Platform as a service related to the crypto world. In the broader sense, Crypto-as-a-Service is the ability to launch a crypto-related product/service, with the service provider providing not only the platform rails but also the regulatory …

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Faisal Khan LLC Banking Payments Cryptocurrency Fintech Blockchain Compliance

What is the difference between an agent and non-agent of an EMI in Europe/UK?

There are a couple of differences between an agent and a non-agent in the European EMI licensing regime. A non-agent for starters is commonly referred to as an operator-led model. Where the operator of the license is handling all the facets of custody of funds, compliance, reporting, etc. The non-agent is essentially responsible for marketing …

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