Faisal Khan

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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closing doors for startups with no financing or knowledge of the business

Why we are closing our doors for pre-revenue Startups

For years, we have been advocates of sharing information and educating everyone for the greater benefit and good of society. This includes individuals, startups, would-be-entrepreneurs, incumbents, colleagues, professionals in the field, etc. However, this open-door policy has started to take its toll on our resources – specifically human resources – and the available time we …

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