WHAT RESTRICTIONS ARE APPLICABLE:
● The average of the total amount of payment transactions for the
previous 12 months performed by the SPI, including agents
through which it provides payment services, must not exceed an
amount equivalent to EUR 1,500,000 per month
● Maximum amount of deposits on client account – EUR 2,000
● SPI is not allowed provide payment services outside Poland
(for example send international bank transfers); it is allowed to have foreign clients, as long as the payment services are provided in Poland

Credit payment transactions

FX for payment services

Money remittance

Acquiring
(accept payments)

Issue payment
instruments

Money transfers

Provide payment initiation with credit (e.g., BNPL at POS), but only as part of payment execution, not standalone lending.

Currency exchange strictly linked to execution of payment transactions (e.g., converting PLN to EUR for a domestic transfer).

Pure money transfer services (e.g., P2P, B2C) within Poland.

Provide merchant acquiring, operate payment gateways, accept card payments (Visa, Mastercard, etc.).

Issue debit cards, prepaid cards, mobile wallets, virtual cards, etc.

Execute wire transfers, direct debits, SEPA transfers within Poland. Monthly cap: €1,500,000 total transaction value (12-month rolling average

Maintain accounts with max €2,000 balance per client. Accept cash deposits and allow cash withdrawals.

Client accounts
(payment accounts)

WHAT IS ALLOWED:
● Maintaining client’s accounts (up to EUR 2,000 per client), cash
accept deposits, allow cash withdrawals,
● Perform money transfers, such as wire transfers or direct debits
(max. value of payment transactions EUR 1,500,000/month);
● Issue payment instruments (cards, mobile apps etc.),
● Accept payments with payment instruments - i.e., provide
services of accepting card payments, operate payment gateways
etc.,
● Realize money transfers;
● Perform currency exchange for payment transactions;
● Credit payment transactions;

Polish Small Payment Institution License with approval issued by the Polish Financial Supervisory Authority:
  Company has an active bank account;
  The SPI can be easily transformed to national payment institution;
  Active office rental agreement, as well as the local law firm providing accounting, consultations and any related help.

WHAT IS ALLOWED (Scope of Services)
Under Slovak law, VASPs can provide the following virtual asset services (as defined in the AML Act and MiCA):

Credit payment transactions

Participation in and provision
of financial services related
to an issuer’s offer and/or
sale of virtual assets

Money remittance

Safekeeping and/or
administration of virtual assets

Transfer of virtual assets

Exchange between
virtual assets

Manage client crypto portfolios; optional under MiCA but registrable if offered.

Currency exchange strictly linked to execution of payment transactions (e.g., converting PLN to EUR for a domestic transfer).

Pure money transfer services (e.g., P2P, B2C) within Poland.

Custody services, including secure storage in hot/cold wallets and administration (e.g., key management); no balance limit per client.

Facilitate crypto transfers on behalf of clients (e.g., wallet-to-wallet sends); akin to remittance but for digital assets.

Trade one crypto for another (e.g., ETH to USDT); includes spot trading on exchanges.

Convert cryptocurrencies (e.g., BTC to EUR) for clients; no volume cap, but transactions must comply with AML thresholds.

Exchange between virtual
assets and fiat currencies

VASP licensed company in Slovakia:
• Company incorporated in 24 December 2024;
• Clean transaction history;
• Active VASP license – all reports submitted;
• Fully online ownership transfer;
• Company type: Slovakian SRO

Fees

AML/KYC

Clients

Geographic Scope

Allowed Services

Volume Cap

Capital

Full (ID, PEP, monitoring)

CHF 5,000–20,000/year

Global (with local compliance)

Crypto-fiat & crypto-crypto exchange Custody & wallet services Transfers (Travel Rule >CHF 1,000) ICO/STO advisory, distributor agreement from BaaS providers for IBANs, transfers.

FINMA-recognized SRO (VQF or SO-FIT)

Regulator

Self-Regulatory Organization in Switzerland for sale:
• Company incorporated in 1 March 2025;
• Clean transaction history;
• Active SRO accreditation – all reports submitted;
• Fully online ownership transfer;
• Company type: Swiss SRO

Fees

Key Restrictions

Clients

Definitions

Geographic Scope

Allowed Services

Volume Cap

Capital

- No anonymous accounts
- Risk-based AML for high-risk jurisdictions
- Services limited to convertible virtual assets; prohibited for unregistered entities

Full compliance required (ID verification, PEP screening, transaction monitoring; FATF-aligned, including Travel Rule)

Submit application to NBG with business plan, AML policies, fit-and-proper declarations for management, proof of capital, and compliance documentation; detailed in registration rules and annexes

- Virtual Asset: Digital expression of value that is interchangeable, non-unique, used for transmission/trading, investment, or payments (excludes digital fiat, securities, other financial instruments)
- Convertible Virtual Asset: Virtual asset with market-equivalent value in fiat, other virtual assets, or financial instruments, enabling exchange

Global (with local compliance)

- Exchange of convertible virtual assets (including via self-service kiosks) into national/foreign fiat currencies, other virtual assets, or financial instruments
- Transfer of convertible virtual assets (Travel Rule applies for transfers >USD 1,000)
- Storage/administration of convertible virtual assets or instruments enabling control (custody & wallet services)
- Management of portfolios composed of convertible virtual assets (excluding collective portfolio management)
- Administration of a trading platform for convertible virtual assets
- Lending of convertible virtual assets - Initial offering of convertible virtual assets (ICO) and/or related services (advisory)

GEL 50,000 (~€16,000)

National Bank of Georgia (NBG)

Regulator

Georgian VASP licensed company for Sale.
License issued on 15th of November, clean history, company can come together with software with integrations to Fireblocks, Kraken, Chananalysis, SumSub. Software has functionalities to have custodial wallets, collect payments, exchange crypto to fiat and fiat to crypto and issue crypto cards.

Company Transfer Time

Key Restrictions

Clients

Definitions

Geographic Scope

Allowed Services

Volume Cap

Capital

- Mandatory registration if serving Canadian public or operating in Canada
- No anonymous transactions; enhanced due diligence for high-risk clients/jurisdictions
- Prohibited from operating unregistered; crypto services limited to non-security tokens

Full PCMLTFA compliance (client ID verification, beneficial ownership, transaction records for 5 years; report suspicious/large transactions to FINTRAC within 24h; risk-based AML program required)

2-3 Weeks

✅ International allowed (if transaction touches Canada)

- Money Services Business (MSB): Any person/ entity offering the above services to the public for remuneration, including virtual currency dealers (crypto exchanges, ATMs)
- Virtual Currency: Digital representation of value (e.g., Bitcoin, stablecoins) used for payment or investment, not issued by central bank

Global (services provided in or from Canada; cross-border allowed with compliance)

- Foreign exchange dealing (e.g., currency conversion for clients)
- Transfer of funds (remittances, wire transfers)
- Issuing, selling, or redeeming payment instruments (e.g., money orders, traveller’s cheques, prepaid cards)
- Virtual currency services: Exchange between virtual currency and fiat (e.g., BTC to CAD); transfer of virtual currency; dealing in virtual currency
- Payment processing or settlement services tied to above

None required (10,000 EUR recommended)

Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), SOR/2002-184 (Money Services Businesses Regulations), as amended 2023

Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)

Legal Basis

Regulator

Company Transfer Time

Key Restrictions

Clients

Definitions

Geographic Scope

Allowed Services

Volume Cap

Capital

- No anonymous accounts; whitepaper approval for offerings >€1M
- Prohibited conflicts of interest; sustainability/ESG disclosures mandatory
- Stablecoin limits: No interest payments on non-e-money stablecoins; redemption rights

Application Process

Submit to home NCA: Business plan, governance, AML policies, capital proof, fit-and-proper tests for management; ESMA notification for passporting

Full AMLD5 + MiCA rules (Travel Rule >€1,000; client ID, PEP screening, transaction monitoring; integrated with EU FIU)

3–6 months (authorization application review; transitional period for pre-2024 VASPs until July 1, 2026)

International allowed (if compliant with local rules; no marketing to non-qualified EU investors without passport)

- Crypto-Asset: Digital representation of value/token not issued by central bank, using DLT/blockchain
(excludes e-money, financial instruments)
- Crypto-Asset Service Provider (CASP): Authorized entity offering the above services; covers stablecoins
(ART/MAT issuers separately)

EU-wide (passporting); non-EU firms can serve EU clients via reverse solicitation only

- Custody and administration of crypto-assets
- Operation of trading platforms for crypto-assets
- Exchange of crypto-assets for fiat/cryptocurrencies
- Execution of orders on behalf of clients
- Placement of crypto-assets
- Reception/transmission of client orders
- Provision of advice on crypto-assets
- Portfolio management for crypto-assets

Tiered: €50,000 (basic); €125,000 (custody/trading); €150,000 (exchange/order matching); own funds ≥3% of fixed overhead

Regulation (EU) 2023/1114 on Markets in Crypto-Assets (MiCA), effective June 30, 2024; full Title III (CASP) from December 30, 2024

National Competent Authorities (NCAs) in EU Member States (e.g., BaFin in Germany, AMF in France); coordinated by ESMA

Legal Basis

Regulator

Crypto Accounting in Poland: Why Your Business Needs It

• Tax Law: Crypto gains taxed at 19% CIT (no thresholds). Every trade, staking reward, or airdrop must be recorded in PLN using FIFO/fair value.
• VAT Exempt: Crypto-to-crypto & crypto-fiat exchanges are VAT-free; only services are taxed.
• KAS Audits: Tax authority uses blockchain analytics; unreported transactions trigger 75% penalty + PLN 20M fines.
• MiCA + KNF: CASPs must segregate client assets, file quarterly reports, and prove solvency.
• Annual Filing: CIT-8 due April 30; missing records = automatic red flag.
• Banking Access: Banks require crypto-proof books to open accounts.
• Investor Trust: Clean financials are mandatory for funding or partnerships.

Cost: 5,000–15,000/year for specialist accountant.

Bankery makes: €2,000 = EU company in 1 week.