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ARTICLE · 02 JUNE 2020

FACT SHEET: Setting up a cryptocurrency (Virtual Asset) exchange checklist

Holley Nethercote
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Before you set up a cryptocurrency exchange, you must first determine the structure of your cryptocurrency exchange.

AustraliaTechnology
Alexa Bowditch
Alexa Bowditch
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Before you set up a cryptocurrency exchange, determine the structure of your cryptocurrency exchange:

  • Crypto to fiat or crypto to crypto
  • Virtual assets to be exchanged
  • Broker or market maker
  • Provide e-wallets
  • Centralised or decentralised
  • Other services (cross-border payments, etc)?
    • Draw up an end-to-end funds flow diagram
    • Determine what services will be provided in Australia
    • Set up an Australian entity (if required)
    • Seek legal advice on which Australian regulatory regimes apply
  • Do you need an Australian Financial Services Licence (AFSL)?
  • Do you need to comply with the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Regime?
    • Design and implement an AML/CTF Program including an AML/CTF Risk Assessment (if required)

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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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