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Required information for VASP registration

Depending on whether the applicant is a natural or a legal person, a VASP candidate must provide the following information with its registration request:

VASP as natural person

  • Name and the first name(s);

  • Precise private or professional address​;

  • The service(s) provided falling under one or more of the VASP services referred in the VASP definition;

  • A description of the money laundering and terrorist financing risks to it will be exposed and the internal control mechanisms it established in order to mitigate these risks and to comply with the professional obligations defined in the AML/CFT Law and in Regulation (EU) 2015/847.

VASP as a legal person

  • Name (dénomination sociale);

  • Precise address of the central administration;

  • A description of the activities performed, in particular, a list of the types of virtual asset services and their relevant qualification;

  • A description of the money laundering and terrorist financing risks to which it will be exposed and the internal control mechanisms it established in order to mitigate these risks and to comply with the professional obligations defined in the AML/CTF Law and in Regulation (EU) 2015/847.

 

Complements of information for VASP resgistration

The CSSF may request complementary documents and information. Regarding authorised Investment Fund Managers intending to manage an Alternative Investment Fund, regulated or not (“AIF”), that is investing in virtual assets, the CSSF may namely request the following:

  • A description of the project and of the activities performed;

  • A description of the different services providers/delegates involved;

  • Information on whether or not the investments in virtual assets will be made directly or indirectly (by the means of derivatives for example);

  • An updated risk management policy including in particular how the risks in relation to the virtual assets are managed;

  • An updated valuation policy including the rules as to how the value of the virtual assets will be determined;

  • A description regarding the experience of the portfolio manager (and other involved entities in the investment management process) in virtual assets;

  • A description of how the custody of the assets will be organised by the depositary;

  • Information regarding the targeted investors, as well as any information on the distribution channels of the AIF;

  • The AML/CFT analysis performed by the AIFM on the assets side (CSSF, FAQ Virtual Assets – Undertakings for collective investment, Q.3, p. 4).

The VASP applicant must also notify to the CSSF the persons (at last two persons) responsible for the VASP management and entitled to effectively determine the policy of the business. In this regard, the VASP must justify the professional standing (“fit & proper”) of these persons as well as of its beneficial owners, which will be assessed by the CSSF on the basis of criminal records and of any evidence demonstrating that these persons are of good repute and offer every guarantee of irreproachable business conduct.

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