The Polish VASP (Virtual Asset Service Provider) cryptocurrency exchange license requires applicants to meet specific conditions covering compliance, security, and operational standards. Below is a detailed breakdown of the key requirements:
1. Compliance Procedures
Applicants must establish and enforce compliance programs to ensure adherence to relevant regulations. This includes:
- Developing a comprehensive compliance manual
- Implementing internal control systems
- Ensuring all business activities align with Polish and EU financial laws
2. KYC (Know Your Customer) Requirements
Identity verification and background checks are mandatory:
- Collect and validate government-issued IDs, proof of address, and other client data
- Conduct risk profiling for each customer
- Maintain updated records for regulatory audits
3. AML (Anti-Money Laundering) Framework
A robust AML program must include:
- Suspicious activity monitoring and reporting protocols
- Regular employee training programs
- Cooperation with Poland's General Inspector of Financial Information (GIIF)
4. Security Standards
Applicants must implement:
- End-to-end encryption for transactions and data storage
- Multi-factor authentication (MFA) systems
- Cold wallet storage solutions for asset protection
5. Business Registration
Legal entity requirements:
- Must register as a Polish limited liability company (Sp. z o.o.)
- Minimum share capital: 5,000 PLN (~1,100 EUR)
- Registered office address within Poland
6. Financial Stability Proofs
Documentation demonstrating financial health:
- Audited balance sheets for the past 2 years
- Liquidity reserves covering 3+ months of operations
- Risk capital buffers as prescribed by regulators
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7. Management Qualifications
Key personnel must have:
- Relevant professional certifications (e.g., CAMS for AML officers)
- Clean criminal records verified through background checks
- Demonstrated 5+ years experience in fintech/financial services
8. Ongoing Reporting Obligations
Licensed VASPs must submit:
- Quarterly transaction reports to KNF (Polish Financial Supervision Authority)
- Annual compliance attestations
- Immediate disclosure of material business changes
FAQs About Polish VASP Licensing
What's the processing time for a VASP license?
Approval typically takes 6-9 months after complete documentation submission, including regulator queries.
Can foreign companies apply?
Yes, but must establish a Polish legal entity with local management presence. Non-EU firms face additional due diligence.
How much does the license cost?
Total costs range €25,000-€50,000 including government fees, legal support, and compliance infrastructure.
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Are there transaction volume requirements?
Poland currently sets no minimum volume thresholds, but monitors activity for risk assessment.
What cryptocurrencies can be traded?
Licenses cover all virtual assets meeting EU anti-terrorism financing standards. New coins require pre-approval.
How often are audits required?
Annual independent audits are mandatory, with interim audits if transaction volumes exceed €5M/month.