Looking for a EU bank / EMI for my crypto fund (SAIF in Estonia)

[Mr Wolf]

Hi everybody,

I am looking for someone who could help regarding opening a corporate bank account for a SAIF Crypto-assets Investment Fund I recently opened in Estonia.

• Everything has been done by the book with support of one of the best law firm in the region (Njord)
• The Partnership qualifies as the alternative investment fund within the meaning of Directive 2011/61/EU of the European Parliament and of the Council on Alternative Investment Fund Managers.
• Fund AML and KYC procedures are agreed by the estonian FIU, and under registration by the FIA
• My own KYC as director of the Fund is bulletproof clean (french citizen, clean criminal record off course, etc)

In Summary :
Everything is super clean and perfectly structured. Nothing to hide. Nothing dark in mind.
Working as researcher for PE & VC Fund, I just try to take the opportunity of the numerous HWNI vested in the funds I work with, who ask me repeatedly : "could you manage for us buying crypto, manage portfolio and custody, and when and how to exit in few months/years ?".
BUT :

• This Fund is designed to welcome small investments (from 10k€, rich people want crypto but only put toe in the water from now...!) and will probably start with a global NAV of 200-300k€ only.
• Yes, it is possible because it's a private fund so I can welcome non-professional investors, thus break the €100k traditional minimum investment level.
• I can build some bulls**t Business Plan claiming I aim to reach the 100 millions € NAV in the next 6 months, but reality is 200-300k€ for next quarter.

Problem is:
>> I struggle to find a bank which agreed to open a corporate account for the fund in order to receive investors money.
>> Bank Frick for example, only work now with clients being already established = >€10M reenues/NAV minimum
>> Estonian banks require that you proove deep connexions with estonian businesses / clients / investors (which I do not have)
>> Lithuania / UK could be the solution but I have no introduction with banks there...

The fact that it's a crypto-assets fund is not really important here, as I will buy crypto to craft the fund portfolio using OTC services : it will look like a simple SWIFT to a supplier from the account data perspective...

I understand that such help might imply reward.
If anyone has an idea... 🙂

 

[Mr Wolf]

Conclusion of the week: it was tricky but I found a solution ! Thank you all for your help.

 

[Clip]

Mr Wolf said:
Conclusion of the week: it was tricky but I found a solution ! Thank you all for your help.
Click to expand...

May I know which one?

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Expat in Hong Kong - There are two ways to conquer and enslave a nation. One is by the sword. The other is by debt. - John Adams

 

[JohnLocke]

Yeah it would ben ice if you could post here about what it is you have found and how it worked out for you 😉

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[Mr Wolf]

I ended up today with 4 Corporate business bank account opened for my fund : Holvi, LHV, Revolut, Transferwise. Wittix is pending, and will be the fifth in case of approval. All this is not just for fun, but to ensure the business is not compromised on case of sudden account closing for any reason.
I was expecting a little more help from the mentor group to say the truth...
But anyway, I now know exactly what to say, how to say it, and more important : what NOT to say in order to avoid immediate refusal from banks.
The main point to understand here is that banks do not want to hear the truth: their process are based on an "average" operator who has been trained to check boxes in a form. Your sincerity, your true vision, your background or reputation: all this means absolutely nothing for them, and neither do they have the time to listen to it. You fit with the boxes, or you don't. Period.
The rule is to twist your story and the facts in order to fit with the boxes, without crossing at any moment the "proven lie" line...
Contact me in PM for those who need precise explanations, I will be glad to help on a one to one basis.

 

[Spinat]

Mr Wolf said:
Contact me in PM for those who need precise explanations, I will be glad to help on a one to one basi
Click to expand...

You could simply explain it more clear here.

The problem with what you have done is the following, for now you got approved and if all goes well you will never get any troubles. But if you provide false information to the EMI then you have opened up a door to them to freeze your account should something fishy show up.

You will have troubles to explain the origination of your transactions, in best case you can make up a cover story which will help you go through the first trouble that may or may not occur but in long term it's going to be tricky.

I whish I had the final solution for your setup but I'm afraid there is not other that the most stable solution is in Switzerland, setup a company and there in person and consult some of the lawyers and specialists there that can setup stable and rock solid banking for your needs. It costs money, but you will never have to worry about troubles with your crypto business.

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[Mr Wolf]

@bluewen, you seems kind and intelligent.

1_ What I did is perfectly clean, clear, legal and has been agreed by the biggest law firm in Estonia
2_What I did does not imply lie, fake documentm, fake story, false information : you should read again my previous message...
3_ I have absolutely no trouble explaining the origination of the transactions, as it comes from a regulated registred crypto fund.
4_Switzerland does not apply to my case for 2 reasons :
4.1 because you can't launch a SAIF in the LP form in Switzerland, thus you can't accept lower minimum investment than $150 000.
4.2 because I work with Switzerland on daily basis for the PE Fund I craft studies for, and know for fact that baks there do not even pick up the phone under $10M under management.

Hope it helps yo understand.

As explain here all the hell I went through : as I paid to be part of the mentor group especially to receive USEFUL advice, and not people telling me how almost impossible it will be with no pragmatic efficient solution, I find weird to pay AND provide the solutions for everybody else for free.
None of any of the questions I raised so far on that forum received any valuable answer of any sort.
So.... 🙂

 

[Spinat]

Your are a big guy as I read your last reply. It must hurt to have spend €95 euro for nothing else then supporting a great initiative taken by Admin and the folks behind it. That you are such a mastermind that figured it all out yourself must be a great gift to have.

I wonder, why did you joined the mentor group at all? What did you expect to find here if you have the solution for everything yourself?

What you wrote about Switzerland is not true, not valid. It is valid in your opinion and from your experience but it is not an overall "how it works" and "how it is" !!

Let me tell you something you may not have figured out yet. You can't get lawyers advice for €95 EURO - you can get help here for basic information and you can find lots of information in areas you may not deal with, so that said, you better move on.

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[Mr Wolf]

No time to argue, sorry, I have a job.
And ming you, €95 is €95, not zero.