Company for cryptocurrency investment pool

[crypto7figs]

I'm from a third-world country, living in another third-world country free tax.

The company I want to register don't have assets under management, but we bring seed rounds to a group of investors for a fee.
The company needs to sign agreements SAFT

Thought about Cayman or BVI with a nominee. What are your recommendation?
(I posted in the open forum, if adm could delete there, I'm sorry)

 

[Sols]

BVI and Cayman sound like good places for closer research. Isle of Man might be another option worth looking into.

Depending on the relation between the investors and the company and its activities, you may need some form of registration (but not license) with the a regulator. Registrations are usually quite simple, typically requiring just a nominee director or two and some form of AML policy.

Reach out to some reputable service providers and see what they say about your business.

I have seen people make similar arrangements in many places (US, EU, Hong Kong), without any kind of registration. However, in those cases it's been friends, family, or other tightly knit groups forming a company to invest in crypto jointly. When you raise money externally, it's a different story.

I think some type of vehicle in Luxembourg could work, but it's a complicated and tedious jurisdiction compared to BVI, Cayman, and Isle of Man. If your long term goals include being more public facing, though, it might be worth the extra hassle.

Toggle signature
This is the probably the answer to your question.

 

[crypto7figs]

Thank you for responding to the thread.

Just to clarify, we do not manage any assets or provide financial advice. Investors choose their investment and according too the pool in which they would like to invest.

As a company that connects projects with investors, we are primarily a service provider. Perhaps a launchpad could be a suitable primary function for the company? Not exactly sure what would be the primary role of the company here, but I am almost sure that it's not a investment fund because we don't make the decisions and don't have access to the funds of investors

 

[crypto7figs]

Maybe it would make sense to register as crowdfunding?
Does anyone have contacts that would make sense? I tried many service providers but didn't have success.

 

[crypto7figs]

It has been almost a week, still didn't have an answer. Thought that paying it would help to have a clearance.
I still didn't find good service providers, I've checked the recommendations, but there is only one BVI that didn't respond to my e-mail and no Cayman.

 

[Sols]

crypto7figs said:
Just to clarify, we do not manage any assets or provide financial advice. Investors choose their investment and according too the pool in which they would like to invest.
Click to expand...

Do the investors give money to you, or do they deposit money directly into the pool? Is the pool regulated in some way?

crypto7figs said:
As a company that connects projects with investors, we are primarily a service provider. Perhaps a launchpad could be a suitable primary function for the company? Not exactly sure what would be the primary role of the company here, but I am almost sure that it's not a investment fund because we don't make the decisions and don't have access to the funds of investors
Click to expand...

It sounds like you're a curated crowdfunding platform.

If you handle the money at any point in the chain (for example, investors pay you and then you deposit money into the pool), you probably need a license or registration of some sort. It's a form of money remittance (taking money from person A to give to person B). Traditional remittance requires a license but since this is for a very narrow scope and essentially buying a product/service through someone, a voluntary registration and proof of solid AML framework may be enough.

If you don't handle the money, I don't think you'd need any kind of regulatory approval. Just make sure you work with a good lawyer to help you get the right T&Cs, disclosures, and warnings in place.

crypto7figs said:
Maybe it would make sense to register as crowdfunding?
Click to expand...

Yes.

As for choice of jurisdiction, I'd start at home. See what regulatory options you have locally. In most cases, that's much easier than going to other countries. Describe your business to a reputable attorney and see what they say.

If you live in a highly unsuitable territory, check with legal advisers in jurisdictions with a strong footing in investments and/or crowdfunding on an international scale. I'd expect these to be Cayman, BVI, Isle of Man, UK, US, Singapore, and Gibraltar.

All of these places are packed with lawyers. To get you started, check with DQ Advocate, ILS World, Vistra, Sovereign Trust, Hassans (Gibraltar), CNP Law (Singapore), Carey Olsen (multinational, including BVI and Cayman), Stuarts (Cayman), and Campbells (BVI).

Toggle signature
This is the probably the answer to your question.

 

[crypto7figs]

Wow, that was an amazing answer. I deeply appreciate you taking the time to answer.

1- No, the pool is not regulated.
They connect their wallet and send the funds to the pool. Then I withdraw from the pool to send to the project.
Then they launch the project send the tokens to the wallet, which I deposit entirely to the pool.
The revenue comes from a service fee.

2- About AML, I don't know the investors, and no way to KYC them, it would kill my business.
Would be necessary? I can AML my part, can't be responsible for who joins or don't to the pool.
It's just how crypto works.

3- The country I am in is not good, I would go for the ones that you recommended.
Thank you very much

Last edited: Apr 9, 2023

 

[Sols]

crypto7figs said:
2- I move from the Pool to a wallet and this wallet to the project. The project then sends the tokens to the wallet, which deposits to the pool. About AML, I don't know the investors, and can't KYC them, it would kill my business.
Click to expand...

By inserting yourself in the money flow, you are entering regulated territory. The regulations are meant to ensure you don't run away with the money and to ensure that you don't take money from or give money to criminals. It's debatable how effective such regulations are, but they are the framework we have to face. However, if someone does use your platform to launder money or fund terrorism, you are on the hook for the consequences. Having an effective AML framework should prevent that, or at least seriously reduce the penalties.

At bare minimum, you might need something like Chainalysis and background screening of parties (PEP/sanctions checks). KYC doesn't always have to involve requesting documents.

If you were dealing in fiat, there would be no question about it. You'd have to have a license. If this is a pure crypto company, you might be able to get away with it for a while.

Toggle signature
This is the probably the answer to your question.