Question Crypto P2P Trading Setup

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IbnAlKhattab

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Aug 31, 2023
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Hey everyone!

First off I want to say I love this forum. You've all built a great thing here. All of this knowledge used to be hidden, but now any regular person can access previously niche knowledge.

Now, here's my problem: I used to trade crypto P2P on personal bank/Wise accounts, but these got shut down. I want to trade crypto P2P on a larger scale (~500k/$1M monthly volume), but banks are an issue.

These are the currencies I ideally want to be able to trade:
- AUD
- PLN
- EU/EEA currencies

I can't find a crypto-friendly bank/PSP/EMI to do local transfers in any currency (other than EUR and GBP).

I need true local transfers, not SWIFT/SEPA. This is because margins are paper thin, so any FX fees = most of the profit is gone.

I found Bankera and a few other crypto-friendly EMIs, but they only have local transfers in EUR and GBP, and the competition in those markets is too high, so the margins are low, and after maintenance fees, KYC fees, and taxes, I'm left with almost nothing.

So does anyone here know of a crypto-friendly bank/EMI that I can do P2P trading in the above markets?
 
EUR and, to a lesser extent, GBP are some of the freest and most easily transacted major fiat currencies today. The regulators have relaxed control and created excellent domestic networks (SEPA, FPS). The same cannot be said for PLN and AUD. Access to those currencies is much harder. A local correspondent bank account is required and those are usually held by large commercial banks (which typically aren't crypto friendly) or companies like Convera, Earthport, Currency Cloud, and so on which are usually a bit more expensive or aren't crypto friendly.

That's a long-winded way of saying it's going to be difficult.

IIRC, not even Zen, which is a Polish crypto friendly EMI (licensed in Lithuania) can provide PLN accounts that can be used for crypto. All accounts which aren't EUR are through Currency Cloud.

Where are you licensed?

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This is the probably the answer to your question.
 
Firstly thanks for replying!

Still haven't licensed because I want to solve this PSP/EMI issue first. I was looking at the Czech Republic (cheapest and fastest). And if the business worked then I can move to a better tax situation.

ZEN says something about local PLN transfers for business accounts, but it's very unclear and their sales team hasn't replied to my 2 emails for over a week.

Currently I don't really see a way to do this, so I came here to ask you wizards what I might possibly be able to do.
 
IbnAlKhattab said:
Still haven't licensed because I want to solve this PSP/EMI issue first.
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That's a bit like buying jet fuel for an airplane you haven't even ordered yet.

P2P crypto exchange can mean a lot of different things, but nearly all of them qualify as a financial service or VASP. Banks/EMIs are going to look at your application and ask to see your license.

In EU/EEA, you can sort of get away with getting a crypto license/registration in one EU member state and use it across the whole area. There are no official passporting rules yet, but for the time being, it's largely tolerated.

But since you want AUD, you are in scope for Australian regulations, which will make things even more complicated.

IbnAlKhattab said:
ZEN says something about local PLN transfers for business accounts, but it's very unclear and their sales team hasn't replied to my 2 emails for over a week.
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The PLN accounts I have seen Zen offer are from Currency Cloud, which does not have a risk appetite for crypto.

AFAIK, some people have managed to open bank accounts in Poland after getting a Polish crypto license/registration. But they haven't been P2P, which is a high risk segment of an already high risk sector.

P2P is very attractive for money laundering. Just steal some money in Poland, dump it on some poorly regulated/controlled P2P exchange, and have slightly cleaner money come out the other end in Australia. It's a great layering technique, in a chain of other layerings.

IbnAlKhattab said:
Currently I don't really see a way to do this, so I came here to ask you wizards what I might possibly be able to do.
Click to expand...
I think the full scope of what you want to do just isn't viable, unfortunately. You'll need to reconsider some parts of the setup.

San Marino might be worth exploring. Have a chat with someone like San Marino Setup ”“ Set up your fintech, cryptoasset or innovative project in the Republic of San Marino about your needs. While I know some of the people involved there, I'm not vouching for the viability of the setup. It's new and largely untested.

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This is the probably the answer to your question.
 
Thanks for the info, I figured it was a bit impossible since it was taking a lot of research with a lot of closed doors.

Just as an FYI, on P2P marketplaces like OKX and Binance, everyone seems to have their own little finesse. Some people make Wise personal accounts with fake info (fake KYC software or fake IDs, etc...). Others use a fronting method (the PSP/EMI they use is under a different name, not their licensed VASP). The list goes on...

The whole problem is the maintenance fees, KYC, tax, etc..., if those weren't there, then it's a no-brainer business. Just toss a few thousand in there and approve the transactions on your phone. I thought I could do this the right way (all legit) but it doesn't look it, and I'm not too keen on fraud.

If anyone has more ideas please chime in.
 
IbnAlKhattab said:
Just as an FYI, on P2P marketplaces like OKX and Binance, everyone seems to have their own little finesse. Some people make Wise personal accounts with fake info (fake KYC software or fake IDs, etc...). Others use a fronting method (the PSP/EMI they use is under a different name, not their licensed VASP). The list goes on...
Click to expand...
For the volume you mentioned, I hadn't considered this option. You can create burner accounts with synthetic, stolen, or borrowed identities. Members such as @JohnnyDoe might be able to help you with that.

But for 500,000”“1,000,000 USD/month, you need a lot of accounts. The average person will get flagged as soon as they transact more than a few hundred or ”” at most ”” a few thousand a month.

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This is the probably the answer to your question.
 
OTC desks that buy direct from market makers.

There's loads. They run slightly differently to exchanges
 
Wonder who these OTCs are because the ones we've dealt with commercially are stricter than exchanges

As for using burner accounts etc that's a one way street to the clink, especially in todays climate, they may not be investigating you personally but the person you did the transaction with and you then become collateral damage.
 
I'm bringing up a relatively old thread without much need, but who knows, it might be useful to someone.

As for PLN, it's surprisingly not that hard to have local processing (local ELIXIR / SORBNET transfers) for crypto activity. In Poland, you have the general VASP license, which is not too difficult or costly to obtain with a good law firm in Poland (DLKLegal in Warszawa and Krakow is a decent option from my experience). You will need to have one Polish AML officer. With the Polish VASP license, you can, of course, get an account at ZEN for EUR processing. They onboard crypto super easily, in general, + they are Polish. Then, for PLN, you have more options. ZEN itself closed a contract with BNP Paribas Bank Polska Spólka Akcyjna. They, similarly to CurrencyCloud (which ZEN uses for all other currencies), they have a lower risk appetite, although don't reject crypto outright. ZEN also got their UK EMI license some time back, so I assume that they now have GBP local accounts, although I haven't checked. With P2P, it might be less likely to be allowed by BNP Paribas. If you create a crypto platform, it's more likely to get approved.

To avoid risk, you can actually also open at PKO Bank Polski, the largest Polish bank. They do accept crypto businesses with VASP licensing. Probably would not work for a UBO from a higher-risk jurisdiction or non-EEA, I visited one of their larger branches and spoke to them in Polish. mBank, which is a really popular retail bank there, will also allow it. mBank doesn't generally ask many questions for opening corporate accounts - I've seen unregulated crypto investment platforms doing SEPA & local-PL with them as well (although I wouldn't take that risk). It's not that they're open to high-risk, but they just don't ask about corporate activity.

Another option can be PaySet, which is more expensive but also crypto-friendly when you have the right licensing. They are partnered with multiple banks, but not all of them allow crypto. We can cross out CurrencyCloud instantly. They have ClearBank, which will accept crypto-related transactions and provide EUR SEPA and GBP BACS/FPS, although it's the most expensive of them. Then there's Sparkasse, which has branches in a lot of countries, so it allows for local IBANs and more currencies. The pricing is fair enough. Banking Circle will provide a lot of currencies (more than 60, although I'm not sure how many they offer for PaySet customers) but not local IBANs, except for EUR, DKK and GBP.

If your turnover is high enough, consider Clear Junction, which has SEPA, SEPA Instant and, again, GBP local accounts. They also have EUR and GBP SWIFT, but their correspondents are not crypto-friendly. Their USD correspondent does not allow crypto, either. They are able to generate IBANs for your customers on demand via their API, though, if that is something you need. Bank Frick is probably best for any other currency. They share the German DZBank's correspondents, which will allow for crypto-friendly CHF, USD, AUD, NZD, CAD, CZK, HUF and a few more, although they won't be local - it will be with Bank Frick's Liechtenstein IBANs.

When all you need are EUR and GBP, there are 10s of EMIs that will take you, even with crypto. You nearly always get Lithuanian IBANs for EUR and UK local details for GBP or UK for both. Those 2 currencies are generally the least problematic for crypto processing anyway. When you look for other currencies, it's hard to get local accounts, but definitely not impossible.
 
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