CASP / Digital Asset licensing in AIFC (AFSA).
Best fit for exchanges, broker/dealers, custody, tokenization infrastructure, and crypto service providers planning regulated operations from AIFC.
- Your regulated activity in AFSA terms (perimeter, permissions, restrictions).
- Client asset flows (fiat + crypto), custody and settlement responsibilities.
- Governance roles: CEO, CO, MLRO, Internal Auditor and reporting lines.
- Capital & liquidity planning, substance, outsourcing and vendors.
- Activity mapping and permission shortlist.
- Client categorisation and product boundaries.
- Marketing and cross-border positioning baseline.
- CO / MLRO model and continuity planning.
- Internal audit approach and oversight.
- Conflicts, complaints, incident response baseline.
- Risk assessment and control design baseline.
- Sanctions screening and monitoring logic.
- Recordkeeping, reporting, escalation procedures.
- License mapping and structuring logic.
- Substance, staffing and outsourcing baseline.
- Application plan + document list + timeline.
- AML policy + onboarding procedures.
- Sanctions policy + screening/monitoring.
- Compliance manual, risk/BCP baseline, incident handling.
- AFSA comment handling and redrafting.
- Controlled function packs and supporting statements.
- Alignment of financial model and capital buffers.
- Private company registration route.
- Constitutional documents and governance.
- Key commercial contracts alignment.
- Policy updates and control testing baseline.
- Periodic reporting and governance support.
- Remediation and regulator interactions.
- Vendor DPAs and outsourcing contracts baseline.
- IP clean-up and assignments.
- Client terms, privacy and disclosures.
Products, clients, flows (fiat/crypto), custody, settlement, vendors, and operational responsibilities.
Permission shortlist, substance plan, governance roles and outsourcing map aligned with AFSA expectations.
Policies, procedures, org charts, role descriptions, risk framework, financial model and supporting packs.
Handle regulator questions, redrafting, clarifications, and implementation adjustments.
- Short description of services and target markets.
- Client types and onboarding flow (incl. KYB if B2B).
- Asset flows: who holds keys, who can move funds, settlement logic.
- Vendors: custody, KYC/KYB, blockchain analytics, payment providers, tech stack.
If some parts are not defined yet, we map them together in the kick-off and build a workable baseline.
- Licensing perimeter memo + assumptions.
- Compliance documentation pack (AML, sanctions, compliance manual, risk/BCP baseline).
- Governance & controlled functions baseline (roles, reporting, independence).
- AFSA Q&A support and revision rounds.
If you want a fixed-scope start, see Packages or request a tailored scope via Contact.
AFSA evaluates substance and governance. Outsourcing can help, but key roles, reporting lines, and oversight must be realistic and documented. We design the model accordingly.
Asset flows (custody/settlement), outsourcing chain, conflicts of interest, AML controls, and whether the documents match real operations and staffing.
Yes. We typically start from perimeter and readiness, then move to document drafting, controlled function packs, and AFSA Q&A handling and revisions.
Yes. Many projects plan multi-jurisdictional expansion. We can map AIFC requirements in parallel with MiCA/UAE routes to avoid rework later.
- Entity and shareholders, where the team will sit.
- Asset flows: wallets, custody, settlement, fiat rails.
- Client onboarding (retail/professional, KYB/KYC approach).
- Vendors and outsourcing (custody, KYC, blockchain analytics, PSPs).
Even 8–10 lines is enough to start.