DSA/ICA Changes as of 12.11.2017

Dear Sirs,

Referring to our last various email regarding subject matter i.e. setting-up a Vanuatu FX/Brokerage Licensed Company, please see the latest updates as received from Vanuatu a few hours ago

1. Providing a copy of Indemnity Coverage (Professional Indemnity Coverage) in the name of the future Representative Securities Dealer (individual) – we can arrange to get it done. Costs for indemnity cover not included in our prices; subject to the insurance company

2. Agreements or Draft Agreements reflecting the setup of the business functionality:

- Account Opening Agreements – we provide
- Contract / Draft Agreement with Liquidity Provider or other regulated Brokerage entity that will execute and clear the position in the market – we can assist with both
- Simple contract for infrastructure use in an office outside Vanuatu – can be a sub-rental contract
- Telephone / Internet contract with the Vanuatu company or another associated company that proves that the company will have internet access
- Providing of Static IP Address
- Providing of skype account username

3. Corporate Shareholders will only be allowed if the corporate docs are duly legalized/certified, all members such as Directors, shareholders etc are fully verified by KYC

- Proof of address of the shareholder company along with the corporate documents
- Proof of identity of all involved persons in the shareholding company with notarized passport and original bank statement/proof of address showing names and address and not older than 3 months
- NO nominees allowed in the shareholding companies – clean Due Diligence required

4. For Compliance Officer we do not recommend any nominees anymore. We need notarized passport scan on white background, proof of address clear scan, CV, names and birthdays of closest family relatives, criminal record certificate. The Financial Intelligence Unit now declines appointments of nominees acting as compliance officers.

5. Directors: we recommend only to nominate as Director also the person or company that is acting as shareholder since National Bank of Vanuatu and the VFSC might consider further deep checks with very long delays and no guarantee of approval

6. Representative Securities Dealer must bring now along notarized passport, original criminal record/police clearance certificate, original bank statement also a CV with 2 business references of previous and current employers (on separate letterheads with stamp and signatures and description of previous or current activity), names and birth dates of closest family relatives

7. Bank statement reflecting that the 50,000 USD securities deposit & license fees will be paid from the shareholders or Representative Securities Dealers bank account - this is for Money Laundering Prevention purposes

Resumé

Due to tighter restrictions and already declined applications of competitors
​'​ customers we recommend strictly to follow our advice and not put more than 2 different individuals or companies in the company structure. The ideal is shareholder and director and Representative Securities Dealer an individual – the same – person. If not other possible then shareholder and director a company SHALL BE THE SAME ENTITY, Representative SHALL BE an individual, compliance officer SHALL be an individual.
WE CANNOT TAKE LIABILITY IF ANY APPLICATION GETS DECLINED BECAUSE CUSTOMERS WANT TO IMPLEMENT TOO MANY NOMINEES OR EVEN NOT APPEAR
​UNDER​ THEIR OWN NAME.

IF OUR ADVISE IS FOLLOWED WE WILL GET IT APPROVED – BUT ONLY AS LONG ALL REQUIREMENTS FROM THE REGULATOR ARE SATISFACTORILY​ FULFILLED!

Account package included:

- Full bank account with National Bank of Vanuatu with sight / online access
- Payment Provider Merchant account in Asia with regulated entity (SEPA, SWIFT, credit card processing (last if approved – subject to the provider)
- Payment Provider Merchant account with regulated entity in Europe (SEPA, SWIFT, BTC, sofortbanking etc)
- IBAN account in Europe with dedicated IBAN number for SEPA funding only and outgoing transfers via SWIFT (ideal if cooperations exist with EU brokers and European Liquidity Providers)
​Always at your kind disposal.

​Best ​regards
​Licensinging Dept​

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