On June 1, 2018, the provisions of the Supervision of Financial Services (Regulated Financial Services) Law, 2016 (the "RFS Law"), that set out licensing requirements for the provision of services in financial assets, were scheduled to come into effect.

However, on May 31, 2018, in order to prevent a regulatory vacuum, the Minister of Finance published an order postponing the effective date until the earlier of October 1, 2018, or the publication date of the Prohibition of Money Laundering Order regarding Providers of Services in Financial Assets.

This postponement presents an opportunity for any entity providing financial asset services that has not yet filed an application for a licence, to apply for a licence now and benefit from the RFS Law's transitional provisions. Under these provisions, providers of financial asset services providing such services prior to the effective date of the new supervisory regime and having applied for a licence prior to said date will be granted approval to continue providing such services until receipt of the licence.