Moments before the new supervisory regime over financial asset service providers came into effect on June 1, 2018, the Minister of Finance signed an order postponing the effective date until the earlier of the following: October 1, 2018, or the issue date of the Prohibition on Money Laundering Order that addresses financial asset service providers.

This postponement enables those engaged in the field of financial asset services – e.g. replacing one financial asset with another, or managing or holding financial assets – who did not file a license application by June 1, 2018, to file a license application before the new deadline specified in the order and to benefit from the law’s transitional provisions.

According to the law’s transitional provisions, anyone engaging in financial asset services who was not required to hold a license prior to the inception of the new supervisory regime, and who files a license application by the inception date prescribed in the law, will be deemed a “long-standing dealer” and will be able to receive an approval for continuing its operations until it receives a license.

We note that the term “financial asset” also includes virtual coins.

We recommend taking prompt action to file your license application. Note that if the relevant Prohibition on Money Laundering Order is enacted before October 1, 2018, the law will come into effect earlier.

If you are still uncertain about whether your business requires a license, see here.