Blockchain and crypto engagements rarely fail on the technology. They fail on structure — a token that cannot be sold where the buyers are, a platform that cannot bank, a protocol whose governance has no legal counterpart. We work on the structure first: entity, ownership, token design and jurisdiction, tested against the markets you actually intend to serve.
From there the work is concrete. The regulatory classification of what you are issuing or operating, the custody and key-management model, the compliance programme a counterparty will accept, and the banking and payment relationships that let the business transact. Where a full licence is not required, we say so — and document why, so the position is defensible rather than merely convenient.
Typical engagements: custodial exchanges and brokers, token issuers, DeFi protocols needing a legal wrapper, and infrastructure providers selling into regulated clients.
- You are issuing a token or operating a platform and cannot say with confidence whether it is a regulated activity in each target market.
- A bank, exchange or payment provider has declined you, or is asking questions you cannot yet answer in writing.
- Your structure has grown organically and needs to be made defensible before a raise, a listing or an institutional partnership.
- You have been told you need "a crypto licence" without anyone testing whether that is true for your model.
Classification decides everything
Whether what you issue is a security, a payment instrument, a utility or something the regulator has not yet named determines the entity, the filing and the markets you can serve. We resolve it before any structure is built.
Custody is the hard part
Who holds the keys, and under what legal arrangement, drives both the licensing perimeter and whether a bank or institutional counterparty will onboard you at all.
Defensible, not merely compliant
The test is not whether a policy exists, but whether the position survives a bank review, an exchange listing diligence or a regulator query eighteen months later.
- Regulatory classification memorandum for each target market
- Entity, ownership and issuance structure, including foundation or trust wrappers where relevant
- Custody, wallet and key-management architecture and its legal basis
- AML/CFT, KYC and transaction-monitoring programme sized to your risk profile
- Licensing or exemption position, with the reasoning documented for counterparties
- Banking, payment and exchange partner introductions
- 01
Model and classification
We map what you actually do — custody, transfer, issuance, intermediation — against the regimes in each market you intend to serve. The output is a written classification, not a conversation.
- 02
Structure
Entity, ownership, issuance and custody architecture is settled next, because it determines what can be licensed, what a bank will accept and what a listing exchange can review.
- 03
Compliance build
AML/CFT, KYC, monitoring and disclosure prepared to the standard a bank or regulator actually applies — decision-ready on first review.
- 04
Position and document
Licence applications or a documented exemption position, so counterparties get a defensible answer instead of an assertion.
- 05
Rails and scale
Banking, payments, custody and exchange connectivity, then the first expansion market once the base is operating.
Classification and structure review
A focused engagement to resolve what you are, where, and what that requires — before you commit further capital or code.
Pathway and build
Full structuring through to licensing, the compliance programme and the banking that makes it operable.
Retained advisory
Standing counsel as the model, the markets or the rules change, with periodic review of the position.
- Projects looking for a rubber-stamp opinion on a structure they have already irrevocably committed to.
- Teams unwilling to change entity or token design where the current one creates unmanageable exposure in their target markets.
Not always. Whether you need one turns on custody, whether you hold or transmit customer funds, and where your customers are — not on whether the business describes itself as "crypto". A great many platforms operate lawfully outside a full VASP authorisation; the point is to document why, and to know the point at which the model crosses the line.
Sometimes, and the analysis is fact-specific: what the token does, how it is sold, what is promised, and to whom. Where the answer is that it is a security in a given market, we design for that rather than pretending otherwise — which usually means a compliant offering structure, not abandoning the market.
It changes the engagement, not the value of it. A large share of this work is remediation: taking something already operating and making the structure, the custody model and the compliance programme defensible before a bank, a listing exchange or a regulator looks closely.
We lead the commercial and structuring workstream and coordinate local counsel. The difference is that the structure is designed around whether the business can bank, transact and scale — not only around the legal question in isolation. Where you need an opinion from a qualified local lawyer, we brief and manage that.