An exchange is a regulated business with a software product, not the other way around. Licensing sets the markets and the products, banking decides whether fiat can move at all, custodial architecture determines what a customer actually owns, and liquidity decides whether anyone trades.
Most exchange failures we see are not engineering failures. They are a licence that does not cover the product, a banking relationship that evaporates at scale, a custody model with no legal separation of customer assets, or liquidity that disappears as soon as incentives stop.
We sequence the exchange as a regulated financial business: entity and authorisation, custody and client-asset protection, banking and fiat rails, then liquidity and market structure — with the compliance programme built to the standard that gets it banked and listed.
- You are launching or expanding an exchange and need the right VASP authorisation for each market.
- Fiat deposits or withdrawals have been cut off by a banking or payment partner.
- Your custody model does not clearly separate customer assets, or you cannot explain the legal basis on which they are held.
- Volume depends on incentives and falls away the moment they stop.
Custody is a legal question
Whether customer assets are legally segregated, and under what arrangement a third party holds them, decides both the licensing perimeter and whether a bank will onboard you.
Banking is the real bottleneck
An exchange can hold a licence and still be unable to move fiat. We treat fiat rails and banking access as a first-order design problem, not an afterthought.
Liquidity must survive incentives
Market-maker rebates and token incentives manufacture volume that vanishes when they stop. We design liquidity that a real order book can sustain.
- VASP licensing pathway per market, with the product-permission mapping
- Custody architecture — segregation, sub-custody and the legal basis for holding client assets
- Fiat rails, banking and payment-partner strategy with introductions
- Market-making, liquidity-provider and listing framework
- AML/CFT, KYC, travel-rule and transaction-monitoring programme
- Exchange policies, terms of service and the counterparty-facing legal file
- 01
Define the product and the perimeter
Spot, derivatives, custody, staking, lending — each carries a different permission. The product map decides which authorisations you actually need.
- 02
Structure custody
How customer assets are held, segregated and protected, and how that is documented so both the regulator and the bank accept it.
- 03
Open the fiat rails
Banking, payments and on/off-ramp partners positioned early, because they are the longest lead time in the whole programme.
- 04
Build compliance
AML/CFT, KYC, travel-rule handling, monitoring and reporting designed to survive a bank review and a licence application.
- 05
Establish liquidity
Liquidity providers, market-making arrangements and listing standards, then a market-structure review once real volume appears.
Licensing and perimeter read
A written determination of the authorisations your product set requires, market by market, with the banking implications named.
Exchange launch programme
Licensing, custody, banking and compliance run as one programme through to go-live and first listings.
Liquidity and market structure
A focused engagement on liquidity sourcing, market-making and listing standards for an operating venue.
- Venues planning to operate without the authorisation their product set requires, in markets that enforce it.
- Exchanges unwilling to segregate customer assets — no durable banking relationship survives that.
It follows from the markets you serve and the products you offer, and there is rarely one right answer. A MiCA authorisation in Europe, a local VASP registration in an offshore market or a US state-by-state approach are genuinely different businesses. We map the products to the permissions and then choose on the basis of where your customers and your banking are.
Usually because the licence, the custody model or the compliance file does not yet answer the questions a bank asks. Banks are not allergic to exchanges as a category; they are allergic to unclear custody, incomplete AML controls and products the licence does not cover. Fixing those is what reopens banking.
For a new venue, usually yes, to establish a credible order book — but the arrangement should be designed so that organic liquidity can take over. We help structure the agreement and the incentives so volume reflects demand rather than subsidy.
It varies enormously by regime and by the completeness of the file. What we control is the quality of the first submission and the banking workstream running in parallel, which together have the largest effect on total time.