We understand that our success is driven by that of our clients.
We would like our clients to launch crypto-related projects which are scalable, successful and in line with applicable laws and regulations. To help you achieve this, we ensure that you receive the best possible advice based on our knowledge and previous experience in Maltese legislation relevant to the crypto-industry.
We promise to do this in the most time-efficient manner because we understand that your time costs money. We are here to help you.
Being based in one of the most crypto-friendly jurisdictions in the world, Zerafa.io has been actively involved in providing advice to various crypto-related projects, including crypto-exchanges, brokers and entities entrusting with safekeeping of virtual financial assets.
In Malta’s recent efforts to regulate the field of cryptocurrencies, blockchain and DLT, any issue or other service relating to virtual financial assets in or from within Malta requires the involvement of a VFA Agent.
Zerafa.io has been established to be in a position to provide the services of a VFA Agent to its clients, in relation to entities providing services relating to VFAs.
We commit to continue providing such services while remaining loyal to our principles of efficiency, dedication, and personal attention.
Apart from guiding you in the licensing process and providing you with other related services, we can help you with the following:
Submission of application for a VFA licence – Since any application for a licence under the VFA Act may only be made through a VFA Agent, Zerafa.io Ltd is offering its services to assist in the submission of an application for a licence to operate under the VFA Act.
Endorsement of classification of VFAs – The requirement to hold a licence in terms of the VFA Act to provide services only subsists if such services are provided in relation to VFAs. Therefore, the service provider is required to carry out the Financial Instrument Test to determine whether the DLT assets in relation to which these services are provided are classified as VFAs. We can also assist you in the carrying out and endorsing the result of the Financial Instrument Test.
Liaising with MFSA – We can assist you in acting as liaison between you and the competent authorities on an ongoing basis by communicating with the MFSA and any other Maltese authority, and submitting to such authorities any required information or documentation.
Our Compliance Services
We also provide the service of acting as Compliance Officer for VFA service providers and our services include the following:
Preparing an Annual Compliance Program
Implementing adequate policies and procedures to identify breaches by the licence holder, to minimise such breaches, as well as reviewing their effectiveness on a continuous basis
Ensuring staff awareness of any applicable laws and regulations and providing adequate training to staff of the licence holder
Carrying out frequent compliance review meetings
Preparing frequent detailed compliance reports following review meetings
Immediately informing the management in case of breaches of any rules and keep adequate records of such breaches, and liaising with the management on any issues raised in connection with his duties
Informing the authorities in case of breaches of any rules, and monitoring returns provided to the authorities to ensure that no incorrect or misleading information is provided to the authorities
Carrying out any other duty that might be reasonably requested by the licence holder and/or the MFSA which is ancillary or complementary to the above duties
Why Work with Us?
We are focused solely on virtual financial assets, blockchain and DLT to ensure a more specialised approach and tailor-made services in a time-efficient manner
We are based in Malta, one of the most crypto-friendly jurisdictions in the world
We specialise in Maltese law, which is one of the few legal systems to regulate the crypto-industry in a holistic manner
We have hands-on experience in the field, having collaborated and provided advice to highly successful players in the industry
We have extensive experience in the financial services and commercial sectors which are also relevant to the crypto-industry and with the licensing and authorisation regime in Malta
We do our utmost to keep updated with current developments by attending specific training and conferences
We insist on continuing professional development so our people can always give you the best advice
Dr. Omar Zerafa
Dr. Omar Zerafa has obtained the degree of Doctor of Laws from the University of Malta in 2010, following which he has also graduated from the University of Leicester with a Masters in European Union Law specialising in Commercial Law during the same year.
Prior to establishing Zerafa Advocates, Dr. Omar Zerafa has worked as an associate with one of the leading financial services law firms in Malta where he was also admitted to partnership, responsible for the structuring and licensing of collective investment schemes, investment vehicles, investment services licence holders including asset management companies and financial institutions. Dr. Zerafa draws on his experience in Maltese and European law on financial services and securities markets to provide highly detailed legal advice to issuers and service providers relating to cryptocurrencies.
He has a Foundation Certificate in Trust Law and Management awarded by the Institute of Financial Services Practitioners and is a member of the Chamber of Advocates, the International Bar Association, the Institute of Financial Services Practitioners and the Financial Services Lawyers Association (UK).
Dr. Emerson Bonello
Director & MLRO
Dr. Emerson Bonello obtained a Bachelor of Law (Honours) degree before obtaining a Master in Advocacy degree in 2017 from the University of Malta.
Dr. Emerson Bonello is currently an Associate within Zerafa Advocates and dedicates a considerable amount of his time researching and providing legal opinions in the field of cryptocurrencies, blockchain and DLT. He occupies the position of a Company Secretary in several companies incorporated in Malta which operate crypto-exchanges or provide services relating to cryptocurrencies. He is approved by the MFSA as a Compliance Officer for a trustee company and two company service providers.
He has also obtained a Foundation Certificate in Trust Law and Management awarded by the Institute of Financial Services Practitioners and is also a member of the Chamber of Advocates.
Dr. Clint Bennetti
Dr. Clint Bennetti is a lawyer by profession who holds a Master of Arts in Financial Services. He started his career as an associate with a law firm that specialises in financial services and investment services law. During his tenure within the firm he was admitted to partnership. He later joined TMF Group as Director where he was responsible for the day-to-day management and operations of TMF Group’s entities in Malta. At TMF Group, he was Director Client Services of a Company Services Provider, coordinating and managing its business on a day-to-day basis and from a strategic perspective, and Managing Director and member of the trustee committee of a Retirement Scheme Administrator.
Dr. Bennetti has held a number of executive and non-executive directorships as well as company secretary positions in a number of companies in a number of diverse industries. During his career, he was approved by the MFSA to act as a director and money laundering reporting officer for an Alternative Investment Fund Management company for which he coordinated the successful application for a Category 2 Investment Services License. He is currently director, company secretary, MLRO and Compliance Officer of a number of entities that are licensed by the MFSA, including a number of collective investment schemes.
Dr. Bennetti holds a number of professional qualifications including a certificate in Trusts Law and Management and a certificate issued with respect to the Virtual Financial Assets Act by the Institute of Financial Services Practitioners. During his career Dr. Bennetti has attended numerous other courses on topics such as risk management, securities law, compliance, company law, investment services and collective investment schemes. Dr. Bennetti is a member of the Institute of Financial Services Practitioners and the Malta Institute of Management and is registered and an Authorised Registered Mandatory with the Inland Revenue Department of Malta.