Scalable tailor-made advisory
services to the crypto-industry

We ensure that you receive the best possible advice based on our
knowledge and previous experience in Maltese legislation relevant
to the crypto-industry.

About us

Being based in one of the most crypto-friendly jurisdictions in the world 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. 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.

van Cutsem Wittamer Marnef & Partners​


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, 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.


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
van Cutsem Wittamer Marnef & Partners​


  • 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 specialise in Maltese law, which is one of the few legal systems to regulate the crypto-industry in a holistic manner
  • 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
  • We are based in Malta, one of the most crypto-friendly jurisdictions in the world
  • 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


MFSA publishes amendments to the VFA FAQs

The Malta Financial Services Authority (the “MFSA”) has recently amended their Virtual Financial Assets (the “VFA”) Frequently Asked Questions (“FAQs”) adding FAQs in section 5 and a whole new section 10. The amendments supplement the

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Updates to the AML Directive – Part II

The following is the second part of an article which provides an overview of the major changes brought forward by the 5AMLD. E-money and prepaid cards There is now increased transparency regarding e-money products by reducing the threshold amounts

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Update to the AML Directive – Part I

A Review of the EU Directive 2018/843 Directive (EU) 2018/843 of the European Parliament and of the Council of 30 May 2018 amending Directive 2015/849 on the prevention of the use of the financial system for the purposes of money laundering or ter

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Consultation Document on MFSA’s FinTech strategy

The Malta Financial Services Authority (“MFSA”) has published a Consultation Document on its FinTech strategy (“Consultation Document”), with the aim of adopting a strategy where the MFSA focuses its efforts towards supporting such industr

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