FACT SHEET: Setting up a cryptocurrency (Virtual Asset) exchange checklist – Technology

Before you set up a cryptocurrency exchange, determine the
structure of your cryptocurrency exchange:

• Crypto to fiat or crypto to crypto




• Virtual assets to be exchanged




• Broker or market maker




• Provide e-wallets




• Centralised or decentralised




• Other services (cross-border payments, etc)?




• • Draw up an end-to-end funds flow diagram

  
  

  • Determine what services will be provided in Australia

  
  

  • Set up an Australian entity (if required)

  
  

  • Seek legal advice on which Australian regulatory regimes
    apply




• Do you need an Australian Financial Services Licence
  (AFSL)?




• Do you need to comply with the Anti-Money Laundering and
  Counter-Terrorism Financing (AML/CTF)
  Regime?




• • Design and implement an AML/CTF Program including an AML/CTF
    Risk Assessment (if required)

  
  

  • Enrol and register as a Digital Currency Exchange with AUSTRAC
    (if required)




• if exchanging cryptocurrency for fiat and vice versa, and




• if geographical link to Australia




• • Prepare and lodge an AFSL application (if required)

  
  

  • If you will outsource any functions, ensure appropriate
    outsourced agreements are drafted and executed

  
  

  • Draft Terms and Conditions, Privacy Policy and Data Breach
    Policy for your exchange

  
  

  • Draft Financial Services Guide and Product Disclosure Statement
    (if required)

Next steps

Read our blog on 5 FAQs for setting up a cryptocurrency exchange in
Australia.

The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.