Zitadelle AG January Regulatory & Market Digest

Zitadelle AG January Regulatory & Market Digest

Global Licensing, Fintech Regulation, and Market Entry Updates

As part of our ongoing commitment to keeping fintech founders, brokers, and crypto businesses informed, Zitadelle AG presents its January Regulatory & Market Digest. This edition highlights key regulatory developments, jurisdictional risks, and strategic licensing and acquisition opportunities across Europe, the Middle East, Asia, and Africa.

Key Global Regulatory & Licensing Developments

Increased Risks from Misrepresented “Fintech Regulators”

In recent months, Zitadelle AG has observed a growing number of entities falsely presenting themselves as regulators while offering so-called fintech, broker, or crypto licences. These structures often lack any statutory authority and expose applicants to significant legal and financial risks.

We strongly advise market participants to conduct enhanced regulatory due diligence and verify:

Legal basis of the regulator
Recognition by domestic or international authorities
Banking and payment acceptance of the licence

Proper jurisdiction selection remains a critical first step in any fintech or crypto market entry strategy.

We already wrote about the questionable jurisdiction of Comoros, then we had an article about Sierra Leone Capital Markets authority (alleged) and now a new website has surfaced - BOFA or bougainvilleofa. Stay away. Stay vigilant.

Offshore Banking Structures – Heightened Counterparty Risk

Certain offshore institutions marketed as “banks,” particularly in smaller jurisdictions such as Comoros, continue to raise serious concerns related to:

Client fund safety
Governance and transparency
Correspondent banking access

For brokers, VASPs, and payment institutions, improper banking relationships can result in frozen funds, loss of payment rails, and reputational damage. Careful counterparty assessment is essential. Now an entity under a name of Wall Street IBU caught our attention due to many customer complaints about frozen funds and requests to top up the account with more balance in order to release any payments. Stay away. Stay vigilant.

Vanuatu VASP Licensing – New Fees and Requirements

Vanuatu has officially implemented revised licensing conditions for Virtual Asset Service Providers (VASPs), significantly increasing the cost of operation:

USD 50,000 government application fee
USD 100,000 annual licence fee

These changes materially impact Vanuatu’s competitiveness and require a reassessment against alternative crypto licensing jurisdictions such as Labuan, Mauritius, or the UAE. Do you think any company is going to apply with such fees? Let usk know your thoughts.

British Virgin Islands (BVI) Added to EU High-Risk List

The British Virgin Islands (BVI) has been added to the EU list of high-risk third countries. This development is already affecting:

Cross-border transactions
Correspondent banking relationships
AML and transaction monitoring requirements

Companies with BVI structures should anticipate increased compliance scrutiny and operational friction.

South Africa – Rising Demand for Crypto Asset Service Provider Licensing

South Africa is once again emerging as a strategic jurisdiction, this time driven by demand for crypto-asset service provider registrations under the FSCA framework. Unlike earlier interest focused on FSP 1.13 derivatives permissions, the current trend reflects Africa’s broader digital asset adoption. If you are interested in acquiring or applying for either FSP 1.13 or the crypto-asset authorization, contact our team for assistance.

UAE SCA Category 5 Licence – A Leading Brokerage Authorisation

The UAE SCA Category 5 licence continues to stand out as one of the most attractive brokerage authorisations in 2025. Key advantages include:

Strong regulatory credibility
Access to regional and international markets
Clear substance and governance requirements

Zitadelle AG supports clients throughout the entire SCA licensing process, including regulatory structuring, application preparation, compliance frameworks, and local senior management hiring. Click here for more information.