Crypto Payment Infrastructure Audit for Major CIS Bank

An innovative crypto service company launched by one of the largest banks in the CIS was preparing to build a multi-jurisdictional infrastructure for virtual asset services, with an initial focus on Hong Kong. The business model contemplated complex flows: third-party providers, cross-border data and asset transfers, and the use of virtual assets in payment and exchange transactions. The client needed clarity on applicable regulations, licensing expectations, and structuring options across target jurisdictions — including the role the UAE could play as a regional hub — before committing significant capital to the build-out.

We conducted a comprehensive legal and operational audit and delivered a structured roadmap covering the full scope of the proposed infrastructure:

1. Regulatory mapping — analyzed applicable virtual asset regulations across target jurisdictions, including Hong Kong and the UAE frameworks under VARA and the Central Bank of the UAE.
2. Risk assessment — identified risks tied to cross-border service delivery, infrastructure dependency on third-party providers, and the use of virtual assets in payment and exchange flows.
3. Compliance review — set out licensing requirements, KYC/AML expectations, and enforcement trends relevant to each jurisdiction under review.
4. Structuring options — proposed scenarios for a scalable, regulator-friendly payments infrastructure, including the UAE entity as a regional headquarters or IP-holding company depending on risk appetite and go-to-market plan.