BITSTAMP is a leading European Bitcoin Exchange. As part of the globalization strategy, BITSTAMP decided to apply for a license as a E-Money Institution in Luxembourg and benefit in this way by EU Passporting with access to the entire European market.
With regards to their application in Luxembourg at the regulator CSSF, BITSTAMP was asked to provide a detailed description document including aspects such as Business Plan, Financial details, AML procedures and IT Setup.
BITSTAMP mandated MAQIT S.A. (MAQIT) as a regulatory IT advisor to assist during the filing. Goals of the engagement were:
- the documentation of the IT description, governance, security and risks parts of the CSSF filing.
- facilitating the question and answer process between BITSTAMP, the CSSF and the Cloud Services provider.
The task involved
- Gap Analysis of the current IT Setup.
- Designing a regulatory compliant IT Target Architecture and Governance model. This setup included a hybrid cloud environment with on premise servers and public cloud servers.
- Collection of existing documentation and writing of the filing documents and appendices.
- Facilitation of the question and answer process with the CSSF.
- Advisory and Project Planning for Post-Filing tasks. Writing of IT Policy, Writing of BCP Policy.
The excellent collaboration between MAQIT and the other actors involved in the filing, made it possible to complete the filing process within a year. BITSTAMP was the first Bitcoin Exchange in Europe to obtain a Payment Institution License.