Belize Financial Institution vs Cyprus CySec License - many questions before I order

Initial question from client:

First of all I would like find out if acquiring a licence is even a possible for my way of doing business. I want to sell an financial instrument (binary options based on currency index) from self service machine. The entire process of buying and execution of option is visualized by symbols known from gambling industry. The process of investing may seems to be similar to process of playing on hot spot gambling machine machine.

Moreover, the company from Cyprus will be only a intermediate (broker) between the customer and some offshore full forex licence investment company. Since it is not a regular way of selling financial instruments I would like to know how Cyprus regulator will react on that kind of proposal.

Like I said, the entire process of investing is taking place near a self service terminal located in a bar or restaurant. So the problem mayby AML procedure and KYC. The optimal way for us is that we do not identify our client at all. I know that this most probably will be impossible, but the question is, how far with 'no identifying' we can go.

The next question is how Cyprus regulator will react if some other EU countries will send some complains for us. I of course not speaking about cheating the clients, only the way of doing business itself.

In additional I would like to know what the company should do after obtaining a licence in order to not lost it. And what will be the cost of it.

I need help with hiring a proper(from regulator point of view) staff as well

Those are topics that I would like to talk about.

CCLOGIC Agent reply:

Thank you for your interest in our services and the formation of a Cyprus financial service licensed company.

You can actually find out much more about this services and capital requirements by visiting the link below:

/forum/articles/59554-forex-fund-management-company-in-the-seychelles-or-cyprus-please-read

We have dedicated staff in-house that has helped a dozen companies to obtain a Financial Service license by CySec.

Our fee range between EUR 35.000 - 45.000 depending on various points.

The Capital requirements may in your case (from how I read you) be EUR 1 million, to be able to clarify that exactly we would need to go in dept into a detailed business description from you. We will charge for this service.

Usually to get started we would need to know if you have such money available and then we can take all details from there, the initial costs to figure out what business model may work best for you starts from EUR 1500 to 2000 in consulting fees where we will put you in touch with our dedicated staff.

Last edited: May 29, 2016

Client reply:

Can you please tell how that consulting service for 2000EUR looks like? My simple question is: what information I will have after that consultation?

If I decided to buy that service, I would like to meet in next week in Cyprus, I have to schedule a several meeting, can you please tell what will be your availability next week?

CCLOGIC Agent reply:

Thank you for your e-mail, we get so many requests like your each week that we have to stop it somehow. 96% of the request we get never end with any sale and we have spend hours on providing information and hold meetings, phone conversations and so on.

So the 2000 EURO are an instalment, we will charge on a per hour rate of (EUR 350 / pr hour) and if the client decide to order we will set off this amount on the total costs. And if you don't order we will set off the per hour rate of the instalment and pay back the rest to the client.

If you still want this meeting, please let me know and I will be happy to forward our relevant invoice and schedule a meeting with our specialists.

Client Reply:

OK, this is a reasonable attitude. I agree on that condition. I will be in Cyprus next week, so I would like to schedule a meeting during that time.

CCLOGIC Agent:

Thank you for your reply.

In order to prepare the instalment amount and to schedule the time needed, please provide me with the agenda for your meeting so we can have all the staff ready at your disposal.

Also, are there any special days you would prefer?

Client reply:

First of all I would like find out if acquiring a licence is even a possible for my way of doing business. I want to sell an financial instrument (binary options based on currency index) from self service machine. The entire process of buying and execution of option is visualized by symbols known from gambling industry. The process of investing may seems to be similar to process of playing on hot spot gambling machine machine.

Moreover, the company from Cyprus will be only a intermediate (broker) between the customer and some offshore full forex licence investment company. Since it is not a regular way of selling financial instruments I would like to know how Cyprus regulator will react on that kind of proposal.

Like I said, the entire process of investing is taking place near a self service terminal located in a bar or restaurant. So the problem mayby AML procedure and KYC. The optimal way for us is that we do not identify our client at all. I know that this most probably will be impossible, but the question is, how far with 'no identifying' we can go.

The next question is how Cyprus regulator will react if some other EU countries will send some complains for us. I of course not speaking about cheating the clients, only the way of doing business itself.

In additional I would like to know what the company should do after obtaining a licence in order to not lost it. And what will be the cost of it.

I need help with hiring a proper(from regulator point of view) staff as well

Those are topics that I would like to talk about.

CCLOGIC Agent:

We will charge EUR 1500 instalment fee that has to be paid, attached our relevant invoice!

Client reply:

Yes, I would like to proceed. I am adding a bank transfer confirmation. You suppose to get the same confirmation from my bank already.

I will be in Cyprus from this Sunday till next Sunday. I have already scheduled two meetings, in Monday and Tuesday. Both at 15:00 and both in Limasson. For the rest time I am available, please propose the data that suits you best.

Client reply after meeting:

Could you provide more information regarding to incorporation financial institution in Belize? What are the requirements and what would be the annual cost of maintenance the company?

CCLOGIC Agent:

The requirements are as per the following:

We will need a CV for each of the shareholders and director together with:

- copy of passport

- utility bill not older than 3 months

- Bankers Reference letter not older than 3 months

Annual costs depends a little on the activity of the company, but typically for accounting and financial report it is EUR 4500 - 6000, company renewal costs (all services, including registered office, company secretary service and government fees) is EUR 4500

As you may see, it is much cheaper and easier to setup, maintain and operate.

Client reply:

It look promising, however I need a little bit more details.

How many directors (executive and non executive) do I need?

What are requirements for directors and shareholder?

Can initial capital came from loan?

CCLOGIC Agent:

Sounds good, I will go through your questions as per the following:

1) You only need 4 directors (we can provide nominees for one of them if needed)

2) They need to have some sort of experience in the field, but no educational requirements nor do they need to show anything.

3) As I mentioned, you can wait to pay in the initial capital up to 12 months and then yes it can come from loan

It is pretty easy to get these entities setup at the moment, since the government in Belize is approving the license and operation with ease in an effort to attract new investment's to Belize.

The nominee director service for such an entity is EUR 1950 / 12 months / each

We don't provide full nominee services for such entities without an additional responsible fee, if you don't want to be director of the company and only want our nominees to be director we will charge EUR 8000 / annual in responsible fee on top of the nominee director fee. We will have to sign an insurance for your business case.

Client reply:

What would be the cost for nominee director? Why only for one director?

CCLOGIC Agent:

The nominee director service for such an entity is EUR 1950 / 12 months / each

We don't provide full nominee services for such entities without an additional responsible fee, if you don't want to be director of the company and only want our nominees to be director we will charge EUR 8000 / annual in responsible fee on top of the nominee director fee. We will have to sign an insurance for your business case.

The responsible fee is an Internal thing we charge because our company has to sign an insurance in case the company will be doing any kind of activity where we can be held responsible because we are providing the nominees. It is not something this entity has to sign or you have.. it is something we have to do.

CCLOGIC Agent:

I had a discussion with our experts in Belize about the setup.

In an official point of view, you're right in what you have been informed about and what you read. However, in real life this is not how they are setup if literally not required by the client.

Actually the share capital in your case has to be USD 100k and can be paid in at the moment where the license is applied for or at the latest 12 months after the licenses has been received by the authorities, the requirement in order to do the latter is that there is prove (bank statement or financial report) that you have such money at the time the company is established, this is what we submit to the authorities and which has been accepted in the other cases we had.

Actually, there is an option to structure the company with an share capital of USD 50,000 to start with and extend it as the activity change.

In regards to the number of directors, we can appoint 2 at the time we apply for the license and add more later if needed by the client, otherwise we will apply for only 2 directors to be in charge for the operation and management, etc. of the company under special conditions which will match your organisation as you described it initially.

To sum up the requirements again that apply for your case specific, we need min. 2 directors and share capital to be paid in at the latest after 12 months is USD 100,000.

As you may read from the above, then if you know what you are doing the public available policy for Financial Service Companies / financial institution in Belize are not static and can be tailored to fit the regulations if done in a regulated environment.

Client reply:

OK thanks for the clarification.

Do you offer a nominee shareholder as well? If yes, what would be the cost of that service?

CCLOGIC Agent reply:

Thank you for your reply.

Nominee shareholder can be provided, we charge EUR 995 / year per shareholder.

Client reply:

We probably will decide to use your service for establishing a Financial Institution in Belize. We need some more details.

When I asked about requirements, you mentioned about requirements persons involved in the company. My question is, what sort of document we will have to prepare by ourself during registration process? Except those personal of course. What would the timeline for establishing such a company? Is that 8,5k EUR your fee only, or it include regulatory fees as well? When your fee needs to be paid? Before or after getting a licence?

CCLOGIC Agent:

Thanks for your reply, you will not need to fill anything, we will do the entire work for you, the only thing you need is to sign the forms and docs where indicated by us and where required.

Beside that we need the following documents:

- copy of passport

- utility bill not older than 3 months

- A CV - for details see en.wikipedia.org/wiki/Curriculum_vitae

The above documents we will need for each of the owners, shareholders of the company and director if you provide the director

It takes typically between 5 - 7 weeks to get it all setup and the application approved and license issued. The fee of EUR 8,500 covers the registration of the company including government fees, our fee and licensing. It does not include nominee services or all the other things we have spoken about.

The fee is payable upon signing and returning our engagement letter and your documents as per the list above, that's when we will start the process, most of the fee are government and licensing fee so we will not cover this on behalf of the client.