Scoping regulated or perceived-high-risk activity

Crypto-asset services, gambling, FX/CFD trading, money remittance, crowdfunding and some cross-border ecommerce models sit under separate or extended AML guidance. Handling money on behalf of third parties raises the same questions. A licence confirms you can legally operate in a regulated sector; claiming to operate in one without a licence - or leaving it ambiguous whether your activity is regulated at all - is one of the recurring rejection triggers.

What resolves the ambiguity is scope, stated in writing: exactly what you do, and exactly what you don't. The pattern from the source guide's crypto-adjacent example generalises - "we are not a virtual asset service provider; we never custody, exchange or transmit crypto-assets on behalf of clients, and we hold no client funds" tells a reviewer precisely which rulebook does and doesn't apply to you.

If licensed: have the licence or authorisation ready, with its scope. If unregulated: state it explicitly in your business description, name the basis, and explain any partnership with a licensed entity (for example, a payment processor that converts crypto-denominated invoices to fiat before funds reach your account). If genuinely unsure: resolve it with a qualified source before applying - "unsure" on an application reads as unscoped risk.

• If I operate in a perceived high-risk sector, I've scoped exactly what I do and don't do, in writing.

  Only relevant for perceived-high-risk sectors - mark it not applicable otherwise.

• I can show my licence, or a clear written basis for why my activity doesn't require one - verified with a qualified source, not assumed.

These become trackable items in your checklist once your personalized plan is generated.

• How to describe your business so it's believed
• Red flags that trigger endless requests
• Your next step