Crypto & Financial Services Licensing

Comprehensive licensing and regulatory filing services for crypto businesses and financial services providers in Australia. The firm provides end-to-end support for obtaining and maintaining all major Australian financial services licenses including Digital Currency Exchange (DCE) registration, AFSL, ACL, and APRA authorizations.

Digital Currency Exchange (DCE) Registration

Specialized expertise in AUSTRAC registration for virtual asset service providers (VASPs) and cryptocurrency exchanges. Services include DCE registration applications, due diligence letters for acquiring banks and payment service providers, and ongoing AUSTRAC compliance. Holley Nethercote was heavily involved in consulting with AUSTRAC during creation of Australia's Digital Currency Exchange regime and chairs Blockchain Australia's AML & Financial Crime Committee.

Australian Financial Services Licence (AFSL)

End-to-end AFSL application support including licensing roadmap advice, preparation and submission of applications, authorised representative appointments, and variation applications. Services cover all crypto-relevant authorisations including dealing in financial products, providing custodial services, operating a marketplace, and advice on financial products. The firm advises on the proposed crypto asset secondary service provider (CASSPr) licensing regime and crypto custody requirements.

Australian Credit Licence (ACL)

Comprehensive ACL application support for crypto-backed lending platforms, BNPL providers, and digital lending businesses. Services include licensing roadmap advice, preparation and lodgement of ACL applications, variation applications, credit representative authorisations, and advice on whether crypto lending activities require credit licensing under the National Consumer Credit Protection Act.

APRA Licensing for Crypto Fintechs

Specialist advice for crypto businesses seeking Authorised Deposit-taking Institution (ADI) status, particularly relevant for stablecoin issuers and digital banks. Services include advice on whether activities constitute a Purchased Payment Facility (PPF), restricted ADI (RADI) applications for fintech banking startups, prudential standard implementation, and managing APRA relationships.

Regulatory Strategy and Filings

Beyond initial licensing, the firm provides strategic guidance on structuring businesses to optimize licensing requirements, managing variation applications to expand authorizations, responding to regulatory inquiries, and maintaining ongoing license compliance. The team includes former ASIC staff providing insider perspectives on regulatory processes and expectations.

Global Crypto Exchange Expertise

The firm acts for some of the world's largest digital currency exchanges, providing practical guidance on navigating Australia's complex regulatory landscape including the interaction between DCE registration, AFSL requirements, and proposed CASSPr licensing. Services extend to regulatory filings, AUSTRAC reporting, ASIC correspondence, and managing relationships with multiple regulators.